GEP-19-46 14:21 FROM:PACE LEGISLATIVE OFFICE

1D:202 293 7eeg PAGE

accountability facilitated a well documented pattern of placing production ahead of. safety.

If and when a worker gets an occupational illness or a cancer that is likely work related,
few will bother to file state worker compensation claims because the burdens of proof are nearly
insurmountable, and admitting that an illness is occupationally related could jeopardize health
insurance coverage. Medical benefit plans uniformly exclude coverage for occupational illnesses
and injuries. For those of us who were made ill, or suffered an untimely death, legislation is
needed to cover 100% of medical costs, lost income or a lump sum payment. Nuclear workers
were placed in harms way to help win the Cold War. A federal remedy is needed for harms
created by the federal government. I hope your Committee will see to it that we are not left out
in the cold and that legislation will be enacted this year. At a minimum, such legislation should
mirror that adopted by the Senate in the Defense Authorization Act (S.2549) and filed in the
House as 8.5189. This approach will provide a building block for more comprehensive coverage

in the future, when other causative agents could be added.

L MOUTH F. OVIDE Wi ADE
MONITORING & PROTECTION FROM RADIATION, HEAVY METALS &
TOXIC CHEMICALS

In prosecuting the Nation’s cold war mission, workers were kept in the dark about the
hazards they faced. Information was provided based on a “need to know” basis—and production
imperatives determined what you needed to know. Breach of secrecy, even where safety was at
issue, could result in the loss of a security clearance. Even to this day, we don’t know what we
confronted. For example, when we started feeding irradiated recycled uranium back into the
process system, we never knew we were introducing contaminants (e.g., technetium, plutonium,
neptunium, etc.), nor were we adequately protected. Over 400 releases of uranium process gases

or fluorine have been documented and many more went undocumented.

A THE POR’ OXE Col ce) (705-E) CAUSED

INTERNAL RADIATION DOSES

The Oxide conversion facility, which operated frora 1957-1978, converted highly
enriched uranium (HEU) oxides into feed material. This was considered one of the most

Page 2 of 14

G


June 26, 1975 Interdepartmental Correspondence GAT-521-75-113

Subject: SAFETY PROCEDURES FOR HANDLING TECHNETIUM-CONTAINING
MATERIALS

“Cascade samples from Area 6 have recently been found to contain excessive amounts of
technetium-99 (Tc99), a potentially hazardous element because of its beta (B-) radiation. During
June 16-20, 1976, multigram deposits removed from the Inlet lines and valves to the Freon
Degrader were found to consist of 20 percent Tc99 by weight.

While safe procedures for dealing with materials containing enriched uranium are standard practice
at GAT, technetium contamination is a new and separate problem. The unfamiliar nature and
unexpected presence of large quantities of Tc99 demand that special precautions be taken by plant
personnel who must handle cascade equipment or materials contaminated with technetium.

Please initiate the necessary action to define the scope of the technetium hazards problem and
specify safe procedures for sampling, storage, and disposal of technetium-bearing materials from
operations involving cascade equipment maintenance to laboratory testing.”

October 2, 1975 Interdepartmental Correspondence GAT-242-75-121
Subject: TECHNETIUM IN X-705 EFFLUENTS

“Need for Immediate Action”

“As we have discussed, the beta gamma activity in the east drainage ditch has increased
astronomically during September. The Chemical Analysis Department has identified the major
source of this activity as beta radiation from technetium-99. The technetium activity in our Station
11 composite water samples during 1975 are shown in Figure 1. Station 11 is located on the east
drainage ditch immediately before it joins with Little Beaver Creek.

The weekly sample collected on September 29" showed a technetium activity of 67,600 d/m/100 ml
(1.79 ppm Tc). This weekly-average value is 101.5 percent of the recommended concentration
guideline2 (RCG) for uncontrolled areas published in ERDAM 0524. It is also over 300,000 times
the radiation limit specified by the State of Ohio (100 picocuries beta/liter). Note, however, that the
State and ERDA standards are based upon instantaneous concentrations. I would guess that our
peak Tc concentration is probably 20 times the average value. Therefore, we may exceed the

ERDA standard by a factor of 20, and the State standard by a factor of 6 million.

In the past the ERDA-ORO Environmental Protection Branch has been concerned if we discharge
effluents that are only a few percent of the RCG. They are very concerned about the current
situation; their major concern is that there may be “immediate repercussions from the Ohio EPA.”

The Ohio EPA has harried ERDA in the past about our radiological effluents exceeding state limits.
The State is complaining about liquid effluents that have contained less than 1 curie/year including
all radioisotopes, but the State has not yet learned that in September alone we have lost about 45



were eight safety engineers. In 1958, AEC published a set of “Minimum Safety Requirements” that
established safety goals, which could not always be achieved.”

“Hundreds of UF6 releases occurred from equipment failures and during maintenance, sampling,
cylinder handling, and connection and disconnection of feed and product cylinders. These releases
caused many intakes of uranium and HF burns, and they contaminated work areas and the

environment.”

“During the 1960s, the PORTS health physics group became concerned with increasing alpha
radiation levels in process and support facilities at the site. While no records were identified to
demonstrate that this issue was satisfactorily resolved, the period coincides with the processing of

recycled uranium at the Paducah Plant.”
-from pages 2, 4, 18, 27, 31, 35, 36, 37 38, 39, 45

August 27, 1962 Interdepartmental Correspondence GAT-810-62-54

Subject: HEALTH PHYSICS PHILOSOPHY AS A GUIDE FOR HOUSEKEEPING
PROBLEMS IN PROCESS AREAS

“Ben Kalmon has refined the Health Physics philosophy on contamination problems involving
housekeeping in the process areas and has prepared a procedure for determining the contamination
index for the X-326 cell housings. His group is still working on procedures for the determination of
contamination indices for the floor, top of compressor housings and inter-cell housings. These
procedures will be forthcoming. In the meantime, it would appear that the general philosophy
presented can be adapted to the conditions in the area using our good judgment to see that its
provisions are maintained.

The general philosophy should be passed down to the foremen for their use as a guide in handling
housekeeping problems involving contamination considerations. We don’t expect or desire that the

philosophy will be openly discussed with bargaining unit employees. Calculations of

contamination indices should be handled by the General Foremen and kept as supervisional
information to help in deciding the need for decontamination.”

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, VOLUME 1 - May 2000

“Inconsistent and incomplete external exposure monitoring and data management practices have
impacted PORTS’ ability to demonstrate that all exposures to personnel have been measured and

recorded accurately.”

“Although the AEC recognized the potential for transuranic contamination of the cascades, it was
not until 1965 appraisal that Oak Ridge identified a potential problem with transuranics and fission
products in the X-705E, and recommended studies to determine where they could concentrate in the
process. Although records indicate that PORTS reviewed the potential problems posed by feeding
reactor returns to the oxide conversion plant, detailed studies were not performed. Goodyear
Atomic Corporation concluded that transuranics were not a significant radiological concern when


“The State of Ohio mandated closure of important site landfills and the incinerator in the late
1980’s and early 1990’s. because of concerns over continued deposal of regulated wastes. The
Plant ceased offsite shipment of radioactive waste, and without approved commercial treatment and
disposal facilities, large amounts of radioactive waste, mixed hazardous and radioactive waste, and
radioactively contaminated PCB waste accumulated and were stored on site; much of this waste
remains in storage today. Numerous inspections and appraisals by the State of Ohio Environmental
Protection Agency (EPA), DOE (e.g., Tiger Team assessment), OR, and internal organizations
identified performance problems in the treatment, storage, and disposal of hazardous waste. By
1988, the State of Ohio EPA sent DOE and the Plant a notice of intent to file suit for hazardous

waste violations.”

“Despite the discharge restrictions, legacy environmental contamination exists in ponds, local

ditches, and streams.”

“While it is likely that PORTS air emission estimates were done in good faith, these estimates did
not reflect all the potential historical releases, including some that could have been significant such
as cell jetting. Evidence of contamination on roo9fs and grounds and recurring high workplace air
sample results in various locations, such as the oxide conversion facility, point to significant
unmonitored releases that had not been previously included in monitoring results. The Plant did not

perform continuous vent monitoring of radionuclides or fluorides until the mid-1980s, and previous
methods for estimating releases have been shown to be unreliable and in some cases non-

“Fluorine and fluoride compounds were used in significant quantities at PORTS and both by design
and by accident were vented to the atmosphere. Plant personnel have repeatedly complained of
offensive fluorine fumes, breathing difficulty, and respiratory tract damage from releases at the
fluorine generating facility and process buildings. The PORTS medical department rarely
confirmed significant health effects, but confirmatory surveys to establish release concentrations
provided unreliable results due to the rapid dissipation of released gases. Continuous
environmental monitoring for fluorides has been conducted for many years, and ambient samplers
sometimes indicated fluoride concentrations that exceeded release limits.”

“From the early 1980s until the middle 1990s, guard force personnel performed security drills
without protective clothing in spaces that were radiologically and chemically contaminated, while
workers in these same spaces generally used such protection.”

“Testing in 1986 identified inaccuracies with the UF6 negative test protocol and the strong
possibility of false negatives. Consequently, when equipment was removed for maintenance,
outgassing was common, despite an earlier determination of UF6 negative.”

-from pages 4, 5, 18, 20, 35, 40, 52
TIGER TEAM REPORT 4-1990 “TRANSITION FROM AN INDUSTRIAL

ENVIRONMENT TO A NUCLEAR ENVIRONMENT”

“Many operations and maintenance activities at PORTS involved hazardous conditions and the
potential for exposure of personnel to physical, radioactive, and chemical hazards. Enrichment


this all changed. Today, in certain buildings and areas, you have to monitor clothing and shoes
whenever you leave the building to make sure you aren’t tracking radiation into clean areas or off
plant site. Primarily, the problem lies in the first 35 years. What were the former workers
exposed unknowingly or perhaps even knowingly? We know that they are having many health

problems, such as cancers and respiratory problems, and in numbers far greater than would be

expected.

2. INSPECTIONS WERE INFREQUENT UNDER DOE’S SELF REGULATION

A July 1980 Comptroller General report, Department of Energy’s Safety and Health
Program for Enrichment Plant Workers Is Not Adequately Implemented (EMD-80-78), found
that DOE’s Oak Ridge Office, which had oversight responsibility for health and safety, had not
conducted a safety inspection at Portsmouth for 3 years and was not adequately responding to
worker safety complaints. Unannounced safety inspections were supposed to occur annually at
each plant, but even when they were inspected, the Oak Ridge Office “does not, as part of an
inspection or any other visit to an enrichment plant, monitor for radiological contamination.” Oak
Ridge explained the absence of inspections on a staff shortage, which the Comptroller General

noted was attributable to Oak Ridge paying safety inspectors at a lower grade than elsewhere in

the DOE complex.
3. HEALTH EFFECTS ARE ON THE MINDS OF MANY CURRENT AND
FORMER WORKERS

Currently, I am a retiree representative for the Worker Health Protection Program
(WHPP). This program is funded by a grant authorized under Section 3162 of the FY 93
Defense Authorization Act, and administered by Queens College and the Paper, Allied-Industrial,

Chemical & Energy Workers Union (“PACE”). It gives former workers a one-time complete

Page 9 of 12


Subject: ACTION PLAN TO ABATE AIRBORNE AND SURFACE CONTAMINATION
LEVEL INCREASES IN THE X-326 BUILDING

“We have analyzed the X-326 Building to evaluate what change may have caused the increases in
contamination levels. It is our conclusion that the primary source is from the cells that are shut
down, but not at a negative and held atmospheric pressure. This allows process gas (PG) and
technetium (Tc-99) in the cell to escape as minor pressure changes occur (due to changes in
atmospheric conditions, temperature, or operational changes of cell pressure), allowing PG into X-
326 cell floor atmosphere. This condition exists in fifty-five cells as of today.”

Comment *It should be noted that these fifty-five cells were spread out over the entire building;
therefore, there was airborne and surface contamination over the entire building.

December 14, 1992 - X-326 AIRBORNE/CONTAMINATION ABATEMENT

December 18, 1992 - Internal Correspondence

Subject: ACTION PLAN TO ABATE AIRBORNE AND SURFACE CONTAMINATION
LEVEL INCREASES IN X-326

“This condition started developing in July of this year as preparations for the Highly Enriched
Uranium (HEU) suspension project resulted in an upset to the normal cascade configuration and
concluded with a large number of cells off stream without UF6 negatives.”

“There are several factors considered in establishing priorities for obtaining cell negatives. Those
cells with good leak rates (maintain pressure below atmosphere) will be at the bottom of the priority
list for obtaining a negative. Those with bad leak rates become the higher priority for negatives.
The following factors must be considered in prioritization; grams of U-235 in the cell, visual
evidence of outgassing, maintenance required to repair cell leaks, permits and radiological
boundaries.

II. Actions:

5. All suspect cells were inspected for evidence of outgassing by looking for deposits. There were
several cells identified as having outgassed in the past.

6. A meeting was held to discuss the impact upon the cascade and nuclear criticality safety
concerns. Management assessed the need to rapidly stop the source as the number one priority.
Also discussed were how premature excessive restrictions and personal protection would hinder the
rapid achievement of the number one priority, ultimately resulting in increased overall exposure
before the problem is resolved.

15. Cell negative priorities will be established by first determining leak rates. Then cells with bad
leak rates will be evaluated based upon visual outgassing evidence (deposits), and U-235 mass in

the cell. Cells with good leak rates will be maintained at about .5 psi below atmospheric pressure
through meticulous monitoring and actions by operators.


May 2, 1995 POEF-050-95-053

Subject: CONTAMINATION CONTROL SUBCOMMITTEE MEETING MINUTES
FROM 4/21/95

“Conclusions by item:
2. Decontamination of the X-326 Building for contaminated area reduction efforts. It was

the desire of the committee that progress in this area continue. Herman R. Potter agreed to
follow up on the elevator issue for the X-326 Building. Costs and schedule for completion
are two of the items to be included in the follow-up. Ron Smith agreed to follow up and
determine what action is required to get Mike Gill released for work on the Contaminated
Area Reduction Subcommittee for work in the X-326 contaminated area reduction.

May 2000 - OFFICE OF OVERSIGHT ENVIRONMENT, SAFETY AND HEALTH
INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION

PLANT, VOLUME 1

p.39 & 40, 31.1.8 Contamination Control “Records of radiation and contamination surveys were
readily available from the start of the plant operations. Survey records for all major buildings
indicate contamination levels above limits over many years. In some cases, follow-up surveys
noted that areas continued to be contaminated above limits, with continued recommendation for
decontamination. However, rigorous enforcement of decontamination requirements was not

evident.

Areas were categorized as “Red, Orange, or Clean” as early as 1955. Permanent Red Job areas
included portions of X-705, X-744G, X-342, X-344, and X-746. Classification of other areas was
subject to change based on survey results. In some cases, classifications were not performed
correctly. In 1980, surveys showed that portions of X-326 met the criteria for a Red Job area but
were not categorized as such. A union grievance filed resulted in a dedicated crew assigned to
decontaminate X-326 to avoid classifying X-326 as a Red Job area.”

p.48, Jetting/Venting “There were times when UF6 was inadvertently/deliberately vented from
purge facilities.”

p. 82, “Technetium-99 is a weak beta emitter with a radioactive half-life of 213,000 years and was
introduced as PORTS in recycled reactor feed. The primary exposure pathways are ingestion or
inhalation. Protective clothing would adequately shield the low-energy beta particles emitted by
technetium. Technetium passed through the Paducah cascade as a volatile compound of fluorine,
depositing on internal surfaces of the cascade and contaminating the uranium product. Similarly,
technetium at PORTS contaminated many areas, including cascade equipment. The AEC did not
specify a limit for technetium in UF6 feed but controlled the concentration of technetium indirectly
to about 10 ppm by limiting gross beta due to fission products. In addition, some customers
established a 10 ppb limit on technetium in product cylinders. There was evidence that workers had
some exposure to technetium.”

Comment *Even though it tended to concentrate at the top of the cascade, Technetium was a major
problem throughout the cascade and other buildings.


6. Area monitoring should continue to be performed in areas where uranium is routinely stored
or handled to characterize potential neutron exposures better. In addition, efforts should be
taken to evaluate potential neutron doses associated with known uranium deposits within the
cascade.

7. Past maintenance activities and personnel involved in physically removing uranium deposits
should be evaluated to provide better insight on the doses attributable to the SLOW COOKER
phenomenon.

8. Administrative changes or decisions regarding issues in the health physics dosimetry program
(doses below the limit of detection, abnormal chip ratios, investigative reports, etc.) should be
better documented and routinely reported to the workforce to educate, inform, and solicit
questions about how the changes or decisions will affect their dose records.”

February 17, 1998 - U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND
HEALTH ADMINISTRATION CITATION AND NOTIFICATION OF PENALTY

Citation 1, Item 7, Type of Violation: SERIOUS

29 CFR 1910.1020(d)(1)(ii): “The employer did not preserve and maintain records of employee
exposure of all employees for at least thirty years:

a. Records of radiation exposures for all company employees were not adequately maintained
from 1993 to 1995 in that some employee exposures were arbitrarily assigned and based
solely upon their past exposures which may have differed from exposures experienced
during the period relating to the assigned dose.

b. Records of radiation exposures were not accurately preserved and maintained in that for the
period of 1993 through 1995 some thermoluminescent dosimeters (TLDs) which were used
to measure and create a record of employee radiation doses, were not evaluated and a zero
dose was assigned to an employee where the exposed TLD which was assigned to the
employee was damaged.”


on “normal” facility operations is a symptom of a larger problem. The X-705 facility was not
designed for its present throughput, or with present regulatory standards in mind.

Background

“H”’ area — On 2/28/94 through 3/2/94, the air samples drawn in the X-705 at the “GG”, “GJ”,
“GO”, and “GR” locations indicated alpha activity greater than the Administrative Control Level

(ACL) requiring respiratory protection.

