Thorium processes had been shut down and most of the thorium equipment had
been removed prior to the effluent data reconstruction, which made the reconstruction
more difficult.

‘Where production data was not available, estimates were based on product
volume and yield information. These estimates were researched from various files of
FMPC, Oak Ridge, AEC, and FMPC customers.

Part of the reconstruction process involved interviews of long-time current and
retired employees about thorium production. The interview included 9 questions.

Note: The question not asked was; What other plants processed thorium?
{That seems so basis, if you’re reconstructing destroyed records.}

This information was used to develop process flow sheets and locations of
possible emission sources that were identified from the components of each process.

pgl9 The data reconstruction indicates that thorium processing was limited to
three plants over short periods in the 38 year production history of FEMP.

Table 5-13 provides a tabular presentation of the thorium production estimates in
MT by year, compared to uranium production in the same plants. The production values
in Table 5-13 represent only the uranium and thorium production in the specific areas as
identified in tk di

Note: Previously in 5.2.1, in the description of processes by plant, thorium is also
mentioned in Planti and Piant4,

Femald document PE745ww, dated March 6, 1963 states: Thorium Furnace--
Plant 6: ‘Air dust samples taken during the operation of the thorium furnace show levels
far exceeding the MAC for thorium, Breathing zone air show levels of various operations
tange from 10 to 1.770 MAC. This is believed to be due to the decrease in ventilation
(Che Pan Ie delivering less than 1/2 of its eafod capacity) and to lack of adequate

Note: In 42 CFR Part 82 (final rule) Federal Register/ Vol. 67, No. 85/ Thursday, May 2,
2002/ Rules and Regulations pg22323 ; in response to a comment on possible recall
difficulties. ‘It is well recognized from health, behavioral, and social research that there
are substantial limitations and variations in the ability of people to accurately recall past


William T. Doran, &.D, Page2
Movember 1, 1963

af internal dose to uranium workers, though frankiy this is ose of the most
@ifficull preblems we have encountered.

Eexposure to internal emitters is the more serious type of exposure st the feed.
which previ ;

paaterials centers and probsbly also st the mille whi

for the feed materials centers, 1 have az impression that airborne exposure
at other sites is a relatively minor portion of the oversil exposure; at Fernald.
bowever, this is not £0. ‘Exposures to external peustrating redistion are rela~
tively minor here and always have been less than the current Federal Radiation
Council Guides of § & per year of gatoms and 30 reps of beta.

Part of the problem with determining internal dose can be illustrated by the
following table. This table gives breathing sone (BZ) concentrations of air~
borne uranium and daily weighted exposure (DWE) concentrations for seven
Operations in our metal productiea plant for the years 1959 and 1962. Au
concentrations are listed in »c/cc; ‘ail numbers are multiples of 107?! yc/ce.
The maximum perziesible sir concentration or a 40-bour week for satarel
‘wranium given in NBS Handbook 69 (6x1078)).c/ co.

1959 1962
Job Description BZ DWE BZ OWE
Rockwell operator - 64x ot igaxtom!? — . 64x) ont} sextant}

Furnace Pot Delidding opr, 40, 0x30721 20, 720°!) 2. 1x1 old =u auton tl
Derby Breakout operator 9. Sxio}4 7, sxtot? «22x20 72} taxon}!
Pot Hook-p operator pease 078) agantot!? arexaat. —.¢4xtor??
Residue operator ngo.oxte"t? 2zoxto"!? = 22cto7M} — .sutord?
Derby Cleaning haiper taax207!)  zazto7lt = 3, az. 07?? 2.2xio7!?

Reduction Area laborer .11.4x1072 1, 1x107!! 190, oxt0“! 9. oxto7}t

As you can sew froc: the above table, 3 Rockwell operator has had 2 relatively
low exposure in 1959 and 1962, and from my information aise in the intervening
years. In 1959 the esidue operator had a high exposure and in 1962, alow
exposure; it is obvious that by 1962 conditions had improved. The Reduction
Area Laborer hae 2 record of low exposure in 1959 and a high exposure in 1962.
As you can see from these examples, exposures from various jobs will fluctuate
considerably over a period of time.

@ vieisos


al

‘re

7

Fer current workers.

For ali workers,

If B1 or B2 are Yes. within what period of time could you provide
this information (e-g-. 2. weeks, ett. )?
With Additions
. Staff (state
With Current additions] sta"
Staffing Levels required)

for current workers
for_al1_ workers

If 81 or B2 are Ko, please explain why this would not be possible.
Please be specific. for example, interne? doses are not recorded,
internal doses are not readily computed from existing data. .

Current workers, 412 employees are not monitored by in vivo comeiny
exposure and doses, cannot be computed rom arinelysis OovS:

doses cannot be computed from urinalysis dats

Do you calculate & dose equivalent to the erttical organ froo

* deitePnally depostted radionuclides? . _

8.

2.

Yes
—
Tf you do not calculate radiation dose equivalents frow {internal
deposited radionuclides, please describe what data you record
concerning internal exposures and the types of analyses which may

possible to perfors on the data (e.9., record urine excretion 6s:
only, record excretion data and in vitro whole body/organ count «

and estimated organ burdens, ete.).
pecune of deposited suclide decarained frou lung cout is FecSFGel



29. Finally, a meeting was held on February 20, 1986. Mr.
Macaulay wanted the procedures signed off the next day. Again I
stated that the Health & Safety Procedure would be inadequate to
cover all operations in a safe manner that would protect worker
health and safety. This statement received no reply. I then
stated that .I would not sign off on the procedures as they were
written, and walked out of the meeting. Worker health and safety
is important to me, as a worker, and I was helplessly watching
Westinghouse try to rush through procedures that would not do the
job.

30. On February 21, 1986, I realized that I was expected

to sign off on procedures that I considered terribly inadequate.
Rather than risk being placed in this position, I submitted my
application for a promotion and transfer to another department.
This was blocked by my supervisors.

31. At this point, I became sick on Thursday, February 27, and
called Mr. Weichold to say that I was going to a doctor for
tests. I told him that I would be absent for two days. On
Monday, March 3, I called Mr. Weichold to say that I was to be -
tested that day and would not be in. I returned to work on
Tuesday, March 4, and was accused by my supervisors of not

calling in, which was simply untrue.

13

: 3128776


TEER recently completed a study for USA Today newspaper. We would like
to request that our report of this study be made part of the record.

‘This study assessed internal radiation doses of workers at three nuclear
materials processing facilities, two in New York and one in Ohio. The plants
were selected, in part, because they all were privately owned and performed a
variety of uranium processing operations during portions of the 1940s and
1950s. The study was a preliminary and partial evaluation of worker .
exposure. Its purpose was to perform screening-type calculations to ascertain
whether the doses to workers in at least some locations or job categories were
high enough to cause serious health concerns. We used government and
contractor records of workers and workplace conditions. Further details about
the study’s methodology used can be found in the written report.

I will describe 3 of IEER's maim findings:

1) We found that working conditions at these three plants were extremely
poor. Workers were severely overexposed, even for then-prevailing
standards. Based on our screening calculations, doses to many workers are
likely to have exceeded the dose limit which was then about 15 rem per year.
This chart {slide #1] shows the cumulative lung dose per worker as it relates
to the number of months exposed (i.e. on the job), and also to different
muitiples of the then-prevailing Maximum Allowable Concentration (MAC)
of uranium in the air. It shows that the more months a worker was exposed,
the higher the cumulative ling dose, arid the higher the level of uranium in
the workplace air (Le. the higher the number of multiples of MAC), the
higher the dose.

‘The data and our calculations suggest that the highest exposed workers had a
high probability of dying from cancer as a result of the exposure. The
estimated mean lung dose in the highest exposure category (8,400 rem)
would be equivalent to.an effective dose {or “whole body" dose) of.
approximately 1,000 rem. Using the International Council for Radiation
Protection (ICRP) cancer risk factor of 0.04%, this corresponds to about a
40% risk of dying from cancer. This is a 200 percent increase in fatal cancer
tisk compared to unexposed persons.

Other types of health problems, including kidney damage, would also be
likely among those workers exposed to the more soluble fonns of uranium.
We found that the government and the contractors seem to have completely
ignored the air concentration limit established for protecting the kidney from
uranium toxicity — we found no evidence that the contractors followed it, or
that the government enforced it, Plant documents indicate that kidney
damage among workers was in fact reported.

We have arrived at these conclusions even though our dose calculations are
partial and do not cover the entire periods of plant operation and all types of
doses. It also should be noted that the amount of material processed does not
necessarily correspond to individual worker exposure level. In other words,
the plant that processed the smallest amount of uranium did not necessarily


INDEX Section 6. Thorium Processes Plant 6

PE 544a

PE 544b
PE 544c
PE 544e
PE 544i
PE 544j
PE S44k

Sludge Furnace Alterations for Oxidation of Thorium Residue - Plant 6
(1959)

Air Dust Evaluation of Thorium Fumace Operations, Plant 6

Air Dust Evaluation of Thorium Furnace Operations, Plant 6 .(1960) _
Air Dust Re-evaluation. (April,1961)

Thorium Turnings in Syivania. (1963)

Air Dust Re-evaluation. (1963)

Meeting to Discuss Cutting up of Thorium Derbies in Plant 6. (1970)

PE 745ww Monthly Report. [Thorium Furnace Plant 6.]

INDEX Section 7. Plant Operations and Exposures

PE 107b
PE 107c

PE 108b
PE 113¢
PE 114d
PE 117b
PE 118
PE 122
PE 125a
PE 131c
PE 142
PE 145a
PE 145¢
PEI
PE 150b
PE 151-
PE 151a
PE 154
PE 157A
PE 160b
PE 161A
PE 162b
PE I71a
PE 174k
PE 178c
PE 178g
PE 301a
PE 300
PE 304a

Survey of 3620 Operations. [Explosions.]
Report on Overexposures. [Uranium hexafloride/ 100% showed urinary
damage.]

Air Dust Samples - Pilot Plant. [220 MAC.]
Pilot Plant

Pilot Plant. [3% U-235.]

Major Injury #1

Major Injury #3 and #4. {Co-op student.]
Pilot Plant. .
Control of Dust in the Sampling Plant

Ore Handling (Plant 1-Plant 2)

Plant 2

Plant 3

Plant 2

“Plant 3 ©

Dumping Ore Concentrate

Refinery Uranium

High Uranium for Urines - Plants 2 & 3

Plant 4. [70 MAC.]

Justification for CP-58-63

Plant 4

Excerpt from Monthly Report. [200 MAC.]

Plant 4 Reactor Screw. [454 MAC.]

Air Dust Results

Plant 5

Plant 5

Plant 5. (359 MAC.][18,000 MAC.}[97,000 MAC.]
Plant 6

Plant 6. [Fires.]

Plant 6. {.44 MAC in 1957-—-18.94 MAC in 1958.]



RE rr

G24C0
2126829
March 6, 1953

Health Conditions in the Various Plants
3. A. Quigley, M.D.

2. ¢. Seatherton CERTRAL FILES

In line with our conversation of this morning regarding the
in ditions in the various plants, I would like to make some

the prescribed maxizmm levbis should be shut down imne .
As long as there is improvement and @ definite sign that every
effort 18 being made to correct the conditions along with the
production and ‘cechnical requirements, it ids possible that
gontinued operation would be permitted.

Ie such 2 recomendation were to be followed, I think that we

xt d’have to shut down most of the Pilot Plant operations and

the chip furnace at a very early date. In my opinion the
‘Shese areas has shown no inclination toward

improving health snd safety sonditions but are conodntrating
shiefiy on production Be

Yours truly,

R. C, Heatherton
RCHsbg

ect &. F, Biase
: A. Stefanec

— eenanr ent



Jarge numbers of workers have received information about their
radiation exposures which systematically understates their actual
exposures.

Another consequence of the incomplete internal dose records before 1989 is
that in compensation cases involving workers who had internal exposures,

compensation cases is, at this time, an open question, but a reasonable one to
pose.

While it is not possible to give an accurate estimate of the proportion of the
500,000 to 600,000 workers who have worked for the DOE that were at risk
of exposure beyond allowable limits, we note that at the uranium processing
plant in Ohio, commonly called the Fernald Plant, most workers were at tisk
in the early years. In fact, in 1955, the worst year for worker exposure, IEER
estimates that almost 90 percent of workers were exposed to more than the
allowable dose limit of 15 rem to the hing. (See SDA Vol. 5 No. 3.)

There are a number of other direct consequences of seriously incomplete
dose records:

¢ Internal exposures of uranium workers may also have led in some
cases to heavy metal poisoning, notably of the-kidneys..Such cases
could have been better detected had internal dose information been a
part of dose records.

« Improper medical diagnoses may have resulted in some cases because
dose records were incomplete.

" © Corrective measures to improve working conditions were likely
delayed or not implemented in many cases because dose records did
not show overexposures,

The problem was most acute in the period before the mid-to-late 1960s for
two reasons. First, evidence indicates that this was the period when.
workplace conditions were the dirtiest and when workers were at higher risk
of exposure. This observation cannot be used to arrive at conclusions about
specific workers or even specific plants. But to date, most of the evidence we
have examined indicates that for various reasons, exposures were generally
highest in this period.

Second, this period is prior to the availability of counting techniques that
allowed for direct measurement of body burdens. Action levels were set for
radionuclides in urine. So long as the content of specific radionuclides was
below these action levels, body burdens and worker doses were assumed to
be below the maximum allowable limits. After Jung- and body-counters
became available in the early 1960s, there were delays in using them. Even


Limits for allowable exposure have varied over the years, and have generally
tended to decline as evolving knowledge about the cancer risks froni
radiation indicated that the dangers it posed were greater than previously
thought. (See Centerfold article on standards.) In order to ensure that workers
are not overexposed, the most important routes of exposure must be properly
monitored. Consideration must also be given to the fact that ionizing
radiation affects people in various ways.

When only external radiation is involved, measurement of worker dose is
accomplished by the use of film badges, (smal! photographic plates sensitive
to gamma and beta radiation), or thermoluminiscent dosimeters (reusable
devices that measure external gamma radiation — also referred to as TLDs).
These devices can measure how much radiation a worker has been exposed.
to, but not the amount of radiation that may have been taken into the body
through inhalation, ingestion or other means.

body and decay, irradiating nearby tissues. Internal radiation is often more
organ-specific than extemal radiation. If the radionuclides become lodged in
particular parts of the body, such as the lungs or bones, for instance, these
areas are irradiated far more than others. Risk of internal exposure is high in
workplaces where the air becomes contaminated with radioactive materials
or dust, as has frequently occurred in various kinds of uranium processing
plants and in uranium mines. Workers can also be exposed internally through
ingestion of radioactive materials (if the radioactive materials get into the
mouth from the air, for example) or by absorption through wounds or cuts.

Internal exposure is less likely in situations where the radioactive materials
are sealed or separated in some other way from the work environment, such
as in glove boxes. However, if accidents occur in these situations, or if
equipment such as a ventilating system or glove box is not efficient or in
proper working order, then workers could be exposed internally as well.

For almost the entire period of nuclear weapons production, limits have been
imposed on exposure from both internal and external routes. Some current
limits apply to combined extemal and internal exposure, while past limits
have applied specifically to particular organs, such as the lungs. For instance,
the limit for lung exposure until 1958 was 15 rem per year for workers and
off-site populations. It was lowered for off-site populations to 1.5 rem per
year in 1959,

Monitoring Doses

Internal dose is monitored in various ways. One common way is to measure
radionuclide concentrations in urine. If one knows the rates of excretion
corresponding to various body burdens, then is possible to calculate these
body burdens and thereby infer the radiation dose.