It appears the cause of the high airborne condition was the removal of existing ventilation duct
work and subsequent clean up operations in the “H” area. Therefore, workers with routine access
to these areas were probably exposed to airborne contaminant levels above the ACLs requiring
respiratory protection for soluble uranium and radioactivity. Additionally, there was apparent
spread of loose surface contamination outside the work area (H area). Ultimately, administrative
controls must maintain radiation exposures ALARA. Present trends suggest that we are not
meeting this goal.

April 21, 1994 - INTERDEPARTMENTAL CORRESPONDENCE

Subject: POTENTIAL CIVIL PENALTIES FOR RADIATION PROTECTION
PROBLEMS

As requested, Dan Minter, Dave Simpson, and myself reviewed the documentation of the NRC
action at the LaSalle County Station and compared the reports against recent events at
Portsmouth. The incident at the LaSalle County Station can be summarized in two sets of
statements.

- The LaSalle County Station was cited by the NRC for:
1. Failure to perform an adequate evaluation of radiological hazards;
2. Failure to use engineering controls to mitigate the creation of an airborne radioactivity
area; and
3. Failure to follow radiation protection procedures.

- The NRC identified four programmatic weaknesses:
1, Management oversight was inadequate;
2. Ineffective pre-job meeting;
3. Poor worker and HP performance; and
4. Ineffective long term corrective actions

The following conclusions were made:
1. Portsmouth has the same potential as LaSalle.

This statement is made based on the review of the X-705 ALARA review conducted in March
1994. The lack of engineering controls, pre-job meeting, and failure to recognize the potential


that the decision to operate the area as a “red” area would be a management decision.
Discussion with employees working in the contamination area revealed that they were not

aware of the contamination.

Finally, in January 3, 1980, an employee was told of the results of the September 1979
contamination survey. On January 7, 1980, the Oil, Chemical and Atomic Workers Union
requested that the area be designated as a “red job” area. The contractor refused, citing a
contamination survey conducted by the contractor’s production group, which showed
contamination below the “red job” level. The union requested a copy of the production group’s
survey but was refused, even though DOE regulations require that such surveys be available to
employees. On January 22, 1980, the union filed a complaint with Oak Ridge Operations
Office which, after investigation, determined that the area should be designated as a “red job”
area and that decontamination should begin.

DOE appraisals or inspections should have revealed this problem. Knowing of the
contamination, appraisals should have included reviewing decontamination procedures
underway. This effort would have revealed the contractor’s lack of action. In addition,
inspections, which included radiation monitoring in addition to non-radiological safety and
health concerns, could have revealed the continuing contamination levels. Inspectors, aware of
the contamination problem, could also have learned of the contractor’s lack of action by
interviewing plant employees in the contamination area.

*1/A “red job” area involves the issuance of company-owned protective clothing, additional
shower time, etc., to avoid the contamination of employees and the spread of the contamination
from the “red job” area.”

May 1990, P.40 & 41 - CONTAMINATION CONTROL (OOESH) VOL.I, DOE

“Records of radiation and contamination surveys were readily available from the start of

plant operations. Survey records for all major buildings indicate contamination levels above limits
over many years. Recommendations for decontamination of locations exceeding PALs were
typically made and noted by Industrial Hygiene and Health Physics personnel on the survey forms.
In some cases, follow-up surveys noted that areas continued to be contaminated above limits, with
continued recommendations for decontamination. However, rigorous enforcement of
decontamination requirements was not evident.”

“As early as 1955, permanent Red Job areas included portions of X-705, X-744G, X-342, X-344,
and X-746. Classification of other areas was subject to change based on survey results. In some
cases, classifications were not performed correctly. In 1980, surveys showed that portions of the X-
326 met the criteria for a Red Job area but were not categorized as such. A Union grievance was
filed and an investigation was performed to review the matter. Other problems with this
classification system included the lack of formal restrictions on movement of personnel and
equipment in and out of contaminated areas. In 1977, Industrial Hygiene and Health Physics noted
that employees wearing contaminated clothing were permitted to enter clean areas such as the
cafeteria, and individuals were allowed to eat and smoke in contaminated areas. A change in
Goodyear Atomic Corporation standard practice procedure SPP H-8, “Health Protection Measures
for Red Orange and Contaminated Job Assignments, was proposed at that time. In 1979, Goodyear
Atomic Corporation established a Contamination Control Steering Committee to review the overall


neptunium or other transuranics until the 1990s, even though recycled reactor were fed into the
Portsmouth cascade beginning in 1955, and the AEC knew that the reactor “tails” at Paducah
contained neptunium in 1957. Today, it might seem incomprehensible that workers were not
tested for potent carcinogens such as plutonium until 40 years after plant operations commenced.
DOE’s reports reveal that “transuranics were a special problem in 1965, 1966, 1975 and 1976
when recycled foreign reactor feed in the form of uranyl nitrate was converted to oxide in the
calciner.” A 1979 analysis of two cascade deposits revealed relative high concentration of
neptunium-237 (55 and 60 percent of total alpha activity), however, there was no change in
procedure to protect workers. Management was basing its radiation protection program on
worker exposure to uranium even though the specific radioactivity of neptumum is 2000 times
higher than depleted uranium.*

EB Dose RECORDS HAVE BEEN ‘ZEROED’ OUT OVER LIABILITY CONCERNS

A Senate Government Affairs hearing held in March 2000 confirmed that management
directed that a guard’s radiation dose records be “zeroed” out after he had an uptake and was
hospitalized, because of the concern that he would bring a worker comp claim. We have no idea
if this was an isolated case or a regular management practice on the part of Lockheed; however a
DOE report stated, “an internal Lockheed martin Utility Services investigation concluded
improprieties may have existed in the Plant’s dosimetry program that resulted in the assignment

(OUNTED) SIGNIFICANT.

In the late 1990s, OSHA was called into Portsmouth after complaints filed by OCA'W and
the Guards union disputed the aceuracy of radiation doses. OSHA has jurisdiction over USEC,

® Independent Investigation of the Portsmouth Gaseous Diffusion Plant, Volume 1: Past
Environment, Safety and Health Practices, Department of Energy, Office of Environment Safety

and Health, May 2000, pp.19, 35.

7 ibid, pp. 37.
Page 6 of 14


curies of technetium. However, note that we now are required to send the Ohio EPA a complete
quarterly report of our radiological effluents; the first report will be sent near the end of October.”

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, VOLUME I - MAY 2000

“External conditions and influences have had a significant effect on the ES&H-related behavior and
intentions of both management and workers at PORTS, especially during the first two decades of
operation. When PORTS began production activities, World War II and the Korean conflict had
recently ended, and the Cold War was a reality. The work being done was classified, involved high
technology, and was important to the national defense. The “need to know” was an ingrained
security policy that had a major effect on attitudes toward sensitive operations and materials.
Management and the Atomic facilities, were largely self-regulated, and guidance and regulatory
requirements were evolving. Significant industrial and environmental legislation that would focus

attention and actions toward greater protection of workers and the environment was not enacted
until the 1970s.”

“Although Plant management was aware since the 1960’s that transuranics and fission products had
been introduced into Plant facilities as early as 1957, until 1975, radiological effluent monitoring
was only conducted for uranium isotopes and related indicator parameters. In 1975, technetium,
and subsequently transuranic contamination, was unexpectedly discovered in liquid effluents from
X-705. Technetium was also detected in airborne discharges. This discovery triggered significant
long-term efforts by Plant personnel to isolate sources of technetium and transuranic contamination,
develop or improve control methods, and establish appropriate monitoring protocols.”

“In the mid-1970s, the first evidence of technetium-99 began to appear in X-326 equipment. Some
of the instruments became heavily contaminated with uranium compounds and technetium-99.
Reportedly, the majority of space recorder background radiation came from technetium-99 that had
plated out in the system. Instrument mechanics reported its frequent presence in instrument lines as
a dark, gooey sludge having the appearance of black tobacco juice. The presence of technetium-99
resulted in significant clothing and personnel contamination and was difficult to remove.”

-from pages 2, 4, 47, 56


“Knowledge of the whole picture is crucial to environmental cleanup. A narrow focus can hinder
progress. It is now common practice in most industries to identify wastes that come from each part
of a process and to determine how best to minimize or prevent their generation. If it did not
understand these connections, the Department of Energy could create other problems while
attempting to resolve the original concerns. For example, how should the Department manage new
wastes that will be created from cleaning up contaminated soil, water, and buildings?”

“FROM SECRECY TO OPENNESS”
“During the Cold War, a large amount of information about the nuclear weapons complex,

including information on issues related to the environment, safety, and health, was withheld from
the general public because of concerns about national security.”

“TWO STATEMENTS BY JOHN GLENN, U.S. SENATOR, STATE OF OHIO”

“1985: Hearing of the Governmental Affairs Committee, U.S. Senate, in Cincinnati, Ohio:
“Although most of us have become aware of the problems at Fernald only recently, the situation

has existed for three long decades. And although we may not be able to do anything about the past

releases of radiation from the plant, I strongly believe that the public has a right to know about such

releases.”

“We must see to it that what happened in the past is never repeated. . . . I’m fully aware of the
economic and national security benefits the plant provides, but, as I said when I toured Fernald last
month, while plants like Fernald are essential to the security of our country, we must see to it that

the cost of that security does not include the health of our people.”

“1994: Confirmation hearing before the Governmental Affairs Committee, U.S. Senate, for Alice
Rivlin as Director of the Office of Management and Budget:

“In 1985, the people at Fernald in Ohio wanted me to come out. They had problems there. I went
out, not knowing how valid their concerns were, and found that they were very valid. We did
General Accounting Office (GAO) studies then of the other spots in the nuclear weapons complex

- all over the country, some 11 States and 17 different major sites._ Cleanup had been put away at that
time. ‘The Russians are coming: we have got to produce.’ ‘What are you going to do with the

waste?’ ‘Put it out behind the plant.”

“_..When we started this, the General Accounting Office estimated that to clean up the whole
weapons complex was somewhere between $8 to $12 billion. Now the latest GAO estimate is $300
billion, if we can figure out how to do some of it, and over a 20- to 30-year period....1 am
concerned about how we take care of these long-term items that are going to require a year-by-year
effort----Cleanup is not going to get cheaper as we go along and it is something that does have to be
done because of the danger to our communities.”


primarily in areas where uranium daughter products tended to concentrate. Documents revealed
and interviews conducted with former production workers and Industrial Hygiene and Health
Physics Department staff members indicated that these areas included ash receivers, sintered metal
filter baths, converter disassembly work, cylinder washing, oxide conversion, and the technetium
and uranium recovery processes. Exposure evaluations during the med to late 1950s indicated
numerous instances of workers being placed on work restriction based on whole body exposures
that were determined to be in excess of PALs. Documents also indicated that before the mid-1980s,
Goodyear Atomic Corporation had never performed extremity monitoring for any operation or
work activity. Documents indicated that various VALVES ASSOCIATED WITH PIGTAIL
OPERATIONS HAD RECORDED BETA READINGS AS HIGH AS 1 RAD/HOUR. Feed
production plant ash receiver areas had floor readings of 5 rad/hour beta. Operators routinely
handled these valves and equipment in X-705 and other locations where significant hand exposures

could occur.

“Dosimetry Programs at PORTS from 1954 to 1992 were neither calibrated nor monitored for
neutron exposures. A National Institute of Occupational Safety and Health (NIOSH) evaluation for
PORTS studied the neutron radiation issue in 1997 and concluded that there was potential for
chronic low-level neutron exposures in areas where uranium was stored (cylinder yards), handled
(feed and withdrawal areas), or solidified within the cascade (deposits).”

“In 1998, OSHA cited USEC for failing to preserve and maintain records of employee exposure of

all employees for at least 30 years. OSHA found that “records of radiation exposures for all
company employees were not adequately maintained from 1993 to 1995 in that some employees’
exposures were arbitrarily assigned and based solely upon their past exposures which may differed
from exposures experienced during the period relating to the assigned dose.” Furthermore, “records
of radiation exposures were not accurately preserved and maintained. For the period 1993 to 1995,
some TLDs that were used to measure and create a record of employee radiation doses were not
evaluated, and a zero dose was assigned to an employee where the exposed TLD which was
assigned to the employee was damaged.” In response to the outstanding OSHA dosimetry citation,
USEC initiated a dosimetry reconstruction effort.”

“Administrative corrections to the site’s dosimetry program to prevent reoccurrence of these issues
were implemented, however the documents indicate that ”the DOELAP (Laboratory Accreditation
Program) TLD database, although reliable, still had overall validity concerns.”

(nconsistent and incomplete external exposure monitoring and data management practices have
impacted PORTS’ ability to demonstrate that all exposures to personnel have been measured and

recorded accurately.)”

“During the 1950s and 1960s, urine samples were typically analyzed for uranium, and in most cases
for alpha activity. Typically, the sample collection procedure involved the collection of Monday
morning urine specimens (the morning following two or more days off the job). This was non-
conservative, and the collection date evolved to a “Friday” sample during the 1970s and 1980s.

Considering that numerous routine urinalysis results reflected uranium intakes in the years of

operation and the rate at which soluble uranium is excreted, some uranium intakes were likely not
identified or properly investigated. Technetium analysis was added in the 1970s.”

“Transuranics were a special problem in 1965, 1966, 1975, and 1976, when recycled foreign reactor
feed in the form of UNH was converted to oxide in the Calciner.”


SEP-29-@@ 18:22 FROM:PACE LEGISLATIVE OFFICE 1D: 2@2 293 7a9ea PAGE

hazardous operations at Portsmouth. Unacceptably high levels of radiation exposures were
documented when the Oak Ridge Operations Office made one of its infrequent inspections to this
plant, including high airbome contamination in the work areas, employees allowed to eat in the
contaminated cold trap room, lack of respirator protection and increasing radiation lung burdens
for chemical operators. A DOE reports notes: ;

The operating contractor was aware of safety problems in X-705-E;

however, production schedules were viewed as more important.

Health physics concerns prompted the contractor to install gloveboxes in 1967 to isolate
workers from ingesting the fine uranium oxide powders. However, even these glove boxes failed
to protect workers adequately, as the gloves deteriorated from exposure to corrosive fluorides.
Airbome uranium contamination problems continued caused by the “burn through” of the
fluorination tower, leaks from cold traps and product withdrawal and breaches into the system.
Two workers were put on permanent work restriction due to ingestion of insoluble forms of
uranium and had measured lung burdens over 50% of the allowable limits many years later.

A good friend of mine—Robert Elkins-worked in the X705-E oxide plant from 1962-65.
By 1965 he was placed on permanent work restriction due to high internal body counts of
radiation. He had enriched uranium, technetium-99, neptunium-237, potassium and cesium in his
body. When he retired in 1985 he was still on permanent restriction. _In the 15 years since his
retirement, the plant management has never contacted him to check on his health or suggest that

he be monitored after retirement.

However, the government didn’t ignore Mr. Elkins. He was contacted by an individual

from Hanford (presumably the transuranium registry) who wanted to pay him $500 for his
cadaver so the government could study what happened to the radiation in his body after he passed

) Independent Investigation of the Portsmouth Gaseous Diffusion Plant, Volume I: Past
Environment, Safety and Health Practices, Department of Energy, Office of Environment Safety

and Health, May 2000, pp. 46.
Page 3 of 14


SEP-19-@@ 1@:24 FROM:PACE LEGISLATIVE OFFICE

1D:202 293 786@ PAGE

radionuclides or toxic chemicals.

In the late 50’s and early 60’s, we had big layoffs. As a result, the preventative
maintenance program went down hill, causing the equipment to not be properly maintained.
Prior to this layoff, the lab handled all sampling equipment, and assured that there was <10 ppm.
uranium hexafluoride in the system—called a “negative”—prior to it being opened up for
maintenance work.

Due to cutbacks, operators had to take over this work of the lab technicians, however, we
were required to use a new system for testing that consisted of pulling a sample through a tube of
salicylic acid (white powder). If the powder didn’t change color in three (3) minutes, then it was
assumed the system was safe to enter (<10 ppm UF6). We now know this was never an approved
method, and there was no research done on this approach. Consequently, we put maintenance
workers in harm's way when we issued a hazardous work pexmit stating that system was safe to

enter.

In reality, some eating areas became so contaminated that management had to build designated
lunch rooms that were surveyed on a regular basis and kept clear.

Due poor contamination control, certain buildings were becoming more contaminated.
For example, leaks from the ERP station had spread comtamination in the X-326 building.
Compressors would malfunction and process gases (UF6) would leak to the atmosphere”. On
one occasion, it was so bad that it looked like a fog moving up the 4 mile long building. When I

" Process gases were routinely vented to the atmosphere to obtain “negatives” to prepare

the cascade cells for maintenance. Records show 23,000 Ibs of uranium and 27 curies of
technetium -99 were released to the atmosphere, and many more releases went unrecorded
because vent emissions were not continuously recorded until the mid 1980s.

Page 9 of 14

13/


SEP-19-90 10:22 FROM:PACE LEGISLATIVE OFFICE

ID: 202 293 7860 PAGE

operations results in chronic low level neutron exposures. Workers who were called in to clean-
out “freeze ups” of uranium inside of the cascade would be particularly at risk. When high dose
readings were found on badges, they were routinely determined to be equipment failures and
summarily discarded.