Another method is to measure the radiation being emitted by the radionuclide
inside the body. Since a portion of gamma radiation penetrates the body, a


e@ SDA Vol. 6 No. 2

Chronology of External Radiation Exposure
Standards

931-34 Advisory Committee on X-Ray and Radium Protection
‘to the National Council on Radiation Protection and
3) adopts X-ray “tolerance dose" of 0.1 roentgen per

940-41 Aivisoy Committee proposes, bint does not implement,
‘ing the X-ray tolerance dose to 0.02
1942 TU. of Chicago Metallurgical Laboratory adopts a "maxinnum
issible exposure” standard of 0.1 roentgen per day. Becomes
for entire Manhattan Project.
11954 | tomic Energy Commission adopts National Bureau of Standards
dose limit of 5 rem per year. Sets additional limits
internal at 15 rem for most
11959 limit for workers remains 5 rem per year. AEC also adopts
limts for the public equal to one-tenth of those allowed for
: 0.5 rem for external exposure; and 1.5 rem for most
1 rgans for internal exposure."
late [Department of Energy adopts dose limit for the public of 100
1980s - ||millirem (0.1 rem) per year; dose limit for workers remains 5 rem
1990 —_iiper year. A new model for calculation of internal doses to
| piveten is adopted, the “committed effective dose
bain article.)

INOTE: For cciomal radiation sources, roentgen and rem an are considered to
Ibe equivalent.

Sources: 1931-34, 1940-41, and 1942: Barton Hacker, The Dragon's Tail, (Berkeley:
[University of California Press, 1987), Appendix A, pp. 163-64; 1954: US Atomic Energy
i AEC Manual, TN-000-22, Chapter 0522, Vol. 0000, Part 0500, AEC-0522-

52, és :
mmerce, March 20, 1953); 1959: NBS, Maximum Permissible Body Burdens and
laximum Permissible Concentrations of Radionuclides in Air and in Water for
ional Exposure, Handbook 69, (Washington: US Dept. of Commerce, June 5,

\[21, No. 1-3, (Oxford, New York: Pergamon Press, 1991), p. 72, parg. (S25).



Internal evaluations of the plant's operations were initiated in 1985 and they
continued until the plant was shut down in 1989. In early 1985, NLO estimated that
the releases of uranium over the 34-year period from 1951, when parts of the plant
were started up, to 1984 were about 200,000 pounds. The NLO estimate was
increased to 300,000.pounds by 1987 after inclusion of estimates of some of the
most serious emissions during the 1950s, There were a number of evident

deficiencies in these official estimates. Among the more egregious errors were:!

¢ The use of an incorrect formula to calculate scrubber releases under conditions
of variable efficiency.

¢ Inclusion of fabricated data that showed that releases were zero at locations
and times when no measurements were being made.

e A failure to account for poor dust collector efficiency and frequent problems
with dust collector equipment.

« Poor industrial hygiene practices, such as leaving radioactive materials to dry
in trays in doorways, and operating equipment that was in poor condition.

TEER was retained in 1987 by the law firm of Waite, Schneider, Bayless, and
Chesley to do some of the expert studies for the class action lawsuit. IEER's review
of the historical documents showed that plant officials were aware of many of these
deficiencies. For instance, the use of the incorrect formula for scrubber releases was
Pointed out in a 1971 memo by a plant engineer, who called it "inherently. deceptive"
because it resulted in release estimates that grew smaller as the scrubber efficiency
deteriorated -- the opposite of the truth. Figure 2 shows the actual releases of
uranium compared to the NLO estimates for an example in which uranium in the air
going into the scrubber was 100 kilograms.

FIGURE 2: Variation of Efficiency of Airborne.Uranium ||.
Releases from FMPC Scrubbers for an Assumed Inlet

Uranium Loading of 100 Kg*



« B. Franke and K.R. Gumey, Estimates of Lung Burdens for Workers at
the Feed Materials Production Center, Fernaid, Ohio, (Takoma Park,
e Maryland: IRER), July 1994.

« Memo from FJ. Klein to RH. Starkey, “Subject: Cleaning Under
Burnout Oxide Conveyors—Plant 5," National Lead Company of Ohio,

December 7, 1960.

© Science for Democratic Action, volume 5 number 3, October 1996
(Takoma Park, Maryland: IEER)

© Science for Democratic Action, volume 6 number 2, November 1997
(Takoma Park, Maryland: IEER)

QU IEER Home Pase

com: Institute for Energy and Environmental Research

Comments to Outreach Coordinator: icer@ieer.org
Takoma Park, Maryland, USA

September 2000


5.3.6 In Vitro Procedures for Other Radionuclides

The primary bioassay for the first 35 years (1951-1986) of Femald operational
experience was urine analysis for uranium metal.

Even for those special cases, they have been so few in number thatthe review of

Se rae OS8. te Penald site reported internal dose experience to the ABC in
an annual report.

Note: Femald document PE760 is a Questionnaire On Radiation Recordkeeping Systems
At DOE/DOE Contractor Facilities; dated June 29, 1984, to Battelle-Northwest
Laboratory. _It includes the following responses about current worker: “AlLemplosees

Te a ceideets inci terort ‘Mortality Among a Cohort of White Male Workers a
a Uranium Processing Plant: Fernald Feed Materials Production Center, 1951-1989, a
study was conducted at the Center for Epidemiologic Research, Oak Ridge Institute for
Science and Education. (From pg6 of that report) ‘ Intemal exposure monitoring for
radiation first began with a urinalysis program in 1952. Workers were monitored on a
non routine basis as 2 control measure and by 1958 urinalysis became a primary means of

internal monitoring.
[The above statement has been misinterpreted in the TBD and does not substantiate the
ORAU team dose reconstructors claim that the Fernald site reported internal dose

_ experience.]

Note: Notation under Table5-23 states: *Various annual reports reported the units in
mgL, which is an obvious typographical error. The permissible urine concentration,
averaged throughout the year, was 0.05mgL

fis it possible that the report was correct, but because it didn’t fit the ORAU
assumptions it was rejected?]

5.3.7 In Vivo Analysis
Lung counting became available in 1968 in the form of a mobile lab.

Thorium-230 is not readily detectable by in vivo measurements. There appeared
CR

pe35 Te workers, who had known exposes to high ir concentvations, had
high urine results or were involved in an incident, were counted on first priority each time
the MIVRML visited the site. Other workers were counted based upon their job exposure
potentials.
Note: Because Femald chose to monitor exposure based on job classification, does not
give validity to the dose reconstructors to assume that because a person was not
monitored more frequently their exposure potential was less.


ae William T. Doran, bi. D. - rage 2
Weovember I, 1962

e When the air dust ceacentration for a job resulta in exposures above a costrol .
° Level, we require the use of & respirator to perform the job. Thus the deter-
muination of the intersel exposure-becomes further compliceted since we can

be sure of how mach of the airberne dust is g removed from the air

which is breathed.
Another serious problem in determining internal exposure is the difficulty ix
work re: which show how long an individual bas worked |

fn various jobs. Five of the jobs in the table are performed by employees .
with the job classification of “chemical operator. “ The other two are class-
ified “chemical operator helper” and "laborer." We have records which teil
tae to which plant a pereon is assigned end in which job classification he worked)
however, these records do not tell us the specific job operation he performed.
It is obvious from the table that all chamical operators in our metal production
plant will not receive the same exposure to airborne uranium. .

We use wrinary uranium excretion information along with air survey information
to be sure that we are controlling sirborne exposures to amounts that will not be ———_
re n uranium excretion

moethods is leas precise that ere estimations of exposure to external radiation.

@ We have wrestled with this problem of estimating internal exposure in the
course of our Epidemiological Study of Uranium Workers here and at Mallin-
ckrodt. It is my personal opinion, however, that because of the wearing of
dust or airline respirators, the expesure to airborne radioactive material
and hence internal emitters has not been in serious prepertions ‘either here
or at Mallinckrodt, Our urinary uranium excretion records substantiate this
I will be happy=-and I believe Mz. Mason will be also--to further discuss with

you and your study committee the problems we have encountered and the experi-
‘ence we have gained in connection with estimating interval exposure.

Sincerely your, ©

JAQ/ mb Director of Health & Safety

ee: ©. L. Dunham, MM, D.
c. L. Karl lx
J. H. Noyes, iz

@ sisisos


6018," National Lead Company of Ohio September 10, 1968, p. 1

4, Memo from J.A, Quigley to C. Dees, National Lead Company of Ohio, October 12, 1953,
3

P.