Cc Wo TO TECHNETIUM-99 ONTTORING

Technetium-99 (Tc-99), a fission product, was introduced into the cascades beginning in
1955 from recycled uranium reactor tails, most which had been first processed at Paducah. DOE
has found that workers were not monitored until 1975, resulting a 20 years of missing exposure
data. Once monitoring began it is clear that significant uptakes went unmeasured. Worker urine
dose records from CY 1976, 1977 and 1978 indicate that 27% of the chemical operators at
Portsmouth tested positive for Tc-99 (66% tested positive for uranium)‘. J vivo hing monitoring
established that 2 of the 45 maintenance mechanics had positive confirmed doses of Tc-99 to the
lungs. Curiously, 563 mechanics were tested for uranium over a three year period, but only 45
were tested for Te-99 or neptunium-237—a far lower exposure rate than for operators. Depending
on whether the Tc-99 was in a vapor or solid form, special personal protective equipment (such
as supplied air respirators) was required, but not provided until the early 1980s. One pregnant
worker had a calculated dose 800 millirem to the fetal thyroid’ of her 10-11 week old fetus,
providing further evidence of inadequate worker protection. In 1979, a Tc-99 release in the
convertor maintenance area caused the internal contamination of six workers as high as five
times the plant restriction levels.

D. co

DISCLOSED UNTIL THE 1990s

At the production level, we were never told about or tested for exposure to plutonium,

AND PL! WERE NOT.

+ Response to Freedom of Information Act Request by OCAW to the DOE, July 1, 1982.

5 4 July 22, 1976 letter from Karl Hubner, Oak Ridge Associated Universities to E.V.
Hansen, Goodyear Atomic, states: “The dose of 0.8 to 1.0 rad to the thyroid gland of a fetus is
considered to be insignificant, and there is no reasonable chance of damage to this organ in terms

of cretinism.” The letter qualified this conclusion by stating: “calculations were based on some
gross assumptions that had to be made because of insufficient data.”

Page 5 of 14


“Routine, accidental, diffuse, fugitive, and planned emissions of radioactive materials and fluorine
to the environment have occurred at PORTS since the beginning of operation in 1954.” “Vent
emissions at PORTS were not monitored continuously until the mid-1980s. “The unreliability of

space recorders and the inaccuracy of grab sampling when compared to continuous monitoring
indicate that emissions may be have underestimated.”

“Industrial Hygiene and health Physics summary reports for the late 1950s to late 1960s indicated
that it was common to have stationary and portable air samples in excess of limits. These above-
limit samples typically were related to process upsets, equipment failure, or maintenance activities,
and were valid high readings. Although logbooks indicated many dusty operations or smoky
conditions in all buildings, most of these samples were related to operations in X-326 and X-705.”

“In 1957, radiological surveys at the Paducah Plant identified that neptunium,-237 was present in
the enrichment cascade. Although the AEC recognized the potential for transuranic contamination
of the cascades, it was not until a 1965 appraisal that OR identified a potential problem with
transuranics and fission products in X-705E and recommended studies to determine where these

materials could concentrate in the process. Records reflect that PORTS then reviewed the potential
problems posed by feeding reactor returns to the oxide conversion plant; however, detailed studies

were not performed.”

“Many operations and maintenance activities at PORTS involved hazardous conditions and the
potential for exposure of personnel to physical, radioactive, and chemical hazards.” “Leaks and off-
gassing from process equipment or components being repaired or replaced exposed workers to
airborne uranium, transuranics, fission products, fluorine, and hydrogen fluoride (HF) gas. Others
worked with, or were exposed to, various hazardous materials and chemicals such as asbestos,
trichloroethene (TCE) and other solvents, polychlorinated biphenyls (PCBs), acids, chromium,
nickel, lithium, welding fumes and gases, and mercury. Radioactive or hazardous materials were
spilled or released to the environment from production related facilities and attendant work
activities.”

“Qver its entire period of operation (1957 to 1978), the oxide conversion process was probably one
of the most hazardous radiological and chemical operations at PORTS.”

“Probably the most hazardous operations at PORTS involved the operation of the oxide conversion
plant, which had continuous airborne and surface radioactive contamination problems over its 21-
year lifetime, from 1957 to 1978. Personnel working in this facility were exposed to transuranics
from recycled reactor fuel feed and to insoluble airborne uranium oxides. Several workers, later put
on permanent restriction from working in airborne-contamination areas, received significant intakes
that were still detectable in their lungs decades later. Maintenance and modification activities that
required breaching process systems or components also exposed workers to radioactive uranium
hexafluoride (UF6) process gas and HF. Decontamination activities in X-705 (Decontamination
and Cleaning Building) and elsewhere involved exposures to hazardous solvents and generated the
largest amount of radioactive and hazardous liquid waste on site.”

“Early safety engineers were transitioned staff from Human Resources Department, with no formal

safety background, training, or ion for becoming safety engineers. During this period, there



SEP-1e-WB 1:1 PROM: PACE LEGISLATIVE OFFICE 1D: 202 233 7aea

SEPTEMBER 21,2000

REGARDING |
HISTOR WORKING CONDITIONS AT YY?
RT: OxIO GASEOUS Dirrusi
AND
CON JONAL ACTION: ADDRESS WORK®) R
ATI LNE: ‘OR DO’ Wi

Sam Ray

128 Overlook Drive
Lucasville, OW
740-259-2863

PAGE

4a


implemented. The presence of transuranic contamination in feed material was not adequately
considered in the design or operation of the oxide conversion process.

Although the tower room typically contained the highest radiation and contamination levels, most
operations and maintenance exposures did not occur in the tower room. Primary activities
resulting in exposures in excess of PALs included handling of oxide powders in preparation for
feeding to the towers, changing the tower feed screw, connecting and disconnecting pigtails, and
performing maintenance on cold traps plugged with foreign materials.

A handwritten report entitled; “Oxide Conversion as Viewed by Development” was written by a
member of the Development Department (circa 1966), in response to a significant error in the
uranium mass balance in the X-705E. The report explained that the oxide conversion process was
originally established as a waste recovery process and not a production process. The subsequent
introduction of reactor returns converted the X-705E into a production facility, requiring a
capacity that “it was ill equipped to handle.” The report further explains that uranium inventory
control and health physics concerns were secondary to production schedules and costs, until
“eventually the inevitable happened.” The author’s reference to “the inevitable” was directed
primarily at the uranium inventory ptoblem, but also refers to health physics problems. This
report provides evidence that the operating contractor was aware of safety problems in the
X-705E; however, production schedules were viewed as more important. The report also refers to
the practice of “de-smoking ash pots through the building ventilation system” as a possibility for
physical losses of small quantities of uranium. Since the building ventilation system was
unfiltered and reactor return materials had been processed, transuranics from the ash pots likely
entered the building ventilation system and were subsequently released to the environment but not
monitored.

A 1976 memorandum (Memo GAT-922-76-184) identified transuranics as a problem at PORTS,
especially in the oxide conversion process. PORTS had an existing inventory of transuranic-
contaminated feed materials for oxide conversion and wanted to process that material. Based on
recommendations from Oak Ridge, Goodyear Atomic Corporation performed a variety of process
improvements and test runs to model fluorination of transuranics and reduce system leaks and
contamination. On September 13, 1978, Health Physics management determined that those
efforts were not sufficient and recommended shutting down the X-705E due to unacceptable
health risks. On October 1, 1978, the oxide conversion facility was placed in a standby status;
then on December 14, 1978, Goodyear Atomic Corporation requested cancellation of the oxide
conversion project.

It appears that during its entire operation, the oxide conversion process placed Plant personnel
working in the area, as well as security guards who may have been on patrol, at risk of exposure
to chemicals and airborne radioactivity. Processing of transuranic-contaminated material was not
adequately anticipated in the original or subsequent designs or operation. Samples obtained after
shutdown showing the presence and level of transuranic contamination in the facility indicate that
worker airborne exposures could have exceeded the acceptable standards, especially given the
apparent lack of discipline in respirator use.

-from pages 45, 47, 49, 50


basis document for rad protection, which would have included the protocols for conducting a

monitoring program for transuranics.

D. CONTAMINATION CONTROLS WERE NON EXISTENT OR WOEFULLY
INADEQUATE UNTIL THE 1990s

When I was hired in 1954, process operators were not allowed to wear coveralls or safety
shoes. If clothing became contaminated, we took this contamination home with us on our
clothing and shoes. To my knowledge, all crafts (such as electricians, maintenance mechanics,
etc) were allowed to wear coveralls and safety shoes. Some were mandatory. Sometime in the
60s, coveralls became optional for process operators; however, it wasn’t until the 90’s when

contamination controls were implemented that they became mandatory. In reality, they should

have always been mandatory.

E. DosE RECORDS HAVE BEEN ‘ZEROED’ OUT OVER LIABILITY CONCERNS

As others will testify today, management directed that a guard’s radiation dose records be
“zeroed” out after he had an uptake and was hospitalized, because of the concern that he would
bring a worker comp claim. We have no idea if this was an isolated case or a regular

management practice.

F. RADIATION DOSES WERE ARBITRARILY “ASSIGNED” (INSTEAD OF BEING

COUNTED)
OSHA was called into Portsmouth after complaints filed by the Oil, Chemical & Atomic

Workers Union (OCA W) and the Guards union questioned the accuracy of radiation doses.
Management directed that doses be administratively “assigned” when the health physics staff had
trouble reading dose badges. One practice involved pinning a dose badge to the wall and running

a scanner over it and assigning this dose to any person whose dose badge didn’t read out on a

Page 5 of 12


PORTSMOUTH GASEOUS DIFFUSION PLANT (PORTS)

RADIOLOGICAL/CONTAMINATION PROFILE
(Compiled and Edited by: Jeanne Cisco, Paul Mullens and Sam Ray)

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, VOLUME 1 - May 2000

“The environmental monitoring program at PORTS was initiated in 1955.

“During the 1952-1953 period, the AEC approved the enrichment processing of production reactor
tails through gaseous diffusion process. In 1957, radiological surveys at the Paducah Plant
identified that neptunium-237 was present in the enrichment cascade. Although the AEC
recognized the potential for transuranic contamination of the cascades, it was not until a 1965
appraisal that OR identified a potential problem with transuranics and fission products in X-70SE
and recommended studies to determine where these materials could concentrate in the process.

Records reflect that PORTS then reviewed the potential problems posed by feeding reactor returns
to the oxide conversion plant; however, detailed studies were not performed. PORTS

correspondence also indicates that health physics staff did not fully understand the presence of
transuranics and technetium-99, and appropriate analytical procedures were not developed as late as
1976. During the 1970s, PORTS health physics and Plant managers participated in pre-planning for
receipt and subsequent processing of recycled uranium known to contain trace quantities of
neptunium-237, plutonium-239/240, and technetium-99. Planning activities included development
of recommendations for material receipt specifications and specific controls to minimize personnel
exposures, including the use of containment devices and ventilation systems. Many
recommendations were implemented but were not sufficient.”

“PORTS was also aware of the presence of technetium on process equipment as early as 1962, but
also assumed that transuranics and fission products would not be a significant hazard to workers.

No special monitoring or personnel protection controls were established.”

Health and safety activity reports from the mid-1960s identified that excessive inhalation of
uranium compounds was the major radiation and contamination risk at PORTS. PORTS documents
also reveal that internal deposition became a problem in 1965 from handling insoluble enriched

uranium, and that urine sample results were neither reliable nor as sensitive as analysis for soluble

forms.

During the 1960s, the Ports health physics group became concerned with increasing alpha radiation
levels in process and support facilities at the site. While no records were identified to demonstrate
that this issue was satisfactorily resolved, the period coincides with the processing of recycled
uranium at the Paducah Plant. In 1979, isotopic analysis of two cascade deposits revealed relative
high concentration of neptunium-237 (i.e., 55 percent and 60 percent of the total alpha activity in
the samples was due to Np-237, respectively). However, there was no indication of a change in the
radiological control program to address this issue, even though data was available to indicate that

some level of transuranic contamination was present in the cascade. Transuranic sampling for work
planning and control was not actively conducted until the 1990s.

The low specific activity and the self-shielding properties of uranium handled at the site limited
dose rates at PORTS. However, certain operations were known to result in higher exposure
potential. Routine whole body beta exposures in excess of PORTS investigation levels existed


SEP-19-@@ 10:25 FROM:PACE LEGISLATIVE OFFICE ID: 202 292 7as6Gq PAGE 16.

cancer and hematopoietic cancers (including leukemia). In 1992, the study was updated, in part
due to a request from Senator John Glenn. In 1996, the study summary was presented to the
workforce. It indicated that there were no statistically significant elevations of any cancer deaths
and the elevations of stomach and hematopoietic cancers identified in the 1987 study had
diminished. These results were presented to the media in September 1999"? However, the
NIOSH officials releasing this information apparently chose to delete the page explaining the
study’s limitations”. We obtained the deleted text from another source. One of the key
uncertainties is the fact that the population is still relatively young and that the poor quality of

” Portsmouth Gaseous Diffusion Plant: Study Summary, Rinsky, Ahrenholz, and
Cardarelli, September 1999
5 Restated below are portions that were mysteriously deleted by NIOSH before releasing

the summary:
of naturally occurring events rather than beg conducted in an experimentally controlled

1) This is still a very young population and the vast majority of them are still alive. As
the workforce grows older, deaths will occur at an increasing rate and of course there is n0 way to
know what these people will eventually die from;

2) this is a study of mortality, not disease incidence. Only diseases that have high case
fatality rate are measured well by mortality. Although most cancers have 2 high case fatality rate,
there has been great progress over the past two decades in prolonging the life of persons with
hematapoetic cancers. Mortality may not be a good measure of these deaths;

3) SMR analyses are not particularly good attributing the proper effects of confounding
and effect modification. The case control stadies that are being worked on are much better in this
regard;

4) the exposure response portion of these analyses are only as good as the exposure
metrics. Because of the way the plant collected exposure data our algoxitbms for assigning

exposure, while the best that can be done, still have a degree of uncertainty. To the extent that
real exposures are over or under estimnated, our answers will be in error; and fimally,

5) these workers were simultaneously exposed to a number of chemical dn physical
agents and it is very difficult to disentangle the effects of the concurrent exposures.

Moreover these workers are protected by some other factors associated with their
employment at this facility, such as lower alcohol and smoking rates as a consequence of their
security clearance requires. This further complicates the interpretation of any harmful effects there
might have been suffered.”

Page 12 of 14


1. PORTSMOUTH FAILED TO PROVIDE WORKERS WITH ADEQUATE
PROTECTION FROM RADIATION, HEAVY METALS & TOXIC CHEMICALS
In prosecuting the Nation’s cold war mission, workers at Portsmouth were kept in the
dark about the hazards they faced. Information was provided based on a “need to know” basis--
and production imperatives determined what you needed to know. Even to this day, we don’t
know what we confronted. For example, when we started feeding irradiated recycled uranium
back into the process system, we never knew we were introducing contaminants (e.g.,
technetium, plutonium, neptunium, etc.), nor were we adequately protected. Today we are still

learning about the extent to which transuranic elements, such as plutonium, were part of the

working environment.

A. THE PORTSMOUTH OXIDE CONVERSION PLANT (705-E) CAUSED NUMEROUS

INTERNAL RADIATION DOSES
Portsmouth operated a facility that converted highly enriched uranium (HEU) oxides into

feed material from 1961-1978. Much of this HEU oxide (87% enriched) was shipped in from the
Idaho Chemical Processing Plant, and processed in the 705-E building. ‘

A good friend of mine, Robert Elkins, worked in the oxide plant from 1962-65. By 1965
he was placed on permanent work restriction due to high internal body counts of radiation. He
had enriched uranium, technetium-99, neptunium-237, potassium and cesium in his body. When
he retired in 1985 he was still on permanent restriction, a situation that confronted many other
oxide plant workers. In the 15 years since retirement, the plant management has never contacted
him to check on his health or suggest that he receive post-retirement monitoring.

However, Mr. Elkins was contacted by an individual from Hanford, WA (presumably the

transuranium registry) who wanted to pay him $500 for his body so the government could study

what happened to the radiation in his body after he passed away. He wife was also offered $500.

Page 2 of 12


TESTIMONY OF SAM RAY
BEFORE THE
COMMITTEE ON GOVERNMENT AFFAIRS

U.S. SENATE

MARCH 22, 2000
REGARDING HISTORICAL WORKING CONDITIONS

AT THE PORTSMOUTH, OHIO GASEOUS DIFFUSION PLANT AND REMEDIES
NEEDED TO ADDRESS THE HEALTH OF DOE NUCLEAR WORKERS

Tam Sam Ray, a former uranium enrichment worker at the Portsmouth Gaseous Diffusion

Plant in Portsmouth, Ohio. I reside at 128 Overlook Drive, Lucasville, OH.

I was hired in 1954 and worked as a production operator and instrument mechanic. In
May of 1994, I was diagnosed with a rare type of bone cancer: chondrosarcoma. As a result, I
had to have my larynx removed. At that point, I had no option but to take a disability retirement.
My understanding is that there are two things that can cause my type of cancer. One is Paget’s
Disease, which I didn’t have, and the other is radiation exposure, which I did have. I have never
smoked a day in my life. It is well documented that certain uranium compounds are bone
seekers.

Your Committee’s hearing is especially timely. The Administration has proposed
legislation to compensate workers nationwide from beryllium, and a remedy for radiation-related
cancers at the Paducah Gaseous Diffusion Plant in Paducah, Kentucky. However, uranium
enrichment workers exposed to radiation at Portsmouth and Oak Ridge were left out of the
Administration’s bill. We hope you will make sure Portsmouth and Oak Ridge workers are not

left out of the final legislation. I believe my testimony illustrates how we toiled under conditions

no less hazardous than Paducah.

Page | of 12


PRY IS-OY 16521 RUM: PALE LEGISLATIVE OFFICE ID:202 293 7688 PAGE S-

INTRODUCTION
Iam Sam Ray, a uranium enrichment worker formerly employed at the Portsmouth

Gaseous Diffusion Plant in Piketon, Ohio. I reside at 128 Overlook Drive, Lucasville, OH.