Cc Institete for Energy and Environmental Research

Conaments to: C=3"} outreach Coordinator: ieen@ieer.org
Takoma Park, Maryland, USA

March, 1997


E.3

E4

ES

Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees. Centers for Disease Control and Prevention
1 sat National institute for Occupational Safety and Health

‘OMB Number. 0820-0639 Expires: O5/3112007

Name of DOE or AWE Facllity:
Locations at the Facility relevant to this petition:

ALL hocechions

st Job titles andior Job duties of employees Included in the ass. In addition, you can IIst by
any individuals other than petitioners identified on this form who you believe should be

included In this clans All Employees 4
All Suh-Contractors

Employment Dates relevant to this petition:

Stat 195) End thrp 1989
Start End

Start End

ts the petition based on one or more unmonito! unrecorded, or inadequately monitored or
recorded exposure incidents?: 0 Yes No

if yes, provide the date(s) of the Incident{s) and a complete description (aitach additional pages
as necessary):

Go to Part F.

Name or Social Security Number of First Petitioner. . _


NOz Fume Releases Page =
gu8y, ¥

received significant NOs exposures while working on the

Filser Feed Tanks. Granted, we are taking corrective
measures in this building; out unless more adecquaze commut:-
cations are set up, I'm afreid wetre going to seriousiy injure
someone before the corrections can be made.

The NO, and dust releases mentioned in reference ietser No. +

have b&en numerous. The ventilation system is entirely in-

adequate to handle the Metal Dissolver and the digestion

operation in P2E~-11. I have recommended both verbally, and

finelly in writing, to L. M. Levy that this operation be

ceased. Lou had agreed with R. C. Heatherton snd me chat he
ld pursue another means of processing this materiai. Io

3 no indi: that he has done so.

The Harshaw system has not been operating since approximately
January 8. During the ensuing period the Digestion pots have
had to be vented to the Nitric Acid Absorber system. This has
resulted in a greatly reduced ventilation on the digesters and
subsequently numerous dust and NO. releases, especially in the
Slag Leach system. The low air flow in itself causes releases
and in addition causes the vent ducts to become plugged because
of the low carrying velocity. Dust and NO, were reieased
virtually conscvanciy from the Slag ieach system while material
was being fed into a digester for a period of approximately
two weeks. This was brought to the attention of virtually
every Refinery supervisor including L. M. Levy, who was notified
by phone of the problem by K. N. Ross on February 13, 1966.
Finally, on February 19, 1968 the vent ducts were dropped and
cleaned ont. The operator told me chat the one section was
rtually completely plugged. After cleaning, some smali
fuming was occurring but not nearly ea much as prior to
cleaning the duct. I understood the Harshaw syscem is vo be
scheduled to go back on stream some time the week of February
26 or approximately seven weeks efter it went down. This :
iong deiay may have been absolutely necessary, but discussions

pave bad with Rient 2 supervisors indicate.. thom.
pedori ey had been given that we could have hed the Barshaw
system back operation sooner.

i stated in the answer to the ORO review that "the NLO
Engineering Division hes given the Refinery fume removal
problem top priority." Of prime concern was the Digester
vent systems. We had been attempting to get something moving
on solving this problem for months prior to the ORO review.
Finally, efter an extended period of "no progress,” you and
i brought the problem to the attention of 8S. F. audia and

2229675,


NATIONAL LEAD COMPANY OF OHIO: 7

CINCINNATI, CHO 45239

February 23, 1968

SUBJECT REPINERY NOg FUME RELEASES
10 3. A. Quighey, M.D.

FROM

R. HE. Starkey

REFERENCE 1) Letter, R. E. Starkey to L. M. levy, dated 2/21/66, Sumaing

into P2E-1l Tank - Metal Dissolver Building.

2) Letcer, R. H. Starkey and 5. A. Mode to J. A. Quigiey, M.3.
and P, G. DeFazio, dated 1/15/68, Plant 2 Hot Sida ofl-

Ventilation Tests.

I sm becoming increasingly concerned with the lack of progress
being made with the control of oxides of nitrogen fumes in che
Refinery. As you recall, the Oak Ridge inspectors were cuite
concerned with the number and severity of the fume releases <n
the Refinery during their review last October. Also, as you
recall, we assured the AEC that 3 ive 29D
priority from our Engineering Division. Subsequentiy, i
a@cail from F. E. Coffman, ORO Safety Division, concerning our
progress in correcting the conditions which were resulting >
fume releases. Apia. btis abe to-patisei big, net wo wi
making progress. J am no longer st com ; that this is
the core In fact, Itm quite concerned that we may be regress-=g
overa. .

Daring December 1967 Refinery supervision recorded|
Which required thet portions of the plant be evac ° s
January there were only two recorded releases and so far only one
release has been recorded this month.

Having visited the Refinery many ‘times during the past thrée

months, I have a feeling that the releases erentt getting any
jess; the personnel ere just bec more used to the fuming.
“Tdmittedly, most of the releases were not large enough to evacuate
the building; but the number of lesser releases were great.

As a besis for my concern, Itd like to delineate a fow areas in
ich I feel that we have regressed. They are:

2. Since December 13, 1967, we have had two instances in the
Hot Raffinate Building where Mechanical personnel have

A Paiwee COMTMACTOR FOR THE U.S. ATOMIC ERERGY COMMISSION

SOERET4

PEIW44,

2611905


a eT
. CaS vasyer
CENTRAL FES. 7, \s

Pas

F

” NATIONAL LEAD COMPANY
. 2154290

OF OHIO
April 5, 1963

SUBJECT: CHANGES IN TERMINOLOGY, ABSORPTION FACTOR AND AIRBORNE ALPHA
ACPIVITY LIMIT
TOs J. H. Noyes

FROM: J. A. Quigley, M.D.

As was approved by M. S. Neilson on March 28, changes have
deen made in 1) terminology pertaining to radiation dose
an@ air and waterborne concentrations, 2) absorption factor
used in counting air dust samples and 3) levels previously
called MAC but now called NCG.

The terminology relative to levels of external radiation is
being changed from "Maximum Permissible Dose (upp)" to
"Radiation Protection Guide (RPG)." This change is in
compliance with the recommendation made ‘by the Federal

Bagiaiion-Gouncil (rac)* for the use of Federal Agencies. |
The FRC defines the RPG as “the radiation dose which should
ot be exceeded without careful consideration of the reasons
Pee doing so; every effort should be made to eneourage the ”
maintenance of radiation doses as far below this guide as

practicable." The numbers quoted for external radiation
exposure are in accord with our present limits.

The terminology relative to concentrations of radioactive
contaminants in air and in liquids is also being changed

from "Maximum Allowable Concentration (MAC)" and "Maximum
Permissible Concentration (MPC)” respectively to "National
Lead Company of Ohio Concentration Guide (NCG)" for both.
We do not propose adoption of the FRC term "Radioactivity

defin his term is defined as the concentration of
radioactivity in the environment which is determined to
result in whole boay or organ doses equal to the Radiation
Protection Guide.

In general, the reason for these changes in terminology is
to avoid the erroneous connotation that is placed on our
old terminology. ‘The use of the word "maximum," in the
above sense, is interpreted by many to imply that a level
that exceeds this point by any amount for any period of

6188558

lyederal Register ~ Page 402 dated 5/18/60.



INTRODUCTION
This questionnaire relates to recordkeeping systems at DOE/DGE contrac:
facilities. The records of interest are these of lifetioe radiation exposur

(doses) to workers. The major question to be answered by this qubstionnaire
: ide an accumulative lifetine radiation dese

. 4s& Do you have the datz to prov

for every worker at your facility for both internal and external exposures,
and 1f so, how much effort will be required to provide those estimates. A
secondary but very dmportant question is, 4f you do not have the data, what
data are missing? - oe

The impetus for this is to determine the impact of various schemes. to
compensate radiation workers who develop cancer. These schemes are based oc:
attributable risk tables which purport to state the probability that & give:
cancer was caused by radiation. The attributable risk tables are broken do
by organ, sex, age at exposure, dose received, and latency period. In orde
to judge the impact of these attributable risk tables, it 1s necessary that
DOE/DOE contractor facilities be able to analyze the radiation doses receiv
by workers in the same categories as contained inthe tables. .--- --~-

This questionnaire should be fiTied out by the faciT4ty which has resp
ibility for keeping radiation exposure records. Piease be as complete as
possible in that the purpose ‘cf this questionnaire: is, in part, to deterwir
the ability of current systems to provide the requested data and the costs
necessary to upgrade the current systess. If your radiation worker records
system has been documented qn any form or described either in internal
documents or publications, please provide copies of those documents.