I was hired at Portsmouth in 1954 when the Atomic Energy Commission’s uranium
enrichment plant fixst commenced operations. I worked as a production operator and instrument
mechanic until May 1994 when I contracted a rare type of bone cancer— chondrosarcoma. Asa

result, I had to have my larynx removed. My understanding is that there are two things that can
cause my type of cancer. One is Paget’s Disease, which I didn’t bave, and the other is radiation,
which I did bave. I have never smoked a day in my life. It is well documented that certain
uranium and transuranic compounds are bone seekers, and I encountered these in my job. I
realize, however, that I am more fortunate than many of my former co-workers and friends, who
bave passed away from different types of cancers, respiratory problems, and other work related
illnesses. After my surgery, I was forced to stop work and take a disability retirement.
SUMMARY

DOE investigation reports show that workers have not been adequately protected from
radiation exposure in many parts of the Portsmouth plant. This led to the ingestion of enriched
uranium, fission products such as technetium-99, and trausuranics such plutonium and
neptunium. Exposure to heavy metals such as mercury, ingestion of highly corrosive chemicals
such as uranium. hexafluoride, and inhalation of asbestos and solvents have taken ther toll, as
well. Even though certain areas had very high levels, workers were not routinely tested for
exposure to transuranic elements such as neptunium and plutonium until the 1990s. Radiation
exposures were systematically undercounted, due to improper bioassay procedures, in vivo body
counting techniques that could not detect transuranics, and failure to conduct extremity
monitoring for 30 years. Even in the 1990s, there is confirmed evidence of a worker having his
radiation dose records “zeroed out” due to liability concerns, doses being arbitrarily assigned, and
neutron doses never being monitored. DOE continues to be exempted from external regulation
by agencies such as the Occupational Safety & Health Administration and the Nuclear
Regulatory Commission. DOE has functioned as a self-regulating enterprise, and this lack of

Page 1 of 14


The Portsmouth plant’s radiation dosimetry programs have been woefully inadequate. For
example, NIOSH discovered that between 1954 and 1992 the site never measured for neutron
exposures. Worker dose records, consequently, do not exist for neutrons. “Slow cooker” effects
from the concentration of uranium deposits in the cascade causes neutron emissions. Workers
called in to clean out “freeze ups” of uranium inside of the cascade would be particularly at risk
from neutrons, but there are no recorded doses to document these exposures.

Cc. WorKERS INGESTED TECHNETIUM-99-A BETA EMITTER

Technetium-99, a fission product, was introduced into the cascades from recycled
uranium reactor tails, most which had been first processed at Paducah. Worker urine dose
records from CY 1976, 1977 and 1978 indicate that 27% of the chemical operators at Portsmouth
tested positive for technetium-99 (66% tested positive for uranium)’. Jn vivo lung monitoring
established that 2 of the 45 maintenance mechanics had positive confirmed doses of technetium-
99 to the lungs. Curiously, 563 mechanics were tested for uranium over a three year period, but
only 45 were tested for technetium-99 or neptunium-237. Depending on whether the Tc-99 was
in a vapor or solid form, special personal protective equipment (such as supplied air respirators)
was required, but not provided until the early 1980s. One pregnant worker had a calculated dose
800 millirem to the fetal thyroid‘ of her 10-11 week old fetus, providing further evidence of

inadequate worker protection. Amazingly, between 1954 and 1993, the site had no technical

> Response to Freedom of Information Act Request by OCAW to the DOE, July 1, 1982.

*A July 22, 1976 letter from Karl Hubner, Oak Ridge Associated Universities to E.V.
Hansen, Goodyear Atomic, states: “The dose of .8 to 1.0 rad to the thyroid gland of a fetus is
considered to be insignificant, and there is no reasonable chance of damage to this organ in terms
of cretinism.” The letter qualified this conclusion by stating: “calculations were based on some
gross assumptions that had to be made because of insufficient data.”

Page 4 of 12


BEF -ae UY 1s PRUMI FALE LELISLALIVE UFE Ile

to s2e2 2y4 yeu PAGE

the goverument corporation that took over enrichment operations in 1993. Doses were
administratively “assigned” when the health physics staff had trouble reading individual dose
badges. One practice involved pinning a dose badge to the wall and running a scanner over it
and assigning this dose to any person whose individual dose badge didn’t read out on a scanner.
A settlement of this OSHA complaint resulted in a reconstruction of doses between 1993-1995.
While management was generally conservative in assigning doses, at least 103 doses. were
undercounted. We have no idea how far back management was simply administratively
“assigning” doses, instead of counting them.

Goodyear Atomic failed to perform any extremity monitoring for radiation exposure until
the 1980s, even though operators handled valves with beta emissions as high as 1 rad/hour and
feed production plant ash recciver areas had floor readings of 5/rad per hour beta*. DOE’s
investigators found that we were not tested in a timely fashion for uptakes of uranium during the
1950's and 1960's and concluded that “some uranium uptakes were likely not identified or
properly investigated.” Air sampling methods for radioactivity were also found deficient by

Between 1981 ond 1990, docontamination workers in the 705 building were exposed to
mercury at up to 175 times the OSHA threshold limit values, largely from open vats of solvents.
A 1990 DOE investigation found “workers were exposed at least once per shift, after sodium
hydroxide was added tanks” and that Martin Marietta’s plant doctor trivialized the hazards of

ingesting mercury.”

8 Independent Investigation of the Portsmouth Gaseous Diffusion Plant, Volume 1: Past
Environment, Safety and Health Practices, Department of Energy, Office of Environment Safety

and Health, May 2000, pp. 36.
° Letter from Gene Gillespie, Site Manager, DOE to Ralph Donnelly, Plant Manager,
Martin Marietta, July 20, 1990, Letter EO-221-696.
Page 7 of 14

11s


Ky

Dan Minter, President
Bill Dimit, V. Pres.

P. O. Box 467
Piketon, OH 45661

Delivery Add: 2288
Wakefield Mound Rd

PH: (740) 289-2405
FAX: (740) 289-2126

E-Mail:
‘paceport@zoomnet.net

PACE ccs

PAPER, ALLIED-INDUSTRIAL, CHEMICAL AND ENERGY INTERNATIONAL UNION, aFL-cio

April 27, 2004

U. S. Department of Health and Human Services
National Institute for Occupational
Safety and Health (NIOSH)
Robert A. Taft Laboratories MS-C34
4676 Columbia Parkway
Cincinnati, OH 45226

TO WHOM IT MAY CONCERN:

Thank you for taking the time to make a presentation to the Portsmouth Unions regarding our Site
Profile being developed and requesting our suggestions and information. Our crew is very anxious
and are standing ready to assist NIOSH in developing this Site Profile before our claims are
adjudicated. We submitted the information we have presently accumulated, but will continue to
assist in developing this Site Profile.

It was alarming to us to learn that your Profile is based only on information after 1985, due to the
lack of information provided to you. Another potential detriment is having to rely on newly hired
Health Physics personnel who may not have the history/knowledge of the Plant for the information
prior to 1993.

As discussed in the meeting, another area of concern is that the individual’s history is not being
captured to the fullest extent. This is because the claimants are unaware of what may be extremely
important to you in order to assist them and the interviewer who is not knowledgeable of the
practices, systems, etc., at the Plant.

The percentage of the time the doses were assigned, as to specific information on the types of work
performed as well as in depth information of the buildings (i.e. the X-770) would all be very
important. We do not feel anyone could capture the chronic exposure. The urinalysis information
has the potential to be more in error than the badge information; since the urinalysis Program has
been significantly modified a number of times over the years.

There are an estimated 100 personal interviews that Dr. Michaels conducted on our Site assessment
that NIOSH would have access to that would prove to be very helpful, as well as available
congressional testimony available on the website.

Access to IMBA to determine the dose estimates and basis for the dose calculations would be
helpful, as well as training to key individuals would server to be very beneficial.

wee


“Due to weaknesses in monitoring programs, such as the lack of extremity monitoring, exposure
limits may have unknowingly been exceeded. In addition, communication of hazards, the rationale

for and use of protective equipment use were inadequate.”

“Environmental practices prior to Federal and State legislation in the 1970s and 1980s resulted in
many adverse impacts to the environment, although essentially all on Federal property.

AEC/ERDA/DOE and contractor management failed to proactively identify ES&H vulnerabilities,
clearly communicate high expectations for ES&H performance, and implement consistent, effective
corrective actions to known problems. Management also failed to ensure that hazard controls were
implemented by supervisors and workers, resulting in additional and higher exposures to personnel

and continuing unnecessary radioactive contamination.”
“Tn 1998, OSHA cited USEC for failing to preserve and maintain records of employee exposure of

all employees for at least 30 years. OSHA found that “records of radiation exposures for all
company employees were not adequately maintained from 1993 to 1995 in that some employees’

exposures were arbitrarily assigned and based solely upon their past exposures which may have
differed from exposures experienced during the period relating to the assigned dose.”

-from pages 5, 6, 37

April 21, 1994 X-100, MS-1213, PORTS (3841)
Subject: POTENTIAL CIVIL PENALTIES FOR RADIATION PROTECTION PROBLEMS

“Review of Documentation of the NRC Action at the LaSalle County Station and Comparison of
the Reports Against Recent Events at PORTS. Conclusion: PORTS Has the Same Potential As

LaSalle.”

“This statement is made based on the review of the X-705 ALARA Review conducted in March

1994. The lack of engineering controls, pre-job meeting and failure to recognize the potential
spread of contamination are parallel.”

“August 18, 2003 Reference No. PR-PTS-03-02876 X-343

“Two protective Force received an uptake of fumes (HF) in a letter dated 10-=28-2003 from Greg
Goslow states that uranium emissions from the X-343 Cold Trap Vent exceeded both the first and
second plant action levels (PAL) during the month of July and August 2003. Mr. Goslow added
that uranium emissions reached over 30 times the baseline effluent quantity, which is 30 times
greater than the expected amount of emissions.”


On one occasion while connecting the production process into an empty cylinder, the copper
tubing pigtail ruptured. Although I immediately valved off the system, the room was filled with a
thick fog of uranium oxide gases. I donned an army assault mask for protection. After the all
clear signal, management sent me to the hospital for urinalysis. Today, we know that you should
wait for 3-4 hours to give the material time to get into your system before urinalysis. For that
reason, my dose records from this accident is going to be suspect, at best.

Indeed, until the mid 1970's, our respirator protection consisted of World War II army
assault masks. It was years later that we learned that these were not adequate to block

radionuclides or toxic chemicals.

In the late 50’s and early 60’s we had big layoffs. Prior to this layoff, the lab took
samples to make sure process gases were reduced to a safe level before opening up the process
equipment for maintenance work. In the process buildings, operators had to take over the work

of lab technicians. Previously, the lab techs used bulb samples that would be taken to the lab and
analyzed. The new system consisted of pulling a sample through a tube of salicylic acid (white
powder). If the powder didn’t change color in three (3) minutes, then it was assumed the system
was <10 ppm UF6 (commonly called a “negative”).

We now know this was never an approved method, and there wasn’t adequate research. In
turn, we put maintenance crafts and others in harm's way when we issued a hazardous work

permit stating that system was at a “negative”.

L WORKERS WERE KEPT IN THE DARK ON CONTAMINATION CONTROLS
Early on, we were told that the buildings would be so clean, we could eat off the floors.

In reality, some eating areas became so contaminated that management had to build designated

Page 7 of 12


scanner. A settlement of this OSHA complaint resulted in a reconstruction of doses between
1993-1995. While management was generally conservative in assigning doses, at least 103 doses

were undercounted. We have no idea how far back management was simply administratively

“assigning” doses, instead of counting them.

Historically, the Health Physics program did little to investigate high radiation doses,
based on the philosophy that high doses were unlikely. Whenever high dose readings were found
on badges, they were determined to be equipment failures and summarily discarded. DOE has

historically claimed no responsibility for the deficient health physics program and poor record

keeping.

G. CHEMICAL OPERATORS WERE OVEREXPOSED TO MERCURY AND ARSENIC

Between 1981 and 1990, decontamination workers in the X-705 (decontamination
process) building were exposed to mercury at up to 175 times the OSHA threshold limit values,
largely from open vats of solvents. A 1990 DOE investigation found “workers were exposed at
least once per shift, after sodium hydroxide was added tanks” and that Martin Marietta’s plant
doctor trivialized the hazards of ingesting mercury in discussions with affected employees.’

Arsenic contaminated feed was fed into the Portsmouth cascades in the late 1980's.
Arsenic migrated towards copper instrument lines causing them to plug up. In 1993 after the
presence of inorganic arsenic was confirmed, NIOSH conducted a health hazard evaluation. Air

samples detected arsenic in excess of OSHA limits.

H. RESPIRATORY PROTECTION DEPENDED ON WWII-ERA GAS MASKS FOR MANY

YEARS AND CONTAMINATION WAS WIDESPREAD
I worked at the Extended Range Product (ERP) station on and off for a number of years.

5 Letter from Gene Gillespie, Site Manager, DOE to Ralph Donnelly, Plant Manager,
Martin Marietta, July 20, 1990, Letter EO-221-696.

Page 6 of 12


May 2000 - OFFICE OF OVERSIGHT ENVIRONMENT, SAFETY, AND HEALTH
INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS
DIFFUSION PLANT —- VOLUME I

Decontamination and Uranium Recove: -705

Since the Plant began operation, equipment was decontaminated and uranium was recovered from
decontamination solutions in the X-705 (Decontamination Building). These activities were
accomplished in areas that were physically separated from the oxide conversion areas.

The most significant occupational hazard in the X-705 was exposure from inhalation of airborne
radioactive material. Radioactive materials in this building were often not contained, providing
the opportunity for worker exposure. Spot checks by health physics personnel often found
evidence of contaminated hands, shoes, and coveralls. Acceptable PALs for airborne radioactive
material were exceeded more frequently in the X-705 than in other buildings. Radiological
hazards were particularly significant in the X-705, because transuranic materials were
concentrated by the uranium recovery and oxide conversion processes, and because insoluble
forms of uranium were routinely handled. Transuranics and insoluble uranium were significantly
more hazardous than the soluble uranium compounds that were the principle sources of radiation
dose in other Plant areas. Prior to the mid-1970s, the health physics staff assumed that all
detected radioactivity was uranium. This non-conservative assumption likely caused
underestimation of the radiological hazards in the X-705.

Decontamination

A significant exception occurred in the late 1970s when a radioactive contaminated acid cleaning
solution entered the plant process steam system through a leak in a heat exchanger that was being
used to heat the solution. Radioactive contamination was transported to the steam plant and to
steam piping across PORTS before the problem was identified and corrected. Today, many parts
of the steam plant remain contaminated from this event.

Oxide Conversion (X-705E)

Over its entire period of operation (1957 to 1978), the oxide conversion process was probably one
of the most hazardous radiological and chemical operations at PORTS.

A demonstration facility with a 3-inch flame tower was built and operated from 1958 through
1965, but was shut down due to health physics concerns and uranium material balance problems.
Problems identified by an Oak Ridge health protection review in 1965 included potential
concentration of transuranics in the processes, internal uranium exposures from enriched
insoluble oxides that were not detectable by urinalysis, and inadequate air monitoring capability.
Although the need to study the transuranic contamination potential and the addition of a separate
tower for re-feed of tower ash were identified by the Oak Ridge review, neither activity was


dropped. The report also stated that under less favorable conditions, this type of accident would
have resulted in injuries and/or fatalities.”

“Operations at the three enrichment plants since the 1940’s have resulted in 240 releases of
radioactive materials containing 1 kilogram (about 2.2 pounds) or more of uranium. Forty-one of
these releases occurred at the Oak Ridge plant; 88 at the Paducah plant; and the remaining 111 at

the Portsmouth plant.”

“In addition, a small number of releases occurred involving uranium oxide and uranyl nitrate. Even
so, these figures do not represent every release of radioactive material. Releases of less than 1
kilogram are not included, and a list of such releases is not available for Paducah and Oak Ridge.
The Portsmouth plant has experienced about 170 additional releases of between 1 gram and 1

kilogram of uranium.”

“Causes of such releases vary widely. More than half of the releases at Portsmouth resulted from
various mechanical failures, including valve failure and failed lines and gaskets. About 15 percent
of the Portsmouth releases resulted from corrosion (primarily liquid storage cylinders), and 7
percent involved human error. At least six releases resulted from dropped storage cylinders.”

“Under DOE policy, operations shall be conducted in a manner to assure that radiation exposures
are limited to the lowest levels technically and economically practicable.”

-from pages ii, 10

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, VOLUME I - May 2000

“The largest release was in 1978, when over 13,000 pounds of UF6 was released to the environment
when a 14-ton cylinder dropped from a transporter and ruptured, emptying its contents.”

“Documents reviewed for the first quarter of 1978 indicated that “Based on the weight analysis via
fluorimetric detection and the monitoring frequency it is possible to exceed, undetected, the
maximum permissible weekly uptake.” The documents also indicated that samples were collected
and analyzed for technetium. Correspondence dated as late as 1988 related to oxide repackaging
stated that “Oxides of uranium are known to have different chemistry from the uranium fluoride

compounds generally encountered at the site. The current urine monitoring program is not adequate

to detect significant exposures to uranium oxides in a timely fashion.” This correspondence also
noted that “available analysis of the oxide does not include sufficient information to determine
whether exposure controls are appropriate since they are based on (transuranics) being insignificant

for the purposes of dose assessment and control.”
“On September 13, 1978, Health Physics recommended shutting down X-705E due to unacceptable
health risks (workers were subjected to these health risks from 1957 to 1978 — 21 year period).”

“On October 1, 1978 The Oxide Conversion was placed in a standby status.”


Skr-19-@@ 10:25 FROM:PACE LEGISLATIVE OFFICE 1D: 202 293 vaee PAGE

is beryllium, radiation, toxic chemicals or heavy metals. Shifting claims for toxic
exposures to the states is ill-advised. HR 5189 and the Title 35 provide for a report to
Congress by the GAO to evaluate whether state programs can be made to work in
cooperation with an Office of Worker Advocacy with DOE. Again, we would prefer a
comprehensive bill to be passed this year, but the approach provided in the Senate lays a
foundation upon which Congress can build in the future.