In order to prevent double counting of records systems, this question:
naire should be completed only by those DOE/DOE contractor facilities whic:
are responsibte for records. -

Questions of a technical nature should be directed to Richard J. Trau
FTS (509) 375-6851.

0036455


pg21 Some records have been recovered that indicate that basic air activity levels
were recorded in fractional MAC for thorium processing.
camp ee te a et Oe Mat eelaakeeeed ieee

processing of umnium, ‘The practices of wearing respiratory protection preventively for
cpoatons Known t produce dusty cndidons were sdminsteed fr ura operations

See ode eines oe amoptitg earned te ecm internal exposure vaing
continuous lapel air samples as breathing zone (BZ) evaluations. From that time until the
present air monitoring is used to conservatively estimate internal intake even when the
worker wore respiratory protection.

The data from the report (Dolan 1988) indicates that just the Pilot Plant, Plant8,
and Plant? processed thorium, A single air sampling data sheet was found that indicated

ant 4 during which there were air activity

Based on evaluation of the available information, dose reconstructors should
assume thorium exposure for any employee whose records establish work, and therefore
exposure potential, primarily in the Pilot Plant from 1964 1979, in Plant.9 in 1954 or
1955, or-in Plant 8 in 1966, 1969,-1970, or 1971.

Note: [How is it claimant favorable to ignore a documented exposure?]

There is some evidence of urine analyses for thorium in claimant files as early as
1955, but to date n mat x 2



pgli An additional radiological concem at several locations At FEMP occurred
‘when workers were subjected to high level of radioactive material-bearing dost So at

Note: What irony! [If dust could effect the dosimeter, what assurance is there that they
would provide an accurate reading?]

There is a discrepancy as to when the ORNL dosimeter was firts used 1953 or
1971, and TDLs were introduced around 1978 or 1979.

ses depend not only on the response of the specific
dosie  e n te Ont csoed cok calvooted, tat ven the decane
geometry, how itis wom, and the simple variables in shiciding afforded by clothing and

primarily beta or low energy ghotons, both of which are predominant with uraniom.

6.3.3.2 FEMP Beta/Photon Dosimeters

-Dosimeters were originally calibrated using 226RA for gamma energy and
uranium for beta and low energy photons.

The use of mrep unit is somewhat unique to FEMP because it declined in use after
the 1950s. (This TBD assumes that a rep is approximately 93ergs/g of tissue.)

6.3.4 Workplace Beta/Photon Radiation Fields.

‘Fhe radiation fields consist of a-complex mixture of beta, x-rays and gamma -
energies. These were supplemented by higher energy gamma radiation associated with
226RA transitions that account for the dose rates associated with the K-65 silos.

63.44 FEMP Beta/Photon Response

NLO skin dose results were usually high but satisfactory.
pgl4 After these tests, NLO conducted several projects to improve it ability to
determine incident beta energies.

6.3.4.2 FEMP Beta/Gamma Response

The processing of the metal resulted in separation of uranium daughter products,
which produced much higher rates in portions of the product, process equipment and by
products.


Nete: I thought the stomach and intestines were in the GI tract, not the bladder. Unless
they are referring to the non-soluble uranium particles that are ingested. These may
‘become imbedded in soft tissue and may not be passed.

Other elements of the protection program include routine monitoring of the
workplace and personnel for radiation and contamination, personnel protection in the
form of protective clothing and respiratory protection in all of the operational areas as
needed, and restricting workers from workplaces with elevated airbome radioactivity
concentrations when the level of uranium in the urine or in vivo counting results exceeded
specified plant action limits.

5.3.2. Air Monitoring Program

Routine air samples were taken in every plant and operational area. This program
was the primary means of controlling intakes.

In the 1960s the samples were counted for both alpha and beta activity.

Workers were directed to use respiratory protection in the form of dust masks or
supplied respirators depending on the anticipated or measured airbome radioactivity

pg30 From 1953 to 1986, the air monitoring program was conducted as a primary
control element. Howevet, the measured ait concentration levels from the routine

5.3.3 Bioassay Program
The initial study was based solely on heavy-metal toxicology limits for kidney

ps3! (notation under Table 5-19) MDA is-accepted as the most reliable
representation for historical MDAs for this analytical procedure.

5.3.4 Environmental Levels and Fecal Sampling
The value of fecal samples was recognized even in the early years and has been
Weil understood since 1986. Several samples are recorded as part ofa study in 1968.

Fecal sampling ¢ can provide useful information, perticularly j
soluble compounds (types M&S)

5.3.5 Analytical Program
MDA (MDL) was not formally established in the early periods (as evidenced by a
record search). Jo addition, the lange ftuctuation in uranium in the diet af



8, LIFETIME DATA, INTERNAL EXPOSURES

aa

“rE

The purpose of this section 1s to determine whether sufficient data ex-
to estimate the cumulative exposures to bedy organs from internal
exposures. interest is whether the facility can provide estimates
dose equivalent. This requirement 4s over and above knowledge of
ceeretion rates or radioactive content of the body. ae

1. Can your factlity provide the lifetime or annual internal radiatic
exposure data for a1] your currently employed workers, by individ:
{i.e., are the data available)?

Yes {also see questions 82, 63, 84, 85, B7 and following)

No (atso see questions, BZ. 86 and following) an opleyens

2. Can. yourfactlity provide the lifetiae cumulative internal radiatt:
for all workers who have been employed et your facility

exposure
date of termination)?
Yes (also see questions 83, B4, 85, 87 and following)

x Ne (also see questions BE"End following) sl) eaplovess ares
monitored for intarnal exposure: see anm

3. If the above answer 1s yes, what data are recorded?

I

Integrated air concentrations
Bioassay results (urine or fecal analysis)

Whole body count results

Evaluation of mathematical models to estimate depositicn

Caleylated internal dose

MILT ttt

Other (please explain).

4. If Yes, what. level of effort would be required to obtain this
jafermation? If costs are predominately computer costs, please
indicate this fact and provide an estimate of cost. If costs ar
predominantely due to staff labor, please indicate the estimate
senehours to complete.

0036459


Note: A policy is a false indicator of actual practices. Fernald document PE330B
describes one such respirator as the ‘epitome of filth.’ and that it would have been a
perfect fomite for the transfer of respiratory infections between employees.

Additional Fernald documents describe piles of scrap materials surrounding equipment in
the work areas. Rags stuffed into equipment in an attempt to limit dust emissions, and
push brooms being used to clean the floor. [Good housekeeping may have been the
policy, but it wasn’t the practice.}

In 2000 a FEMP team working on the DOE Ohio Field Office Recycle Uranium
Project Report (DOE 2000) qualitatively rated various plant processes in relation to the
potential for prodncing airbome dust in categories. This report was consistent with
historic FEMP air activity measurements and recorded intemal exposures.

Table 5-5 Fernald plant processes, materials and dust release potential.

Note: Plant 6 dust release potential was not included in this evaluation. This TBD stated
early on that metal fires were common, resulting in airborne uranium concentrations. A

Femald document identifies the smoke as U308 airborne particles.

[How can a dose reconstruction be reasonably accurate when the exposure potential data
is not inclusive for all production areas?]

5.2.1.4 Chemical Toxicity. The early basis for conducting routine urine analysis
en’ to somue the uratiumn expome conietls wete wiegaste to present chesninal inxiciy.

Note: Fernald document PE901, dated Nov.1,1963 states “We use urinary uranium
excretion information along with air survey information to be sure that we are controlling
airborne exposures to amounts that will nt be harmful. ‘We do not consider the urinary.

or exposure, “We have assumed that the determination of intemal exposure by any
method or combination of methods is less precise than are estimations of exposure to
external radiation.