TM The current medical screening program carried out by DOE under
93 Defense Authorization Act should go even further, with lifetime annual medical

Screening, and fully paid medical insurance for displaced or retired workers. A Medigap
supplement should be fully funded by the government for nuclear workers.

Workers at Portsmouth and Paducah face a unique problem with retiree health care
benefits. Since USEC was privatized, it has assumed responsibility for the Lockheed
Martin retiree health care benefits program. However, these benefits could be in jeopardy
if USEC, as many predict, will fall into bankruptcy in several years or is liquidated even
sooner. Unlike pensions, retiree health care benefits are not guaranteed under ERISA.
We need legislation to guarantee that the funds which the DOE has already transferred to
USEC to cover the retire health care liability are placed in a safe harbor and these benefits
will be delivered as intended.
SUMMARY

On January 29* of this year, the New York Times reported: “After decades of denial, the
government is conceding that workers who helped make nuclear weapons ... were exposed to
radiation and chemicals that produced cancer and early death.” In the article, Energy Secretary
Bill Richardson said, "Jn the past, the role of’ government was to take a hike,....and I think that
was wrong.” Nuclear workers have paid a price and deserve a fair remedy. The Senate has

passed a provision that would spend a portion of the budget surplus to help those made ill in the
service to our national security. We urge your Committee to help make that provision become

under Section 3162 of the FY _

law this year.

Page 14 of 14

18


X-326 BUILDING RADIOLOGICAL PROFILE

Radiological contamination has been a major problem in the X-326 over the years. Numerous
releases have caused this contamination problem.

The major contamination came from two sources: ERP STATION
HEU SUSPENSION PROJECT

I. ERP STATION

ERP Station compressor failures on the cell floor. The ERP Station operates at above
atmospheric pressure and when these leaks occur(red), the ventilation system picked up
airborne contamination and circulated these particles from the cell floor to the operating floor.
The magnitude and duration of these releases determined how much of the building became

contaminated. Some releases contaminated the entire building.

PORTSMOUTH GASEOUS DIFFUSION PLANT, VOLUME 1; PAST ENVIRONMENT,
SAFETY, AND HEALTH PRACTICES, May 2000 — p. 35

During the 1960s, the PORTS Health Physics group became concerned with increasing alpha
radiation levels in process and support facilities at the site. While no records were identified to
demonstrate that this issue was satisfactorily resolved, the period coincides with the processing of
recycled uranium at the Paducah Plant. In 1979, isotopic analysis of two cascade deposits revealed
relative high concentration of neptunium-237 (i.e., 55 percent and 60 percent of the total alpha
activity in the samples was due to Np-237, respectively). However, there was no indication of a
change in the radiological control program to address this issue, even though data was available to
indicate that some level of transuranic contamination was present in the cascade. Transuranic
sampling for work planning and control was not actively conducted until the 1990’s.

August 27, 1962, GAT-810-62-54 - Interdepartmental Correspondence

Subject: HEALTH PHYSICS PHILOSOPHY AS A GUIDE FOR HOUSEKEEPING
PROBLEMS IN PROCESS AREAS

“Ben Kalmom has refined the Health Physics philosophy on contamination problems involving
housekeeping in the process areas and has prepared a procedure for determining the
contamination index for the X-326 cell housings. His group is still working on procedures for
the determination of contamination indices for the floor, top of compressor housings, and
intercell housings. These procedures will be forthcoming. In the meantime, it would appear
that the general philosophy presented can be adapted to the conditions in the area using our
good judgment to see that it’s provisions are maintained.

The general philosophy should be passed down to the foremen for their use as a guide in
handling housekeeping problems involving contamination considerations. We don’t expect or
desire that the philosophy will be openly discussed with bargaining unit employees.
Calculations of contamination indices should be handled by the General Foremen and kept as
supervisional information to help in deciding the need for decontamination.


eee Feuloemaive Urrius tuszwe wu you PAGE

exposure data makes it difficult to establish cause and effect relationships. What motivated this
apparent censorship is beyond our knowledge. What is clear is that the study is far from

conclusive.

4,

RECOMMENDED ACTIONS FOR CONGRESS
Representative Ed Whitfield and 23 members co-sponsored HR 4398, a comprehensive

bill that provides a federal worker compensation remedy for those exposed to radiatio:
beryllium, silica, toxic chemicals and heavy metals at DOE nuclear facilities and .
suppliers. It stands out amongst other bills seeking compensation for radiation exposed
workers because, unlike the Administration’s bill GAR 3418), it expands coverage beyond
the Paducah workforce and 55 workers in Oak Ridge to cover the entire DOE nuclear
complex. Compensation is modeled after the Federal Employee Compensation Act

(FECA).

HR 5189, which was introduced by Representative Mark Udall, covers radiation,
beryllium and silicosis through a program administered by the Department of Labor. It is
funded as “direct spending” and replicates Title 35 to the FY 2001 Defense Authorization
Act (S.2549) that was adopted by the Senate is before the House-Senate Conference
Committee. While Title 35 is not as comprehensive as HR 4398, Title 35 is a very, very
important building block that addresses some of the most glaring problems confronted by
nuclear workers seeking worker compensation. me tS i isi

should be i in the to Waiting
another year to take action—as some have suggested is not fair to those who are
suffering today and who have waited far too long already.

Any successful bill must shift the burden of proof to the government in determining
causation where the exposure data is missing or of poor quality, because the failure to
properly monitor for radiation and toxic hazards unfairly imposes an insurmountable
burden of proof on a victim. HR 5189 and Title 35 create a special category of workers at
Portsmouth, Paducah and Oak Ridge K-25 sites where the dose data cannot be
reconstructed to establish proof. Some types of dose estimation to compensate for
missing data can be useful, but the threshold for establishing “proof” must take account
of the wide errors inherent in even the best dose estimates. Good science relies upon good
data, As NIOSH noted in a 1993 report, that “prior to 1981, the amount of quantitative

industrial hygiene data is scant to non existent.”

A single agency, such as the Labor Department’s Office of Worker Conapensation
Programs, should administer a federal workers comp program. An ideal program
provides one-stop shopping for addressing occupational illnesses regardless of whether it

" Protocol for the Study of. ‘Mortality Patterns Among Uranium Conversion and

Enrichment Workers, NIOSH, J. Stebbins, etal, July 1, 1993, pp.15

Page 13 of 14

17,


CONCLUSION

AEC/ERDA/DOE’s priority has always been production. Production was primary and nuclear
safety secondary. As a result of this approach, we now have DOE facilities all over the country
that are contaminated, (Linking Legacies — January 1997 Connecting the Cold War Nuclear
Weapons Production Processes to Their Environmental Consequences)

Nuclear workers (cold war veterans) were put in harms way as a result of this approach. In
October of 2000, the EEOICPA was passed by Congress and signed by the President to
compensate nuclear workers made ill by exposure to radiation. For those workers not covered
under Special Exposure Cohort, NIOSH will do dose reconstruction to determine if illness or
death was 50% or more likely caused by radiation exposure.

The problems arise with the method(s) NIOSH will use to perform their dose reconstruction.
(Examples: urine monitoring data, dosimetry data, etc.) This data is suspect at best in NIOSH’s
own words. “Final Report July 2001”, page 73, “In an earlier study, NIOSH evaluated the urine
monitoring data, but reasoned that the mass uranium data had not been collected in a way that
allowed back calculation to actual exposure.”

The dosimetry program has had problems over the years. Badges not calibrated for neutron
exposure and zeroing of badges. NIOSH “Final Report July 2001, page 85”

4) Historically, control dosimeters were positioned in areas of elevated background radiation
which resulted in artificially low recordable doses.

2) Monitoring results below the limit of detection should also report that limit of detection.
Recording results as zero and “less-than” an exposure or dose limit should be avoided. (page

86)

Even if this process is practical, we still will not have the true picture. Without chronic exposure
factored into the equation, the worker will be short-changed.

An analogy would be the reconstruction of an old vehicle. When restoration is completed, the
outside and inside may look good, but when the key is turned, nothing happens. The hood is

lifted and the engine is missing. Chronic exposure is the missing engine with dose reconstruction.

Chronic exposure cannot be reconstructed. The building(s) the employee worked in and radiation
exposure in these buildings would have to be factored as a percentage in the total reconstruction

process.

The present dose reconstruction process is designed for failure. The ultimate results will be a
legal quagmire, individual lawsuits, class action lawsuits, etc.

In the final analysis, NIOSH’s dose reconstruction failure may make DOE’s failure with Subtitle
D (physician’s panel) look tame in comparison.

|


They both declined the offer. It appears that the government is more interested in what happens
to Mr. Elkins after he is dead than what happens to him while he is still alive. If the Congress is
funding this kind of effort, perhaps it could reorient the Department of Energy’s priorities toward
caring for the living.

Mr. Elkins’ over exposures to radiation were not the exception, it appears. A 1985 DOE

report states':

“the oxide conversion facility was not able to maintain adequate containment of the
radioactive materials during operating periods.”

“As such, the decision was made in the 1977 time frame to shut down that facility
pending modifications to provide adequate containment measures. These modifications
were never funded, and the facility has not operated since.”

In vivo body counts (a relatively insensitive method of measuring the amounts of
radiation in the lung) taken after 1965 found eight employees with radiation counts above DOE’s
15 rem lung standard and two employees had more than 7.5 rem (half of DOE’s standard). Since
1972, another 7 were found with more than 7.5 rem.” Of the 17 employees listed above, 11 had
worked in the oxide conversion facility. This number of overexposed workers actually measured
and reported by Goodyear Atomic underscores the point that workers in the oxide conversion
facility were subjected to uptakes of excessive levels of radiation.

B. NEUTRON DOSES WERE NOT MEASURED BETWEEN 1954 AND 1992

'The Report of the Joint Task Force on Uranium Recycle Materials Processing,
Department of Energy, 1985, DOE/OR-859

? Information on Three Ohio Defense Facilities, Fact Sheet for the Ranking Minority
Members, Subcommittee on Energy, Nuclear Proliferation and Government Processes,
Committee on Governmental Affairs, U.S. Senate, November 1985, GAO/RCED-86-51 FS.

Page 3 of 12


SEP-19-@@ 18:22 FROM:PACE LEGISLATIVE OFFICE 1D: 2@2 2935 7a6a PAGE

away. He wife was also offered $500. They both declined the offer. It appears that the
government is more interested in what happens to Mr. Elkins after he is dead than what happens

to him while he is still alive.

Mr. Elkins’ over exposures to radiation were not the exception, they were the rule. A
1985 DOE report states*: :

The oxide conversion facility was not able to maintain adequate
containment of the radioactive materials during operating periods.

As such, the decision was made in the 1977 time frame to shut
down that facility pending modifications to provide adequate
containment measures. These modifications were never fimded,
and the facility has not operated since.

In vivo body counts (an insensitive method of measuring the amounts of radiation in the
lung) taken after 1965 found eight employees with radiation counts above DOE’s 15 rem lung
standard and two other employees had more than 7.5 rem (50% of the maximum permissible
body burden). Since 1972, another 7 were found with more than 7.5 rem.? Of the 17 employees
listed above, 11 had worked in the oxide conversion facility, underscoring the point that workers
in the oxide conversion facility were subjected to intolerable, if not barbaric, working conditions.

B. on Doses Were Ni DB 1954 AND

The Portsmouth plant’s radiation dosimetry programs were woefully inadequate. NIOSH
discovered that between 1954 and 1992 the site never measured for neutron exposures. Worker
dose records, consequently, do not exist for neutrons. “Slow cooker” effects from the
concentration of uranium deposits in the cascade, as well as in uranium storage and feed

?The Report of the Joint Task Force on Uranium Recycle Materials Processing,

Department of Energy, 1985, DOE/OR-859

3 Information on Three Ohio Defense Facilities, Fact Sheet for the Ranking Minority
Members, Subcommittee on Energy, Nuclear Proliferation and Government Processes,
Committee on Governmental Affairs, U.S. Senate, November 1985, GAO/RCED-86-51 FS.

Page 4 of 14


dose of this size may be possible if the exposure occurred near a highly enriched uranium deposit.
The “SLOW COOKER” phenomenon could explain doses in this range.

In addition, this review found that background measurements used to correct personal results have
changed throughout time. Depending on the type of dosimetry system used, background was
handled in one of three ways: it was calculated using statistics, manually entered into the dosimetry
algorithm, or determined from badges in or near the working areas. All these methods have certain
limitations. The latter may NOT represent true background exposures (especially if these locations
were in elevated radiation areas). Another issue regarding reporting and recording practices
involves doses that could not be linked to individuals. A computerized account, setup to store these
“unlinkable” doses, is commonly called the “BUCKET DOSE” account. A cursory review of this
account indicated that several person-rem could not be assigned to individual workers or visitors.
Both approaches (background issues and BUCKET DOSE) reduce the reportable doses and will
eventually lead to an artificially low dose history for the facility.”

p.14 CONCLUSIONS - “This evaluation showed that a potential chronic low-level neutron
exposure exists at this site where uranium is stored, handled, or solidified within the cascade. areas
most likely associated with neutron exposures include the Feed and Withdrawal areas, cylinder
storage yards, and places where uranium deposits are formed within the cascade. Job titles most
likely associated with potential neutron exposures would be those involving routine tasks in
potenti8al neutron areas (listed in Table IV). Area neutron doses ranged from less than the
detection limit (0.2 mSv) to 7.1 mSv and varied with the amount of uranium present, its enrichment
level, geometric configuration, and time spent near the source. While the area measurements
confirmed the presence of a chronic low-level exposure to neutrons, all personal doses were below
the limit of detection. Recent neutron monitoring results conducted by the site have shown
reportable neutron doses. Historical health physics programs (1954-1992) neither calibrated nor
monitored for neutron expo9sures. Therefore, potential neutron doses have not been enclosed in the
workers dose histories. Data from this evaluation were based on a small sample size and may
reflect specific production and seasonal conditions during the 3-month period.”

p.14 & 15 RECOMMENDATIONS - “The following recommendations are based on observations
made during the survey and document reviews. They are intended to help ensure the safety and
health of the workforce. These recommendations stem from the present understanding of the
workers’ occupational exposures and potential health effects associated with these exposures.

1. The area TLDs used by LMES (DOE contractor) should be used with an appropriate phantom
material to monitor neutron exposures in the X-345 vault areas properly.

2. To ensure maximum efficiency in detecting neutrons, workers who are likely to be exposed to
neutrons should be informed about the proper positioning of the TLD and its angular
dependence in detecting incident neutrons.

3. The document entitled “D20-Moderated Californium-252 Neutron Calibration Factor (Knd)
Determination” dated August 17, 1995, should be revised. A minor error in the calculation
should be corrected. The Mean Net Test Response calculation used in Mean GROSS Test
Signals instead of the Mean NET Test Signals as referenced in the text.39

4. The linkage issues regarding the “BUCKET DOSE” account should be reviewed and corrected
to improve record keeping and reporting activities. Where possible, the “BUCKET” doses
should be assigned to individual workers.

5. Archive tapes should not be recycled to facilitate future dose reconstruction efforts for
compliance or epidemiological purposes.


SUMMARY

In the haste to produce atomic bombs during the war, certain risks may have been taken in
research, production, testing, transportation and waste disposal. We are now paying the price for
these risks with environmental contamination at DOE sites over the entire country. Even more
important is the effect on the workers’ health at these DOE facilities. Many have fallen ill and/or
passed away from being exposed to different types of radiation and radioactive contaminants
introduced back into the systems.

Although AEC recognized the potential for transuranic contamination of the cascades, it was not
until a 1965 appraisal that OR identified a potential problem with transuranics and fission
products in the X-705E, and recommended studies to determine where these materials could
concentrate in the process. Records reflect that PORTS then reviewed the potential problems
posed by feeding reactor returns to the oxide conversion plant; however; detailed studies were not

performed.

Dosimetry programs at PORTS from 1954 to 1992 were neither calibrated nor monitored for
neutron exposures. A National Institute of Occupational Safety and Health (NIOSH) evaluation
for PORTS studied the neutron radiation issue in 1957, and concluded that there was potential for
chronic low-level neutron exposures in areas where uranium was stored (cylinder yards), handled
(feed and withdrawal areas), or solidified within the cascade (deposits). In 1998, OSHA cited
USEC for failing to preserve and maintain records of employee exposure of all employees for at
least 30 years.

During the 1950s and 1960s, urine samples were typically analyzed for uranium, and in most
cases for alpha activity. Typically, the sample collection procedure involved the collection of
Monday morning urine specimens (the morning following two or more days off the job). This
was non-conservative, and the collection date evolved to a “Friday” sample during the 1970s and
1980s. Considering that numerous routine analysis results reflected uranium intakes in the years
of operation and the rate at which soluble uranium is excreted, some uranium intakes were likely
not identified or properly investigated. Technetium analysis was not added until the 1970s.

Over its entire period of operation (1957-1978), the oxide conversion process was probably one of
the most hazardous radiological and chemical operations at PORTS. A handwritten report
entitled, “Oxide Conversion” as viewed by Development (CIRCA 1966) in response to a
significant error in the uranium mass balance in the X-705E, explained that the oxide conversion
process was originally established as a waste recovery process and not a recovery process. The
subsequent introduction of reactor returns converted the X-705E into a production facility
requiring a capacity that “it was ill equipped to handle”. The report further explains that uranium
inventory control and health physics concerns were secondary to production schedules and costs.
On September 13, 1978, Health Physics management recommended shutting down the X-705E
due to unacceptable health risks. On December 14, 1978, Goodyear Atomic Corporation
requested cancellation of the oxide conversion project.


handle.” The report further explains that Uranium Inventory Control and Health Physics concerns
were secondary to production schedules and costs. This report provides evidence that the operating

contractor was aware of safety problems in X-705E, however, production schedules were viewed as

“Worker safety and health programs were established when the Plant started operation and have
evolved significantly. The implementation and effectiveness of these programs varied widely and,

in many ways, failed to adequately protect the safety and health of PORTS workers. It was not
until the 1990’s that a more focused and rigorous ES&H training program was established.”