$.2.2 Recycled Uranium (RU) Processes were introduced to Fernald in
Feb.,1961.

Plant 1 and other locations were protected with airline respirator equipment
particularly for the 1976 shipment of tower ashes from the PGDP.

Reference indicates that the internal dose technology, techniques, procedures, and
philosophy similar to ¥-12’s were used at Fernald.



23. Plutonium-bearing materials containing more than lo parts
per billion (PPB) require special handling, including the use of
protective equipment, respirators, constant air monitoring,
routine worker exposure analysis and strict adherence to quality
assurance/quality control procedures. In 1982, Fernald had

processed plutonium-bearing materials of up to 7,757

parts per billion without observing any safeguards. The

September 1985 DOE investigation was highly critical of this

practice.

24. Against this background, Westinghouse was planning to pro~-

¢ess more of this material in response to pressure from

Production.

25. on February 7, 1986, I was assigned to develop procedures
for the plutonium program. The assignment was to upgrade
procedures. At a meeting on February 10, 1986, Mr. Weichold and
I-were told to-write two new procedures and revise six others.°
Health and Safety was given the responsibility of writing a
special procedure that would include information on all health
and safety aspects of the operations. I stated at the time that
other procedures were involved. I was told by Mr. Macaulay,
Westinghouse Operations Training Manager, te stick with the
eight. Two days later, February 12, management decided to add

four more procedures.

11

3128774


* RATIONAL LEAD COMPANY
OF O8IO

TEPLE: STANDARD OPERATING TROCEDURE FOR THE COLLECTION OF
. \TR DUST 3.4PLSS
AUTHOR: X- Z. Ross
DATE: December 23, 1960
SCOPE: Tris SOP covers the methods to be follewed for the
. rolieetion of air cust samples.
PURPCSE: 1, To determine the air dust exposures of individuals

or groups of individuals in the performance of
specific jobs sad while is the general vicinity
of seurces of airborne material.

2. To determine the sources of air dust.

3. To supply information that will aid in preparing
specific recommendations designed to mininize
personnel exposures. . .

working specifications for air survey work include the
collection of samples according to standard methods as
outlined in this procedure, making use of equipment,
rates, and times preseribed so as to meke possible
reproducible results. .

SOMDEYIONS REQUIRING SPECIAL PRECAVEIOMS:

1. Fire and Safety ; .
{a} ‘There are areas where explosions aay occur. Pusps with
explosioh-~procf motors or other equipment are seeded for
survey work in these areas.

shall practice good safety techniques and
‘ali safety rules whenever collecting samples.

(d) .

2.

{>} ‘Hhe surveyor is expected td comply with any posted radiation
Signs and time lindta or other pertinent Health & Safety
vision recommendations in the area he is sampling.

4



Health and Environmental Impacts
of Nuclear Weapons Production

This issue of the newsletter has three articles on health and environmental impacts of nuclear
apons production: 9} a general overview of how health and dose reconstruction studies are }j

a arding radiation exposure and health risk to its

bors; and iii) a case study of worker exposure at the Fernald plant

\We will continue this series in future newsletters. Note that these evaluations only address
jesposures for the period when nuclear weapons plants were operating. They do not include

Radioactivity in the Fernald Neighborhood
By: Arjun Makhijani

The Department-of Energy's Feed Materials-Production Center (also called the
Fernald plant), located near Fernald, Ohio, produced uranium metal mainly for use
in plutonium production at the Savannah River Site in South Carolina and at
Hanford in Washington state. The plant was operated by National Lead of Ohio
(NLO) from 1951 through 1985. In 1986 it was taken over by Westinghouse. NLO
had a number of subcontractors, (the Alba Craft plant in Oxford, Ohio, for example),
who performed a variety of tasks such as machining of uranium metal. The Femald
plant closed in 1989, and the site now has a new name: the Fernald Environmental
Restoration Management Corporation (FERMCO). It is currently being remediated
by the DOE contractor, Fluor Daniel.

- The Fernald plant consisted of 10 production operations (called "plants") as well as.
other support buildings. In these facilities, uranium in various forms, including ore
concentrates, scrap, and recycled material containing uranium were processed to
produce uranium metal. The six waste pits at the site contain both radioactive and
non-radioactive chemicals, including uranium isotopes, thorium-230 (a waste
material from the uranium production process), thorium-232, and barium salts. In
addition, the K-65 silos located on the site contain radium-226, a decay product of
uranium which emits radon (see centerfold). Figure 1 shows a schematic diagram of



SEC Petition

Office Of Compensation Analysis and Support
NIOSH

4627 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Attention: SEC Review Board

respectfully submit this petition on behalf of the Fernald workers; the living, the
deceased and their families.

I believe that NIOSH was not able to determine with reasonable accuracy the
radiation doses incurred by the workers at Fernald. Based on insufficient accurate
information, they were unable to estimate the maximum radiation dose that could have
been incurred by any member of this class.

Documents indicate there was no monitoring for specific types of ionizing
radiation known to be present. The monitoring was limited in frequency and to limited
groups of workers, The monitoring was inaccurate die to sampling techniques and
dosimeter limitations. Some data could not be interpreted due to deficiencies in the
record keeping procedures. Worker assignments often changed as they were rotated to
different locations in an attempt to limit exposure levels.

Dose reconstructors believed ‘Good housekeeping’ practices were followed at the
site. This misconception and limited data resulted in imaccurate default assumptions.
Data-was reconstructed forthe thorium processes because the records had been destroyed
in 1970, but it lacks validity due to gross error.

Therefore, I believe it is not feasible to estimate with sufficient accuracy the

radiation dose that the workers at Fernald received and that those radiation doses
endangered the health of those workers, and possibly their families.

Respectfully submitted,


ee P. & SOx IS cacpean, 060 4it

oe. .
owoes: AREA COOE: 213-720-008
e JUN 29 BBE : 2317020
Dr. Richard J. fraud
Bactelle-nertiwest Laboratory
Box 999
Richland, Washington 99352
Dear Dr. Traub:
QUESTIONNAIRE CH RADIATION FECORDRZERING SESTINS RE DOE/DOE COMTEACTOR
PACILITIES
Rett Latear, H.R. Theisen to BM. Spenceley, “Rediacion Exposure Recoris,
eared Sune 12, 1984
cur completed copy of the subject is attached. Also attached’
are responses to previous regarding cur employes radiation
monitoring program which contain infersetion about radiatien recordkeeping
systems.
Sinserely yours,
Co .
: Origin! Signed By
e RM. SPENCELEY
, ey
naneger
TAD/VvS
actcach.
ce: “A.W. Doneck
2. A. Dugan
W. 3. Grannen
3. L. Minnafela .
Ss. Rk. martin
a. a. Schneider
%. R. Theisen
R 8. Veideer
c& 3. Randel
Central Piles
G. ¢. Smith

a cemq cowreacron yee Tet SEPantuent oF Extues



e SDA Vol. 5No.3
, Fernald Workers' Radiation Exposure’

By: Arjun Makhijani

Like workers at other nuclear weapons plants, workers at the Feed Materials Production
Center near Fernald, Ohio (commonly called the Fernald plant) were routinely assured that
they were being protected and that, in general, their exposures to radiation were under the
maximum legal allowable limits. These assurances, given by the Department of Energy and
its contractors, have been based on records of worker doses. A careful analysis of Fernald
plant data indicates that these claims are incorrect.

Three categories of radiation data were collected for workers at Fernald:

1. Direct measurements of worker external radiation doses. (Collected using film badges
worn by workers, for instance.)

2. Measurements of radioactive materials inside workers’ bodies, The methods included
analyzing urine samples and measuring gemma radiation emanating from
radionuclides trapped in workers' lungs (called "lung counting").

3. Measurements of radioactivity in the workplace environment. These are made by

e@ sampling the air in the general area where the work is done and in the "breathing
zones" close to workers’ faces.