“The exposure of workers to radioactive materials was monitored, and with some exceptions,
documented exposures were within the limits applicable at the time. However, monitoring

deficiencies caused exposures to airborne radioactivity to be underestimated, and actual exposures
were likely higher than indicated by PORTS monitoring records. Extremity monitoring was not

employed; exposures of hands, feed, eyes in high beta radiation fields were underestimated and
could have resulted in exposures exceeding limits.”

“Industrial safety, industrial hygiene, and health physics staff performed surveys, inspections, and
event analysis and made recommendations for hazard controls and personnel protective actions.
However, they had little oversight or enforcement authority until the 1970s. Staffing for all safety

and health organizations was very limited well into the 1970s and was insufficient to provide
adequate attention for up to 2500 employees working in numerous and varied hazardous

conditions.”

“Radioactive contamination and control limits were established to minimize personnel exposures
and prevent exceeding regulatory limits. A network of stationary air samplers and portable and
breathing zone samplers provided data on airborne contamination. This monitoring frequently
showed that limits had been exceeded. PORTS’ assumption that all uranium intakes were soluble
compounds that would be excreted quickly and could be monitored effectively by urinalysis was
not conservative for some locations and activities where insoluble aerosols were generated, such as
the oxide conversion plant and from maintenance activities involving grinding, cutting and
buffing.”

“Monitoring deficiencies cause exposures to airborne radioactivity to be underestimated, and actual
exposures were likely higher than indicated by PORTS monitoring records. Extremity monitoring
was not employed; exposures of hands, feet, and eyes in high beta radiation fields were
underestimated and could have resulted in exposures exceeding limits.”

“Due to weaknesses in monitoring programs, such as the lack of extremity monitoring, exposure
limits may have unknowingly been exceeded. In addition, communication of hazards, the rationale
for and use of protective measures, accurate information about radiation exposure, and the
enforcement of protective equipment use were inadequate. Further, workers were exposed to
various chemical hazards for which adverse health effects had not yet been identified. Management
also failed to ensure that hazard controls were implemented by supervisors and workers, resulting in
additional and higher exposures to personnel and continuing unnecessary radioactive
contamination.”


“PORTS had a fairly conservative contamination control policy; however, historical evidence
suggests that management expectations for contamination control were often not met in the field.”

“The shortage of respirators is confirmed by the union safety meeting minutes in the 1973 to 1975
period.”

“Records of radiation and contamination surveys were readily available from the start of Plant
operation. Survey records for all major buildings indicate contamination levels above limits over
many years. Recommendations for decontamination of locations exceeding PALs were typically
made and noted by Industrial Hygiene and Health Physics personnel on the survey forms. In some
cases, follow-up surveys noted that areas continued to be contaminated above limits, with continued

recommendations for decontamination. However, rigorous enforcement of decontamination
requirements was not evident.”

-from pages 3, 4, 6, 17, 19, 21, 24, 39, 40, 46

REPORT BY THE COMPTROLLER GENERAL OF THE UNITED STATES, July 11,1980

“Radioactive release (Portsmouth; May 2, 1973; type A)

“A uranium hexafluoride release occurred as an employee was attempting to take a liquid sample of
material from a storage cylinder. The leak, which lasted approximately 20 minutes, resulted in the
loss of 215 pounds of uranium. Damage was estimated at about $13,600; no injuries or exposures
resulted.”

“Compressor failure resulting in radioactive release (Portsmouth; April 10, 1975; type B)

Failure of an expansion joint resulted in the release of nearly 27 pounds of uranium over a 27
minute period. Two employees were placed on temporary restriction; however, neither was found
to have inhaled significant amounts. Damage was estimated at about $29,000.”

“Radioactive Release (Portsmouth; August 6, 1975; type B)

Electrical problems resulted in erratic heating of uranium hexafluoride and a blocked copper tube.
The tube ruptured and allowed about 2.0 pounds of uranium (enriched to 97.5 percent uranium-235)
to escape over a 5 to 25 minute period. Although 17 workers inhaled more than the permissible
amount of uranium, DOE did not consider any to have received a significant dose. Damage was

estimated at $28, 310.”

“Valve malfunction resulting in radioactive release (Portsmouth; November 10, 1975; type B)

After an August 5, 1975 release, new operating procedures were implemented but, in this case, were
not followed. A connection was made with only one gasket rather than the required two, and when
the valve was opened, about 23 pounds of uranium enriched to 97.5 percent uranium-235 escaped.
The leak lasted 46 minutes because of inoperable safety equipment. No employees received what
was considered to be significant exposures, and total cost of the accident was estimated at

$101,127.”
-from pages 7, 8


Il. HEU SUSPENSION PROJECT IN X-326

June 5, 1992 - HEALTH PHYSICS RADIOACTIVE CONTAMINATION SHEET HEALTH
PHYSICS SURFACE CONTAMINATION SURVEY

December 8, 1992 - Internal Correspondence, POEF-160-92-634
Subject: X-326 PERFORMANCE INDICATOR REVIEW

“(2) The percentage of positive bioassay samples for individuals assigned to the X-326 has
almost tripled. This increase was first noticed in June with a major occurrence of positive

bioassay sample happening in August.”

“(4) The X-326 1992 Air Card Program summary shows a significant increase during August
and September, from 0.03% of the derived air concentration (DAC) to 0.2% of the DAC. From
the RADCON Manual, an area with an airborne radioactivity concentration of 10% of the DAC

would require respiratory protection.”

“The following occurrences also indicate the X-326 radiological conditions have degraded to a
point that the HEU Suspension Project should be re-evaluated.

(1) The X-326 Berthold results indicate 110 instances of detectable contamination from

November 18 through December 1.

(2) Instances of removable contamination in the ventilation ducts due to facility design. This
condition can exist in all process buildings, but is highlighted due to the higher assays in the
X-326.

(3) Numerous reports of minor “out-gassings” and/or releases.

(4) Instances of individuals not clearing the Berthold monitors when exiting the building.”

December 10, 1992 - Internal Correspondence, 814-92-86


SEP-19-@@ 10:24 FROM:PACE LEGISLATIVE OFFICE 1D: 292 292 76eaG PAGE

working as an instrument mechanic, I had to work in areas that I knew or suspected were
contaminated. I often felt we should have radiation surveys to see if the area was contaminated,

but at the time it was a hassle to get your supervisor to request a survey.

We have had many small releases which were never reported, as well as documented
large releases. Inside of the withdrawal room we had a major release. There were green “icicles”
hanging in the room from crystalized uranium Hexafluoride. Management had declined to install

safety measures to prevent this release.

Goodyear Atomic issued a Health Physics Philosophy as a Guide for Housekeeping
Problems in the Process Areas, which it distributed to all supervisors on August 27, 1962.
While management assured workers there was no hazard at the uranium enrichment facility in

Portsmouth, Ohio, it warned supervisors:

We don’t expect or desire that the philosophy will be openly

discussed with bargaining unit employees. Calculations of

contamination indices should be handled by the General Foreman.

and kept as supervisional information in deciding the need for

decontamination.

Until the 1980's, there were few or no personal radiation monitors (frisking devices).

This technology was available, but apparently for DOE the cost outweighed the risk. In the 90’s,
this all changed. In certain buildings and certain areas, you have to monitor clothing and shoes.
Without a doubt, if we tried to operate today, as we did the first 25 to 30 years, NRC would cite

the plant for violations.

When I was hired in 1954, process operators were not allowed to wear coveralls or safety
shoes. If clothing became contaminated, we took this contamination home with us on our
clothing and shoes. To my knowledge, crafts (such as electricians, maintenance mechanics, etc)
were allowed to wear coveralls and safety shoes. Sometime in the 60’s, coveralls became
optional for process operators like myself; however, it wasn’t until the 90’s when contamination

Page 10 of 14


“Portsmouth utilized a network of stationary air samplers at various production and non-production
areas throughout the plant. Data documented frequent air sampling results in excess of Portsmouth
limits. These above-limit samples typically were related to process upsets, equipment failure, or
maintenance activities, and were valid high readings. Although log books indicated many dusty
operations or smoky conditions (releases) in all buildings, most of these samples were related to
operations in X-326 and X-705”

“Documents revealed that the methods/calculations pertaining to the air monitoring system
contained three non-conservative assumptions: (1) constant sampling rates for the area air
monitoring systems were determined to be non-conservative for over ten percent of the permanent
sampling locations (primarily in X-705), which were noted as experiencing heavy dust loading that
routinely resulted in lowering flow rates; (2) the absorption effect of the dust buildup on filters was
not considered when the samples were counted, and relatively small amounts of dust on filters will
prevent alpha radiation from being detected; (3) the air monitoring system utilized cellulose filters
for sample collection, but the effect of particle penetration into the filter medium was not
considered. This submersion of radioactive particles within the filter medium was discussed in
ANSI N13.1, “Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities,” the
consensus standard at the time. This guide stated that cellulose filter papers were not well suited for
detection of alpha-emitting radioisotopes by direct counting.

It is evident that there were elevated airborne radioactive concentrations and non-conservative air
sampling assumptions, coupled with continuing management and supervisory failures to actively
enforce the use of appropriate respiratory protection divides. Additionally, workers were reluctant
to use this equipment. Consequently, personnel exposures were likely during a variety of
operations at PORTS”

NEUTRON DOSIMETRY

November 1996 and February 1997 - NIOSH HEALTH HAZARD EVALUATION REPORT
HETA 96-0198-2651 OF PORTSMOUTH GASEOUS DIFFUSION PLANT

p.13 & 14 HISTORICAL HEALTH PHYSICS PRACTICES - “In an effort to reconstruct past
neutron exposures, the historical health physics monitoring and reporting practices were reviewed.
LMUS and union personnel indicated that abnormal chip ratios and high doses (above 2.7 rem)
were routinely assumed to be due to equipment failure (“bad badges”) and little effort was made by
the Health Physics Department to investigate such doses. The 2.7 rem dose supposedly occurred in
the early 1970s during the removal of a uranium deposit in the X-326 Building (high-assay).
However, no report was found in reviewing the Health Physics Exposure Investigation Reports
regarding this event. In addition, no such dose was found in reviewing the computerized Health
Physics historical data provided by the site to NIOSH in support of the current epidemiologic study.
Past recording and reporting activities applied to high doses were provided as reasons for the lack
of historical documents and missing data. Recording decisions regarding high doses were based on
the philosophy that doses of this size were very unlikely when compared with past doses reported
and recorded at the site. Therefore, equipment failure was provided as the reason for the abnormal
dose, and the recorded dose was entered as something other than the measured valve. Official
documentation of this policy for reducing assessed doses could not be found, however. A measured


Worker safety and health programs were established when the plant started operation and have
evolved significantly. The implementation and effectiveness of these programs varied widely,
and in many ways, failed to adequately protect the safety and health of PORTS workers. It was
not until the 1990s that a more focused and rigorous ES&H training program was established.

Staffing for all safety and health organizations was very limited well into the 1970s and was
insufficient to provide adequate attention for up to 2500 employees working in numerous and
varied hazardous conditions.

Records of radiation and contamination surveys were readily available from the start of plant
operation. Survey records for all major buildings indicate contamination levels above limits over
many years. Recommendations for decontamination of locations exceeding PALs were typically
made and noted by Industrial Hygiene and Health Physics personnel on the survey forms. In
some cases, follow-up surveys noted that areas continued to be contaminated above limits, with
continued recommendations for decontamination. However, rigorous enforcement of
decontamination requirements was not evident.

Environmental practices prior to Federal and State legislation in the 1970s and 1980s resulted in
many adverse impacts to the environment, although essentially all on Federal property.
AEC/ERDA/DOE and contractors failed to proactively identify ES&H vulnerabilities, clearly
communicate high expectations for ES&H performance, and implement consistent, effective
corrective actions to known problems. Management also failed to ensure that hazard controls
were implemented by supervisors and workers, resulting in additional and higher exposures to
personnel and continuing unnecessary radioactive contamination.

In the 1980s, OR ES&H Oversight became more rigorous and proactive, especially after the Tiger
Team assessment in 1989 identified significant programmatic deficiencies and unsafe conditions

and performances at the plant.



more effective control measures would ameliorate these risks and lessen the hazardous conditions
formerly created...

The ultimate disposal of contaminated waste-subsurface, surface and airborne-needs much more
thorough study. Even the simplest of such data-recorded periodic measurements of stream

pollution below the plants-are almost wholly lacking. Even with such records, present knowledge
of radiation and chemically toxic effects on animal and vegetable life is so limited that water supply
inlets below plant disposal outlets cannot be unqualifiedly recommended. The disposal of
contaminated waste in present quantities and by present methods (in tanks or burial grounds or at
sea), if continued for decades, presents the gravest of problems.”

-from pages 8, 9, 64, 67

“THE EVOLUTION OF HEALTH PROTECTION STANDARDS
FOR NUCLEAR WORKERS”

“1950 Scientists discard the idea of a “maximum permissible exposure,” recognizing that any

amount of radiation may be dangerous. Radiation protection scientists recommend that exposure be
“as low as reasonably achievable.” Concern over latent cancer, life shortening, and genetic damage

also causes standards to be halved: 0.3 rem per week (15 rem per year).”

“1990 The National Academy of Sciences BEIR V report asserts that radiation is almost nine times

as damaging as estimated in BEIR J. Annual doses may no longer exceed 5 rem per year. The
International Commission on Radiation Protection recommends that an average dose of 1 or 2 rem

per year not be exceeded.”

“RADIATION AND HUMAN HEALTH”
“Its potential for commercial and medical benefits, and its health risks became quickly apparent.”

“At lower doses, radiation can damage DNA, sometimes leading to cancer or genetic mutations.”

“Jn general, the risks of adverse health effects are higher when exposure is spread over a long
period than when the same dose is received at one time.”

“NEED TO KNOW”
“In the interest of national security, nuclear weapons workers generally knew only their particular

jobs. As the Atomic Energy Commission said of the Manhattan Project:

“Just as a man-of-war was compartmentalized to prevent a single torpedo from sending the vessel
to the bottom, the (Manhattan Project) had been subdivided to prevent some indiscreet or disloyal

individual from revealing the whole enterprise to the enemy.”

“The Atomic Energy Commission used these words to describe the system wide
compartmentalization of knowledge deemed essential to building the first atomic bombs. The
intentional narrowing of the field of knowledge, commonly called the “need-to-know” principle,
asserts that there is no real need for individuals to have information beyond the minimum needed
for their jobs. This approach to security pervaded the complex during the Cold War.”


facilities with the potential for such exposures included the cascade and other process buildings; a
feed manufacturing plant; an oxide conversion plant; decontamination, cleaning, and uranium
recovery facilities; a smelter; and incinerators. Leaks and off-gassing from process equipment or
components being repaired or replaced exposed workers to airborne uranium, transuranics, fission

products, fluorine, and hydrogen fluoride (HF) gas.”

September 15, 1993 - HEALTH PHYSICS TECHNICAL GROUP MEMO HT-93-27

Subject: REVIEW X-705 CYLINDER DRYER OVEN AREA
SAFETY & HEALTH COMPLAINT #701-137 (6-17-93)

“Upon collection of air samples that exceeded administrative control levels, Health Physics advised
operations to discontinue use of a pressurized air hose for drying cylinders by forcing air through
the cylinder.”

“IMPACT: Internal doses to workers in this area are under-estimated. Historically, X-705
personnel internal exposures have ranged up to 35 mrem. Assigned exposure could be under-
estimated by as much as a factor of fifty. For example, as a worst case, an individual continuously
exposed to 25% TRU material, whose estimated internal dose from uranium was 35 mrem, would
have actually received 1750 mrem.”

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION PLANT,
VOLUME | - MAY 2000

“The AEC, the Environmental Research and Development Administration (ERDA), and DOE have
always had a site presence at PORTS. But until 1989, had limited ES&H oversight capability or
responsibility. OR conducted very cursory annual safety and health program appraisals from 1957
to at least 1980. However, these appraisals typically involved two or three persons for three or less
days on site “addressing” a broad scope of ES&H functions, as well as corrective actions from
previous appraisals. There was little evidence of field observation in these appraisals.”

“Although the Plant appeared to be responsive to the concerns and recommendations raised by OR,
root causes and programmatic issues were rarely identified and addresses; the adverse conditions
and performance reoccurred, or remained uncorrected in other Plant areas. In the 1980s, OR ES&H
oversight became more rigorous and proactive, especially after the Tiger Team assessment in 1989
identified significant programmatic deficiencies and unsafe conditions and performance in the
Plant. The AEC and its successors also investigated worker allegations of unsafe conditions and
practices, but with inconsistent rigor and effectiveness. A 1980 review by the General Accounting

Office sharply criticized DOE oversight of ES&H at the gaseous diffusion plants.”

“Goodyear Atomic Corporation management oversight of ES&H was reactive and often ineffective,
as reflected in continuing ES&H problems through the years. The Plant responded well when
Federal and State regulators raised major concerns or when new regulations were issued,
implementing corrective actions and developing new programs and controls. However, Plant

management often failed to ensure that ES&H staff recommendations were executed, or that ES&H
requirements were implemented and enforced by first-line supervision.”



“December 14, 1978, Goodyear Atomic Corporation requested cancellation of the Oxide
Conversion Project.”