The third category is not a direct measurement of dose but provides an'indication of working
conditions leading to exposure. Standards are set limiting the concentrations of radionuclides
in the air so that the radiation doses to workers might be kept below allowable maximum
limits. EER performed an independent assessment of radiation exposure to workers as part
of a class action lawsuit filed by the plant's workers against National Lead of Ohio, DOE's
contractor until 1985.

Working conditions at the Fernald uranium processing plant near Cincinnati were appalling,
especially in the 1950s and early 1960s. They were typified by high air concentrations of
uranium in many areas of the plant which often exceeded the Maximum Allowable
Concentration (MAC) by tens of times, hundreds of times, and even thousands of times. One
1960 plant document lists the air dust concentration in the breathing zone of an operator
cleaning under a burnout conveyor as 97,060 times the MAC.?

Work procedures also contributed to the high air dust concentrations in the plants. For
example, a 1968 plant document described the procedure for emptying @ dust collector:

The dust is emptied from the coflector on the second floor and falls down a chute to a
nonventilated drum on the first floor. The operator on the first floor signals to the operator on
the second floor that the drum is full by pounding on a metal beam with a hammer. Because of
the noisy conditions prevalent in the plant. the second floor operator does not always hear the
e signal. This results in an overflowing dram of dusty material causing a cloud of radioactive dust
to fill the area which also goes up the stairwell into the second floor.>


a

Percent of Wokers with an Inferred
Annual, Average Uranium Lung Burden
Corresponding to a Lung Dose of 15 Rem}
or More.

68824 8 8

8 8

r-)

2

|Source:B. Franke and K.R. , "Estimates of Lung Burdens for Workers at the Feed Materials
[Production Center, Fernald, Ohio," (Takoma Park: IEER, 1994), p. 8,

The presence of large and variable amounts of radon during lung counting appears to have
created measurement errors in the records of many workers. Fernald's procedure for lung
counting included measurement of subtraction of ambient external radiation readings,
including radiation from radon and its decay products. However, differences in radon levels
between the time that background measurements were téken and the time that the lung
counting was done could mean that the actual tung burden may have been higher or lower
than reported. Such fluctuations would tend to cancel out in population dose estimates, such
as the ones that IEER made, -which are presented in this article. Further, the result of - -
subtracting high background readings resulted in many negative estimates of lung burden,
which must necessarily be rejected as false, as well as a large number of low values below 5
milligrams, which IEER considered to be too unreliable to use. IRER's work took these
statistical problems in lung count data into account by omitting all lung burden estimates
below 5 milligrams. Worker doses from radon and its decay products would be in addition to
those from uranium hing burdens discussed above. These remain to be estimated.

External exposures

In general, external exposures were also not carefully monitored at the Fernald plant. For
instance, there was a high potential for some workers to experience significant external
exposures, especially to their hands. Hand exposures were not calculated at all until 1970,
when some workers began to wear wrist dosimeters. In many cases, external dose records
indicate readings of zero. Without further records and investigation, its is not possible to
assess whether these meant that there was no significant reading above background, whether
there were other problems with the data, or even whether some of the data were fabricated
(@s was the case with some of the uranium release data).


One example of the problems of the extemal radiation dose record dates from the early
1980s, when thermoluminiscent dosimeters (TLDs) were introduced in place of film badges.
Contamination of the TLDs by uranium prevented accurate readings and so a “correction
factor’ was introduced to the raw dose reading. However, NLO used the same correction
factor for all workers regardless of the working conditions and duration of exposure during
the month. The result was that some workers were, after “correction,” estimated to have
negative radiation doses. These records were apparently referred to the Health Physics
section for further action, but it is still not known what was done with the estimates. One
possible outcome is that a zero was entered into the dose record.

Concluding observations

Just after the presentation of IEER's findings in court in 1994, the DOE settled the lawsuit on
bebalf of NLO, providing workers with lifetime medical monitoring, and other benefits. But
the DOE has still not acknowledged that worker dose records are severely flawed and
incomplete. So far as IEER has been able to determine, DOE and its contractors still
routinely fail to inchide estimates of internal doses in worker dose records. Therefore, in the
nuclear weapons plants were workers have been exposed to conditions that might cause
intemal exposures, the dose records would be systematically incomplete and underestimate
worker exposure.

In many epidemiological studies, or at least in some cases, the general assumption that film
badge data are a useful proxy for actual total exposure may not be valid. Inaccurate external
dose records, lack of dose records for many high internal exposures, and the highly variable
conditions of uranium dust to which workers were exposed make film badge data suspect.
Finally, worker records contain almost no information about exposures to non-radioactive
toxic materials, such as acids, metals, and solvents, which are routinely used in large
quantities,

Nuclear weapons production in the U.S. has involved 600,000 workers, many of whom.
worked in uranium and plutonium processing facilities, where there were risks of internal
exposures. Identifying those most at risk by estimating internal exposures is a matter of

’ elementary justice arid health protection. Efforts must also begin to find groups at high risk
due to chemical exposure. Such evaluations can lead to identifying high risk worker groups.
Medical monitoring may provide early detection for such workers who may otherwise not
suspect that they are at risk until it is too late for them.

Return to SDA Vol. 5 No. 3 Main Menu.
Return to SDA Main Menu.
Return to IEER Homepage.

ENDNOTES
1, This article is based on the following IEER report: Bernd Franke and Kevin Gurney.

Estimates of Lung Burdens for Workers at the Feed Materials Production Center, Fernald,
Ohio, (Takoma Park: Institute for Energy and Eavironmental Research, 1994).

2. Memo from FJ. Klein to RH. Starkey, "Subject: Cleaning Under Bumout Oxide
Conveyors - Plant 5,” National Lead Company of Ohio, December 7, 1960, p. 2

3. Memo from C. W. Zimber to Leininger, “Subject: Employing Rotex Dust Collector No,


TO
FROM
REFERENCE
ure
a .
ee vate

"$ NATIONAL LEAD COMPANY
- a ; OF Onto
J P.0, BOX 158
MT. HEALTHY STATION Zq’ cal
CINCINNAT! 31. OHIO i¢

explo and bis immediete superio:
aost coat Bis imeing a work history in regeré to
this mants activities.

ts in the roving saintenance crew and the
period from . — worked on the
cleaning out the flourze adjacent to the °) °
afte: gan was tran to the first


3. When I first reported to work at Fernald in May, 1984, I
observed several serious problems. The facility was antiquated
and in poor condition. . The building in which I worked, the
Laboratory Building, was contaminated with uranium dust from
personnel tracking it into and throughout the building.
Contaminated shoes and clothing were strung throughout the
corridors and even placed on benches that were used for coffee
breaks. A layer of radioactive dust also covered the cabinets,

shelves, and horizontal surfaces throughout the building.

ae In the operation buildings, I found layers of uranium dust;
magnesium fluoride, green salt, orange oxide and uranium saw
chips covered the floors to a level of one-quarter inch thick.
At times, the air was so full of uranium dust I had trouble
breathing, and afterwards, I got a sore throat. Respirators and

masks were not being worn by personnel.

5. But the main problem I encountered from Day One was in the
Quality Assurance Department where I worked. The Quality
Assurance function at these DOE plants is particularly

important, since DOE contractors are essentially self-regulated.
The quality assurance function is supposed to identify problems
and assure that corrective actions are taken. Quality Assurance
also plays a significant role in preventing future accidents by

analyzing root causes of problems.

3128766


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Contro! and Prevention
Hines Compensation Act

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 6 of 7)

FS We have attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitaffons might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technica! implementation
guidelines.

{Attach report to the back of the petition form.)

F.4 0 UWe have attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
‘Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
Journal, that identifies dosimetry and related information that are unavaiiabie (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

(Attach report to the back of the petition form.)
: ; ‘ to Part G.

Signature
Signature Date
Signature Date

Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of

fact or any other act of fraud to obtain compensation as provided under EEQICPA or who
knowingly accepts compensation to which that person is not entitied is subject to civil or
administrative remedies as weil as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by.a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true.

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

eens nae
if there are additional petitioners, they must complete the Appendix Forms for additional petitioners.
The Appendix forms are located at the end of this document.