“A radioactive contaminated acid cleaning solution entered the plant process system through a leak
in a heat exchanger that was being used to heat the solution. Radioactive contamination was
transported to the steam plant and to steam piping across PORTS. Today, many parts of the steam

-from pages 20, 38, 47, 50

September 18, 1979 - INVESTIGATIONS OF HEALTH AND SAFETY CONDITIONS AT
PORTSMOUTH GASEOUS DIFFUSION PLANT

“Process operators have the responsibility to test for the presence of UF6 before releasing the piece
of equipment to maintenance. The Health Physics Department should be informed if the test is
positive (presence of UF6 or UO2F2). This procedure is bypassed by first line supervisors
(foremen) and equipment tested positive for UF6 is released to maintenance for hotcutting and
removal.”

“The investigation found that process operators sample for the presence of UF6. Procedures require
that the system will not be cut into with a UF6 positive (more than 10 ppm UF6). There is no
requirement to notify health physics if a negative (less than 10 ppm UF6) cannot be obtained.”

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, ', VOLUME 1 - May 2000

“In 1979, isotopic analysis of two cascade deposits revealed relative high concentration of
neptunium-237 (i.e., 55 percent and 60 percent of the total alpha activity in the samples was due to
Np-237, respectively). However, there was no indication of a change in the radiological control
program to address this issue, even though data was available to indicate that some level of

transuranic contamination was present in the cascade. Transuranic sampling for work planning and
control was not actively conducted until the 1990s.

“In 1979, a release in the X-705 annex during disassembly of a converter resulted in the internal
contamination of six workers with technetium levels as high as five times the Plant restriction levels
(but not in excess of regulatory limits).”

“In 1980, surveys showed that portions of X-326 met the criteria for a red job area but was not

“Tn 1980, analysis of cascade deposits confirmed the presence of neptunium and plutonium in the

process system. These data indicate that, while Goodyear Atomic Corporation management was
aware of both transuranics and technetium contaminants from incoming feed materials, they failed
to recognize or evaluate potential radiological problems resulting from their concentration in the

cascade.”


physical. When I talk to former workers and retirees, | find out how little they knew about what
they were exposed to. I get calls from widows whose husbands have passed away with cancers.
They want to know if their spouse’s exposure in the workplace caused their illness.

In 1987 NIOSH reported that Portsmouth workers had experienced excess stomach
cancer and hematopoietic cancers (including leukemia). In 1992 the study was updated, in part,
due to a request from Senator John Glenn. In 1996, the study summary was presented to the
workforce. It indicated that there were no statistically significant elevations of any cancer deaths
and the elevations of stomach and hematopoietic cancers identified in the 1987 study had
diminished. These results were presented to the media in September 1999°. However, the
NIOSH officials releasing this information apparently chose to DELETE the page defining the

study’s limitations’, which includes (1) this was a mortality study and not a study of disease

° Portsmouth Gaseous Diffusion Plant: Study Summary, Rinsky, Ahrenholz, and
Cardarelli, September 1999

7 Restated below are portions that were deleted by NIOSH before releasing the summary:

“All observational epidemiologic studies have some limitations since they take advantage of naturally
occurring events rather than being conducted in an experimentally controlled environment. Here are the biggest
limitations that we know about:

1) This is still a very young population and the vast majority of them are still alive. As the workforce grows
older, deaths will occur at an increasing rate and of course there is no way to know what these people will
eventually die from,

2) this is a study of mortality, not disease incidence. Only diseases that have high case fatality rate are

measured well by mortality. Although most cancers have a high case fatality rate, there has been great progress over
the past two decades in prolonging the life of persons with hematopoeitic cancers. Mortality may not be a good

measure of these deaths;

3) SMR analyses are not particularly good attributing the proper effects of confounding and effect
modification. The case control studies that are being worked on are much better in this regard;

4) the exposure response portion of these analyses are only as good as the exposure metrics. Because of the

way the plant collected exposure data our algorithims for assigning exposure, while the best that can be done, still
have a degree of uncertainty To the extent that real exposures are over or under estimated, our answers will be in

Page 10 of 12


January 6, 1993 - Internal Correspondence POEF-160-93-011
Subject: AIRBORNE RADIOACTIVITY SUMMARY OF THE X-326 BUILDING

“The need for increased loose surface contamination surveys and special airborne monitoring in the
X-326 Building was deemed necessary by Health Physics supervision and started on December 11,

1992.”

“This data indicates the following:

1. The airborne concentration varied inversely with atmospheric pressure; as pressure went
down airborne activities increased. This correlation still holds true; however, the increase in
activity for the same change in atmospheric pressure is not as dramatic as compared to the
increases noted when the special air monitoring program began on December 11.

3. Airborne concentrations are virtually the same on the operating and the cell floor. The
operating floor has only slightly lower activity level.

4. Airborne concentration is virtually the same north to south. The south side of the building
has only a slightly lower activity than the rest of the building.

5. Contamination levels are uniform throughout the building with the exception of the
southwest corner of the building, which exhibits unusually high beta activity.

6. There were days when the overall airborne radioactivity concentration did exceed 10% of
the DAC; however at no time was the airborne on average greater than 10% of the DAC for
an entire workweek.

While the situation appears to have eased, a concerted effort to take the number of cells to a
negative must be continued.”

February 9, 1993 - Internal Correspondence POEF-160-93-098

Subject: SUMMARY OF AIRBORNE RADIOACTIVITY STUDY PERFORMED IN
THE X-326 BUILDING

“The need for increased loose surface contamination surveys and special airborne monitoring in the
X-326 Building was deemed necessary by Health Physics Supervision.”
AIR SAMPLING
1994 NIOSH HEALTH HAZARD EVALUATION REPORT NO. 94-077-2568
p. 19, “The location of the samples collected in the X-326 Building, which is at the product
enriched end of the process and contains a higher of U235, presents radiological health hazards due
to uranium which are not adequately addressed with the mass per volume airborne concentrations.”
May 2000 - OFFICE OF OVERSIGHT ENVIRONMENT, SAFETY AND HEALTH
INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS
DIFFUSION PLANT - VOLUME |

p. 39, 3.1.7 - AIR SAMPLING


October 2, 1975 - INTERDEPARTMENTAL CORRESPONDENCE, GAT-242-75-121

Subject: TECHNETIUM IN X-705 EFFLUENTS

Need For Immediate Action

As we have discussed, the beta-gamma activity in the east drainage ditch has increased
astronomically during September. The Chemical Analysis Department has identified the major
source of this activity as beta radiation from technetium-99. The technetium activity in our
Station 11 composite water samples! during 1975 are shown in Figure 1. Station 11 is located on
the east drainage ditch immediately before it joins with Little Beaver Creek.

The weekly sample collected on September 29" showed a technetium activity of 67,600 d/m/100
ml (1.79 ppm Tc). This weekly-average value is 101.5 percent of the recommended concentration
guideline2 (RCG) for uncontrolled areas published in ERDAM 0524. It is also over 300,000
times the radiation limit specified by the State of Ohio (100 picocuries beta/liter). Note; however,
that the State and ERDA standards are based upon instantaneous concentrations. I would guess
that our peak Tc concentration is probably 20 times the average value. Therefore, we may exceed
the ERDA standard by a factor of 20, and the State standard by a factor of 6 million.

The Ohio EPA has harried ERDA in the past about our radiological effluents exceeding state
limits. In September alone, we have lost about 45 curies of technetium.

What Has Been Don

Studies by the Process Technology Department have shown that all of the technetium in the
drainage ditch originates at the X-705. We are still not sure exactly how the technetium is
entering the X-705, but obviously it is either contained in cylinder heels and/or the process
equipment being decontaminated.

Even if we maintain the average-weekly concentration slightly below the RCG, our instantaneous
Tc concentrations will still exceed both State and ERDA standards by a very wide margin.
March 10, 1994 - HEALTH PHYSICS OPERATIONS MEMO, OM-94-019

Subject: ALARA REVIEW OF AIRBORNE RADIOACTIVITY IN X-705 GREATER THAN
ADMINISTRATIVE CONTROL LEVELS

Though this ALARA review was triggered by an isolated event (“H” area), this is the third
instance of high levels of airborne contamination being spread into areas of the X-705 where
routine work does not require respiratory protection this year. The adverse impact of this event


93 Defense Authorization Act should go even further, with lifetime annual medical
screening. We need fully paid medical insurance for displaced or retired workers. A
Medigap supplement should be fully funded by the government for nuclear workers.

2 Workers at Portsmouth and Paducah face a unique problem with retiree health care
benefits. Since USEC was privatized, it assumed responsibility for the Lockheed Martin
retiree health care benefits program. However, these benefits could be in jeopardy if
USEC, as many predict, will fall into bankruptcy or liquidate in several years. Unlike
pensions, retiree health care benefits are not guaranteed under ERISA. We need
legislation to guarantee that the funds which the DOE will be giving to USEC to cover
the past retire health care liability are placed in a safe harbor and these health benefits will

be delivered as intended.

SUMMARY
Energy Secretary Richardson acknowledged that “After decades of denial, the

government is conceding that workers who helped make nuclear weapons were exposed to
radiation and chemicals that produced cancer and early death.” In the New York Times article,

the Secretary said: "In the past, the role of government was to take a hike,....and I think that was

wrong,” Nuclear workers have paid a price and deserve a fair remedy.

° New York Times, January 29, 2000, pp1.
Page 12 of 12


4 INTRODUCTION

In the late 1990’s, the Department of Energy (DOE) admitted that nuclear workers had been put in
hatms way during the Cold War. (Cold War Veterans)

In 1999, congressional hearings were held in the Senate and the House of Representatives. Asa
result of these hearings, Congress passed and the President signed the “Energy Employees
Occupational Illness Program Act of 2000” (EEOICPA). Part of this act deals with dose
reconstruction for nuclear workers who have contracted cancer. Site profiles are an important
ingredient in helping NIOSH in their effort to do dose reconstruction.

In order to have a valid profile, we need to understand what transpired to bring the EEOICPA into
existence. To do this, we need to look at the nuclear industry since its inception.

CLOSING THE CIRCLE ON THE SPLITTING OF THE ATOM

“THE MANHATTAN PROJECT”
“The quest for nuclear explosives, driven by the fear that Hitler’s Germany might invent them first,

was an epic, top-secret engineering and industrial venture in the United States during World War II.
The term “Manhattan Project” has become a byword for an enormous breakneck effort involving
vast resources and the best scientific minds in the world. The workers on the Manhattan Project
took on a nearly impossible challenge to address a grave threat to the national security.”

“From its beginning with Enrico Fermi’s graphite-pile reactor under the bleachers of Stagg Field at
the University of Chicago to the fiery explosion of the first atomic bomb near Alamogordo, New
Mexico, the Manhattan Project took a little less than 3 years to create a working atomic bomb.
During that time, the U.S. Army Corps of Engineers managed the construction of monumental
plants to enrich uranium, three production reactors to make plutonium, and two reprocessing plants
to extract plutonium from the reactor fuel. In 1939, Nobel Prize-winning physicist Niels Bohr had
argued that building an atomic bomb; can never be done unless you turn the United States into one
huge factory.” Years later, he told his colleague Edward Teller, “I told you it couldn’t be done
without turning the who country into a factory. You have done just that.”

-from pages 1, 2, 38, 39, 81

April 2, 1948 - REPORT OF THE SAFETY AND INDUSTRIAL HEALTH ADVISORY
BOARD

“The Atomic Energy Commission isolated its projects, built plants which are a marvel of
engineering and guarded them with extraordinary efficiency. Their sins of emission-liquid, solid, or

gaseous-were diluted and isolated to what was estimated as perfectly safe, but AEC is now entering
a phase in which their operations in this regard will soon be public property and they will be

accountable to public health-a very severe critic...

In the haste to produce atomic bombs during the war certain risks may have been taken in research,
production, testing, transportation and waste disposal with the understanding that subsequently


compared to uranium, and tower ash (where transuranics were expected to concentrate) could be
monitored to measure the existing hazard. However, this monitoring program was not
implemented. PORTS was also aware of the presence of technetium on process equipment as early
as 1962, but also assumed that transuranics and fission products would not be a significant hazard
to workers. No special monitoring gr personnel protection controls were established. This posture
persisted until 1975, when sampling and analysis of media, including pond sludge and waste
samples, identified technetium-99.”

“In 1957, radiological surveys at the Paducah Plant found neptunium-237 in the enrichment
cascade. Although the AEC recognized the potential for transuranic contamination of the cascades,
it was not until a 1965 appraisal that OR identified a potential problem with transuranics and fission
products in X0705E, and recommended studies to determine where they could concentrate in the

process. Although records indicate that PORTS reviewed the potential problems posed by feeding
reactor returns to the oxide conversion plant, detailed studies were not performed.”

“In-vivo monitoring was performed on oxide conversion plant workers, and, in 1965, significant
intakes of insoluble uranium were detected in at least two of these workers. These employees were
put on permanent restriction and had measured lung burdens over 50 percent of allowable limits
many years later. One worker still had a significant lung burden when he retired in 1985.”

“In 1965, an in-vivo body counting program was initiated to monitor for insoluble enriched
uranium, a material for which the urinalysis program was not sufficiently sensitive or reliable.

Studies performed in 1990 indicated that the in-vivo counter’s capability for analyzing transuranics
was questionable, making it difficult to demonstrate that all internal exposures have been accurately

detected and assessed.”

“In-vivo radiation monitoring for insoluble radionuclides by lung counting was initiated, first by
sending workers to Fernald or Oak Ridge, and later using a mobile counter periodically sent to

PORTS from Oak Ridge. However, lung-counting methods were not sufficiently sensitive and

were only effective for assessing relatively large intakes.”

“Some workers had extremely high intakes of uranium detected by bioassay or in-vivo testing that
put them on work restriction for months or years. In 1965, ten employees sustained lung exposures
greater than one-half the permissible level, and eight were reported to the AEC as overexposures in
accordance with AEC regulations. In addition, a worker who had a massive intake of UH6 in 1973
was still excreting uranium six months later, and two workers in 1965 were exposed to uranium
levels high enough that, as late as 1973, in-vivo testing showed greater than 50 percent of the
maximum allowable body burden for uranium. Finally, one worker, still living, was put on
permanent restriction in 1981, and his in-vivo monitoring before his 1985 retirement still showed

high uranium readings in his lungs.”
“X-705 OXIDE CONVERSION

“A handwritten report entitled “oxide conversion as viewed by Development” was written by a
member of the Development Department (CIRCA 1966) in response to a significant error in the
uranium mass balance in X-705E. The report explained that the oxide conversion process was
originally established as a waste recovery process. The subsequent introduction of reactor returns
converted X-705E into a production facility, requiring a capacity that “it was ill-equipped to


buiewe “os roo PAGE

Arsenic contaminated feed was fed into the Portsmouth cascades in the late 1980's.
Arsenic, which is a known carcinogen, migrated towards copper instrument lines causing them to
plug up. Air samples detected arsenic in excess of OSHA limits. In 1993 inorganic arsenic was
discovered, and the union subsequently requested a health hazard evaluation over concern that

there were inadequate controls.

Fluorine gases from the fluorine plant stack were frequent and resulted in numerous
complaints from workers in the area, especially during temperature inversions, fog, rain or when
the vented gases are forced to ground level.”®

Trichloroethylene (TCE) was used as a degreaser and chiller. A 1986 special survey
found levels of TCE in excess of the OSHA permissible levels in process building X-326.

H. RESPIRATORY PROTECTION DEPENDED ON WWIHI-ERA GAS MASKS FOR MANY
S RK AREAS WERE P ERLY TESTED FOR PRESENCE OF

RADIONUCLIDES
I worked at the Extended Range Product (ERP) station on and off for a number of years.

On one occasion while connecting the production process into an empty cylinder, the copper
tubing pigtail ruptured. Although J immediately valved off the system, the room was filled with a
thick fog of uranium oxide gases. I donned an army assault mask for protection. After the all
clear signal, management sent me to the hospital for urinalysis. Today, we know that you should
wait for 3-4 hours to give the material time to get into your system before urinalysis. For that

reason, my dose records from this accident is going to be suspect, at best.

Indeed, until the mid 1970's, our respirator protection consisted of World War II army
assault masks. It was years later that we leamed that these were not adequate to block

1° Independent Investigation of the Portsmouth Gaseous Diffusion Plant, Volume I: Past
Environment, Safety and Health Practices, Department of Energy, Office of Environment Safety

and Health, May 2000, pp.27.

Page 8 of 14

ie.


NIOSH
Page 2

The assurance that the 32 or more PORTS NIOSH decisions could be re-evaluated, if the Site
Profile development or any other information could impact those decisions should make claimants
feel a little better about having to sign the OCAS form and go through the closing interview process
knowing the information is still forthcoming.

During the meeting, a number of potential items and situations were identified that would assist in
your function of dose reconstruction. We feel that this information may provide the evidence that
accurate dose reconstruction is not possible. We ask that these recommendations be part of your
dose reconstruction assessment.

We requested that you determine the percentage that the personal and environmental badge results
were assigned or missing. Our historical knowledge leads us to believe that a large percentage of
the badges were assigned a dose or labeled as missing. The process of assigning doses was not
consistent and does not seem to be as technically sound as NIOSH would expect. Providing us that
information would be appreciated.

We also requested that you look into operational documentation that may contain information that
would identify potential exposures that may have not been well documented in the health and safety
data. This information included, but not limited to, the procedures and logbooks related to the
radiation clusters, the argon gammagraphs, classifying of removed process equipment, monitoring
of deposits in the cascade (RASCAL) readings, and special cascade projects.

We offered to assist you in specifically identifying which of this data would be helpful. Please let
us know when you wish to visit the plantsite to collect this information.

President

Ce: Advisory Board


June 26, 1975, GAT-521-75-113 - Interdepartmental Correspondence

Subject: SAFETY PROCEDURES FOR HANDLING TECHNETIUM-CONTAINING
MATERIALS

“During June 16-20, 1975, multigram deposits removed from the inlet lines and valves to the
Freon Degrader were found to consist of 20 percent Tc by weight.”

“While safe procedures for dealing with materials containing enriched uranium are standard
practice at GAT, technetium contamination is a new and separate problem. The unfamiliar
nature and unexpected presence of large quantities of Tc demand that special precautions be
taken by plant personnel who must handle cascade equipment or materials contaminated with

technetium.”

January 20, 1977 - ERDA Investigation

Subject: ERDA INVESTIGATION

“Employee Complaint re: Technetium Close Out Conference held with ERDA Inspectors:
Mike Kanazawitch, Richard Smith, and B. J. Davis -- Attending for the Employees were W. J.
Fields, Local Union President; C. A. McNelly, Local Union Vice-President; and Local Union
Steward, J. G. McCollum.

At X-326 Building, Cell 25-7-18 in June 1976, there was widespread technetium
contamination. C. Spradlin of Health Physics for GAT stated that X-326 was hot halfway
down the building. Several maintenance personnel were exposed and went on restriction on
June 18, 1976 and were taken off restriction on June 23, 1976. We were informed at the
January 20, 1977 meeting that Yelley had a body count of 79,000 and Schuller a 57,000 body
count.”

February 8, 1980, Operating Specification CN 11.1

Subject: GUIDELINES FOR NON-EMERGENCY ACCESS CONTROL OF X-326
BUILDING

“1.0 SCOPE
Surveys conducted by IHHP indicate that parts of the X-326 Building have surface
contamination levels sufficient to require decontamination. Aside from certain well-
defined ground floor areas, the contamination is confined to the cell floor. A
decontamination crew has been assigned and dedicated to the building. Boundaries
have been established, using barricade tape and signs that indicate the contaminated
area.”

May 8, 1980, Interdepartmental Correspondence


PORTSMOUTH GASEOUS DIFFUSION PLANT (PORTS)

RADIOLOGICAL/CONTAMINATION PROFILE
(Compiled and Edited by: Jeanne Cisco, Paul Mullens and Sam Ray)

INDEPENDENT INVESTIGATION OF THE PORTSMOUTH GASEOUS DIFFUSION
PLANT, VOLUME 1 - May 2000

“The environmental monitoring program at PORTS was initiated in 1955.

“During the 1952-1953 period, the AEC approved the enrichment processing of production reactor
tails through gaseous diffusion process. In 1957, radiological surveys at the Paducah Plant
identified that neptunium-237 was present in the enrichment cascade. Although the AEC
recognized the potential for transuranic contamination of the cascades, it was not until a 1965
appraisal that OR identified a potential problem with transuranics and fission products in X-705E
and recommended studies to determine where these materials could concentrate in the process.

Records reflect that PORTS then reviewed the potential problems posed by feeding reactor returns
to the oxide conversion plant; however, detailed studies were not performed. PORTS

correspondence also indicates that health physics staff did not fully understand the presence of
transuranics and technetium-99, and appropriate analytical procedures were not developed as late as
1976. During the 1970s, PORTS health physics and Plant managers participated in pre-planning for
receipt and subsequent processing of recycled uranium known to contain trace quantities of
neptunium-237, plutonium-239/240, and technetium-99. Planning activities included development
of recommendations for material receipt specifications and specific controls to minimize personnel
exposures, including the use of containment devices and ventilation systems. Many
recommendations were implemented but were not sufficient.”

“PORTS was also aware of the presence of technetium on process equipment as early as 1962, but
also assumed that transuranics and fission products would not be a significant hazard to workers.

No special monitoring or personnel protection controls were established.”

Health and safety activity reports from the mid-1960s identified that excessive inhalation of
uranium compounds was the major radiation and contamination risk at PORTS. PORTS documents
also reveal that internal deposition became a problem in 1965 from handling insoluble enriched

uranium, and that urine sample results were neither reliable nor as sensitive as analysis for soluble

forms.

During the 1960s, the Ports health physics group became concemed with increasing alpha radiation
levels in process and support facilities at the site. While no records were identified to demonstrate
that this issue was satisfactorily resolved, the period coincides with the processing of recycled
uranium at the Paducah Plant. In 1979, isotopic analysis of two cascade deposits revealed relative
high concentration of neptunium-237 (i.e., 55 percent and 60 percent of the total alpha activity in
the samples was due to Np-237, respectively). However, there was no indication of a change in the
radiological control program to address this issue, even though data was available to indicate that

some level of transuranic contamination was present in the cascade. Transuranic sampling for work
planning and control was not actively conducted until the 1990s.

The low specific activity and the self-shielding properties of uranium handled at the site limited
dose rates at PORTS. However, certain operations were known to result in higher exposure
potential. Routine whole body beta exposures in excess of PORTS investigation levels existed


MEMORANDUM (MEMO GAT-922-76-184)

“A 1976 memorandum identified transuranics as a problem at PORTS, especially in the oxide
conversion process.”

6-23-77 GAT-920-77-64 Subject: THE UNION’S EXPRESSED CONCERN OVER
RADIATION AND RADIOACTIVE CONTAMINATION

“The Company relies upon the Industrial Hygiene and Health Physics Department to measure levels

of contamination in work areas. Employees working in the area are not expected to make such
surveys; therefore, survey meters have not been made available to them.”

“Tt is true that employees are not told the exact levels of radioactive contamination in the areas in

which they are working. With proper understanding of radiation and contamination—such as the
employees are getting in the new training course—the employee’s concern is whether or not the
contamination or radiation in the area a less than that considered safe for a working area. The IH &

HP Department makes those decisions.”

“Tt has been the failure to close down existing ventilation systems rather thank the lack of
ventilation that has been responsible for the spread of released materials.”

“Control of contamination in lunchroom or dining facilities has been a problem.”
“It is true that evacuation procedures and monitoring station procedures are not always clearly

understood or followed.”

-from pages 3, 4, 5

July 11, 1980 REPORT BY THE COMPTROLLER GENERAL OF THE UNITED STATES

“Department of Energy’s Safety and Health Program For Enrichment Plant Workers is not

adequately Implemented.”

“Safety and Health Inspections Not Conducted”

“When inspections have been conducted, they have not included checking radiation levels in the
plant. Thus, DOE cannot be sure that it is aware of potential hazards and take prompt action to
eliminate or mitigate the risk of accidents. A March 7, 1978 release of more than 10 tons of liquid
uranium hexafluoride from a ruptured storage cylinder at the Portsmouth, Ohio enrichment plant
may have been avoided, had the Department conducted on-site inspections and discussed safety and
health concerns with employees.”

“A vehicle carrying a 14-ton cylinder containing liquid uranium hexafluoride failed. The cylinder
was dropped and ruptured, releasing 21,125 pounds of uranium in about 5 minutes. No employees
were exposed in excess of maximum limits; damage totaled $368,350. A report on the accident

indicated the vehicle was in extremely poor condition and that many cylinders had been previously


Ser AS m we Bete PRUME PACE LEULSLALIVE Urrits

tb: 2u2 2y4 rue PAGE

controls were implemented that coveralls became mandatory. In reality, they should have always
been mandatory.

Current workers benefit greatly by the present safeguards in place. Primarily, the
problem lies in the first 35 years. What were the former workers exposed to unknowingly or may
be knowingly? We know that they are having many health problems, such as cancers, respiratory
problems, etc. and in numbers far greater than would be expected. ;

2 INSP’ WE! 7S POL OF SELF
REGULATION

A July 1980 Comptroller General report, Department of Energy's Safety and Health
Program for Enrichment Plant Workers Is Not Adequately Implemented (EMD-80-78), found
that DOE’s Oak Ridge Office, which had oversight responsibility for health and safety, had not
conducted a safety inspection at Portsmouth for 3 years and was not adequately responding to
worker safety complaints. Unannounced safety inspections were supposed to occur annually at

each plant, but even when they were inspected, the Oak Ridge Office “does not, as part of an
inspection or any other visit to an enrichment plant, monitor for radiological contamination.” Oak

Ridge explained the absence of inspections on a staff shortage, which the Comptroller General
noted was attributable to Oak Ridge paying safety inspectors at a lower grade than elsewhere in

the DOE complex.
3 ON.

FORMER WORKERS

Currently, I am a retiree representative for the Worker Health Protection Program.
Funded by DOE, this program gives former workers a one-time complete physical, and tung
cancer screcning will be added this fall. When I talk to former workers and retirees, I find out
how little they knew about what they were exposed to. I get calls from widows whose husbands
have passed away with cancers. They want to know if their spouse’s exposure in the workplace

caused their illness.
In 1987 NIOSH reported that Portsmouth workers had experienced excess stomach

Page ll of 14


lunch rooms that were surveyed on a regular basis and kept clear (1980’s).

Due the lack of a contamination control program, certain buildings were becoming more
contaminated. For example, leaks from the ERP station had spread contamination in the X-326
building. Compressors would malfunction and process gases (UF6) would leak to the
atmosphere. On ONE occasion, it was so bad that it looked like a fog moving up the building,
which is approximately “2 mile long. I became personally aware of this contamination problem
when working as an instrument mechanic, because we had to work in areas that we knew or
suspected were contaminated. I often felt we should have surveys, but at the time it was a hassle
to get your supervisor to request a survey. Today, the story is different.

We have had many small releases which were never reported, as well as documented
large releases. In side of the withdrawal room we a major release. There were green “icicles”
hanging in the room from crystalized uranium hexaflouride. Management had declined to install
safety measures to prevent this release.

Goodyear Atomic issued a Health Physics Philosophy as a Guide for Housekeeping
Problems in the Process Areas, which it distributed to all supervisors on August 27, 1962.
While management assured workers there was no hazard at the uranium enrichment facility in
Portsmouth, Ohio, it warned supervisors:

“We don’t expect or desire that the philosophy will be openly discussed
with bargaining unit employees. Calculations of contamination indices
should be handled by the General Foreman and kept as supervisional
information in deciding the need for decontamination.”

Until the 1980's, there were few or no personal radiation monitors (frisking devices).

This technology was available, but apparently for DOE the cost outweighed the risk. In the 90’s,

Page 8 of 12


spread of contamination are parallel. The mitigating factor in our favor is the significantly
lower specific activity of uranium compared to reactor corrosion and activation products. The
Jack of continuous air monitors and diffuse on pneumatic equipment is identical to LaSalle.

|. The enterprise has the potential for civil penalties for radiation protection.

A review was conducted of the past 12 months of compliance activity from “Nuclear News”.
The NRC has issued fines to the commercial power industry totallying over $3.7 million in the
past 12 months. They are fully staffed to win a court fight and have no reluctance to do so.
With one exception, the fines are levied for operational performance and not documentation
problems. (A $15,000 fine was levied against one utility for insufficient analysis of a safety
system design change.) Given the events and non-conformances of the past 9 months, we have

the potential liability for civil penalties.


Subject: PHASE II INVESTIGATION OF HEALTH AND SAFETY CONDITIONS AT
PORTSMOUTH PLANT

P. 3, #6. “Expedite the decontamination of Building X-326 and institute procedures to reduce
further contamination and require immediate cleaning should an area become contaminated in

the future (see Allegation 2A).”

P. 18, ALLEGATION 2A: “It is alleged that a survey conducted by the company on Building
X-326 revealed a much higher level of contamination than was indicated to the Union safety
representative. A Business Confidential Report No. GAT-923-78-297C supposedly contains
the correct reading which indicates that the building was on the border line of a “red job”

status.”

FINDINGS: “The referenced report (GAT-923-78-297C) does exist and it does indicate that
the cell floor of Building X-326 should be classified as “red job” area. The Committee finds
that Goodyear did not completely or timely implement the recommendations of the report.”

P. 19: “When questioned about how this building became contaminated, middle management
stated it was due to a decrease in the timely decontamination of areas after maintenance and/or
releases. This change began in the mid-1960’s more or less coincidental with reduced
operating levels in the Plant.

The Committee concludes that these practices, specified above, exhibit a failure on the part of
management to assign a sufficiently high priority toward contamination control.”

July 11, 1980, Report By The COMPTROLLER GENERAL of The United States

Subject: DEPARTMENT OF ENERGY’S SAFETY AND HEALTH PROGRAM FOR
ENRICHMENT PLANT WORKERS IS NOT ADEQUATELY
IMPLEMENTED

“The Department of Energy’s (DOE’s) program to protect the safety and health of employees at
its contractor-operated uranium enrichment plants has not been fully implemented by DOE’s
Oak Ridge Operations Office. Appraisals and inspections of plant conditions are not as
frequent and/or as thorough as required. Instead of independently investigating employee
complaints, DOE has delegated this responsibility to the contractor”

P. 23 (X-326) “In another example, the lack of inspections and inadequacy of appraisals
allowed a situation to exist for nearly 1 % years before corrective action was taken. On
October 24, 1978, contractor safety and health personnel at the Portsmouth plant issued a
report, which stated that one area of a building was highly contaminated. The report
recommended that the area be classified as a “red job” area *1/ and that decontamination
procedures begin. The contractor took no immediate action. In September 1979, the
contractor’s safety and health staff again found the area to be contaminated and made the same
recommendation contained in their earlier report. The contractor again took no action. Oak
Ridge Operations Office safety and health officials informed us that they were aware of the
contamination problem but thought that corrective action was underway. They also indicated


contamination control program at the Plant and make recommendations for implementation of a
more effective and uniform policy. Contamination control problems continued to persist into the
late 1980s. Although Goodyear Atomic Corporation management and the Industrial Hygiene and
Health Physics Department were concerned about the need to control contamination levels as low
as reasonably achievable (ALARA), contamination control policies and procedures were not fully
effective, as evidenced by continuing radiological problem reports and PORTS emphasis on
corrective actions that lasted into the 1990s. These deficiencies are likely to have resulted in
additional exposures and spread of contamination over the plant operating history.”

May 8, 1980, Interdepartmental Correspondence

Subject: PHASE Il INVESTIGATION OF HEALTH AND SAFETY CONDITIONS AT
PORTSMOUTH PLANT

P.3, #6, “Expedite the decontamination of Building X-326 and institute procedures to reduce further
contamination and require immediate cleaning should an area become contaminated in the future

(see Allegation 2A).

April 25, 1990, FINAL TIGER TEAM ASSESSMENT FOR THE PGDP, P. ES-3 (X-326)

“Contamination control is a major concern at PORTS. Efforts have been underway to reduce
contamination levels in the major process building. Inadequate contamination control and
occupational safety practices in three PORTS maintenance support facilities were considered
sufficiently serious to warrant immediate corrective measures by the contractor. These measures
were accomplished while the Team was on site. A breakdown in standard workplace controls was
found in these facilities, with widespread evidence of eating, drinking, and smoking in
contaminated areas; a lack of routine contamination surveys being conducted; and little follow-up
and accountability to contamination surveys and tagging. The larger issue of upgrading the PORTS
contamination control program is being addressed in the implementation plan for DOE Order
5480.11 (Occupational Radiation Protection).

Occupational safety concerns centered on basic Occupational Safety and Health Administration
(OSHA) and DOE requirements and procedures not being implemented in the workplace. Although
many of these requirements and procedures are prescribed by the PORTS Safety Manual, they are
neither understood by workers, nor enforced by supervisors. Unsafe practices requiring prompt
abatement were observed during Team member walk-throughs. Management is cognizant of the
scope of these deficiencies (raised in an earlier ORO appraisal) and is determining how best to
implement an OSHA compliance program consistent with the Secretary’s 10-Point Initiative.

Management from MMES has recognized that the PORTS safety analysis report (SAR) is
inadequate. It is being revised, although the time frame for completion (FY 1994) seems
protracted. Derivative operational safety requirements (OSR’s) are not clearly prescribed; written
procedures to define acceptable conduct of operations in the context of OSRs and DOE
requirements are incomplete and not consistently enforced. The formality and discipline that guide
typical nuclear operations are lacking at PORTS, a root cause for many findings.”


incidence; (2) the population is still relatively young to conduct an epidemiology study; (3) case
control studies would be better at identifying cause and effect; (4) the exposure data is weak; and
(5) workers were exposed to a mix of chemicals and radiation and the effects are difficult o
disentangle. We obtained the deleted text. These limitations, if incorporated, substantially alter

the light in which the findings should be considered. What motivated this apparent censorship is

beyond our knowledge.

RECOMMENDED ACTIONS FOR CONGRESS

Congressman Ted Strickland and 10 cosponsors introduced HR 3495 to provide workers’
compensation for radiation exposed workers at DOE nuclear facilities and suppliers. It
lays down important marker, because, unlike the Administration’s bill (HR 3418 and S
1954), it expands coverage beyond the Paducah workforce and 55 workers in Oak Ridge

to cover the entire DOE nuclear complex.

al

. Any successful bill must shift the burden of proof to the government in determining
causation, because the failure to properly monitor for radiation and toxic hazards imposes
an insurmountable burden of proof on a victim. Dose reconstruction is very costly, takes
years to accomplish and the results are questionable at best since basic data was never
collected in many cases. NIOSH noted in a 1993 report, that “prior to 1981, the amount
of quantitative industrial hygiene data is scant to non existent.*”

. A single agency, such as the Labor Department’s Office of Worker Compensation
Programs, should administer a federal workers comp program. We need one stop
shopping for addressing occupational illnesses regardless of whether it is beryllium,
radiation, toxic chemicals or heavy metals.

The current medical screening program carried out by DOE under Section 3162 of the FY

error; and finally,
5) these workers were simultaneously exposed to a number of chemical and physical agents and it is very
difficult to disentangle the effects of the concurrent exposures.

Moreover these workers are protected by some other factors associated with their employment at this
facility, such as lower alcohol and smoking rates as a consequence of their security clearance requires. This further
complicates the interpretation of any harmful effects there might have been suffered.”

® Protocol for the Study of Mortality Patterns Among Uranium Conversion and
Enrichment Workers, NIOSH, J. Stebbins, etal, July 1, 1993, pp.15

Page 11 of 12