Name or Social Security Number of First Petitioner: .


a ‘Special Exposure Cohort Petition U.S. Department of Health and Human Services
Seta Cnekgy epkopane ecupeaorad Centers for Disease Contro! and Prevention
Imess Compensation Act

National institute for Occupational Safety and Health

‘Complete at feast one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.4 3x We have attached either documents or statements provided by affidavit that Indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area
monitoring.

(Attach documents and/or affidavits to the back of the petition form.)
Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored.

Sao Satna,

F.2 U We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit{s) indicate that radiation monitoring records for members of the
ue ° ropésed class havé been lost, alteréd illegatfy, or destroyed.

See Continuation Page

Part F is continued on the following page.

Name or Social Security Number of First Petitioner: _


pocfoen oe tstinuts cabetion, The dose ca 1
nl sae pons ftir, bat cal open nienl inat

"Barly in 1989 an in vivo counting facility was constructed on the Fernald site to
pale nly ann

Note: Fernald documents PE901 and PE760 state that their urine records can’t be used to
[Dose reconstructors attempted to use those records for that very purpose.]

Tang monitoring began in 1968 with the MEVRML and continued in 1989 with
the Fernald IVEC counting facility until 2001. NoR i e reportec
analysis before 1989,

pening fers hy met

ofthe processes,

ica R are not known, although it is apparent
from the chemical roseocs to which the materials were subjected dteing want
processing, a variety of forms would be expected. Hence the dose reconstructor should
assume the most claimant favorable solubility type for the target organ.

5.2.3 Thorium Processes. A comprehensive effort to reconstruct the effluent of
pear an thorium from Fernald plants in 1988



Cohort Petitio US. Departinont of Health and Human Services
Docupational Centers for Disease Control and Prevention

{Spectal Exposure Cohort Petition — roms
Fl

The ORAU TBD for dose reconstruction at FEMP, identified the following areas
in which monitoring was not available to Fernald workers:

*No monitoring for internal exposure for Ru contaminants, “No smears or air sampling
filters were analyzed specifically for: Piutoniam, Neptunium or Thorium isotopes, before
Feb. 1989. *No RU contaminants were reported in analysis before 1989. *In Vivo
counts were not performed frequently enough to be of significant value in TRU dose
reconstruction. *Interual dosimetry was not introduced until 1986. *Before DOE
Order 5480.11 (89) bioassay data was not routinely used to estimate intake and internal
organ dose. *No routine air monitoring was used to establish intemal intake or
exposure estimates. “Jn Vitro bioassays for thorium were not performed. *No
records were found of any bioassay results for Radium or daughter products during this
time. *No non-uranium urinalysis was conducted. “No fecal sampling has ever been
apart of the routine bioassay program. *No monitoring for non-uranium
radionuclides. “No monitoring in Geect TRU coatanninmnts with the MIVRML- *No
neutron dosimetry.

The above items are highlighted in a summary of the TBD to assist in their location.

Tn addition to the above I would like to add, the uranium urinalysis that was
performed was based on chemical toxicity and not radiological toxicity. So therefore,
*no radiological uranium urininalysis monitoring was performed. (In a Fernald
document entitled ‘Radiation Hazards at Fernald’ the writer says “Before discussing the
steps taken to protect personnel against the inhalation of radioactive dust, the writer
would like to indicate that the present maximum allowable concentration for uranium
dust is based on the chemical toxicity of uranium rather than the radiological toxicity.
[his can be verified by reading the footnote for the ureniam concentration ia the National

Ce Nae cen This will be
confirmed with additional documentation.

F2
The ORAU TBD states that much of the thorium data has been lost, and the plant
bioassay monitoring data recovered to date has been sperse, A large number of records
were dest " ls during declassification efforts (Dolan and Hill

The TBD states that no information was identified to address the uncertanties in
were used. I would suspect the source of the exposure is missing from the records. The
TBD also states there is no analogous validation for data obtained before 1987 and
especially back to the1950s.



26. Management gave eight calendar days to complete the
procedures, and added six calendar days to complete dévelopment
and implementation of training, roping off areas, procurement of
disposable clothing, cleaning, and more. Management gave us a
total of 14 days to complete the project. That was far too little
time. I felt that at least two months were required due to the
magnitude of the project, and I said as much. Despite this, Mr.
Weichold and I were the only ones assigned to write and-revise

procedures,

27. On February li, Mr. Weichold informed me that he would not
be working on the project, and gave me the full responsibility
for completing the assignment. This change definitely made it
smpossible to meet the deadline for the project. I had already
pointed out in the earlier meeting that I believed that
everyone was "unduly overly optimistic" concerning the
preparation time given to process the plutonium. The unanimous

response at that time was "No, we can do it." As Mr. Macaulay

‘said, "I think you guys can get the job done."

28. The next meeting was held on February 14, 1986. At this
meeting Mr. Macaulay wanted the procedures signed off. I stated
that the procedures were inadequate, especially the Health and
Safety Procedure. I then told him that all procedures would have
to be sent around again for review. They reluctantly agreed to
ohe more review. I also pointed out that maintenance personnel
would have to be trained. No one had even thought of that. This
was an amazing oversight since the head of the plutonium program
was also the head of the training program.

12

3128775


9. Despite the importance of the procedures, I consistently
found that the procedure being audited was often non-existent,
out-of-date, inadequate, ignored, or inaceuréte. Complicating
the situation was the fact that ‘nanagement was slow to respond.
Management ignored key items for correction, and failed to
implement corrective action when promised. For ‘example, in an
audit of the solid waste incinerator at Fernald in the summer of

1985, I discovered that materials contaminated with radioactive

materials were being burned. Fernald does not have a license for

that. Radiation could conceivably go up the stacks and into the
atmosphere. Management would never know whether or not this

occurred since ther are no radiation monitors on the stack.

Management promised to correct the situation, but when I followed
up to check the corrective actions, I found that they had not
corrected the situation. I read in the newspaper that the Ohio
EPA shut down the solid waste incinerator in May of this year

because radioactive ash was found in the incinerator.

_Apparently,..Fernald. management. had.still.not implemented the-

corrective actions. This uncaring, unprofessional attitude

and practice of management continued. Massive health and safety
problems uncovered during the course of many audits went

unresolved.

10. Finally, follow-up audits revealed that several, sometimes
none, of the corrective actions promised had been implemented.
This problem was so pervasive that I wondered why I was wasting

my time doing the audits at ail.

3128768


14. When Westinghouse took over operations at Fernald on January
1, 1986, organizational changes occurred site-wide. The
Westinghouse line was, "Forget what has gone on in the past.

It's a whole new ball game." I first realized the meaning of
this when on January 6 I was told by Mr. Grumski, the
Westinghouse Quality Assurance/Quality Control Manager not to
perform any more audits, because there was “nothing to audit on a
QA basis." What was meant was that there was no Quality
Assurance program onsite to date. However, I felt that they
should at least follow up on previous audit responses. My
immediate supervisor told me and a co-worker to write an audit
evaluation of each previous audit over the last year (1985) and
identify outstanding deficiencies. I was told that these
evaluations would be presented at the January monthly QA meeting.
This was not done. Nor were they presented in February or March.

Yet there were many outstanding deficiencies that needed

immediate correction. : a

15. I expected better communications and attitudes to improve
throughout the site with Westinghouse, and to some extent it was
better. Westinghouse promised that Quality Assurance would be a

high priority. But, when push came to shove, Production had

total control. I concluded that Westinghouse was adept at saying

the right things, but when it counted, it was "business as

usual."

3128771


Note: If Fernald records had been adequately reviewed by the ORAU team, discrepancies
in data should have been discovered. A discrepancy exists in the data provided by Dolan
and Hill 1988 (pg18 sec.5), which differs from data by Alvarez 1984(pg18 sec.6) Both
ate in regard to locations of thorium processes.

Section 6-Occupational External Dose

6.1 The Introduction

Fernald processed such large quantities of radioactive material, in this case
uranium, up to 10,000MTU annually and a small amount of thorium with a staff of up to
almost 2,900. (date?)

The occupational dose received by the workers at FEMP was a function of the
physical location of the worker on the site, the process, and the type and quantities of

TODNee Ler tha Unease ed pm ences of ataest

Workers at FEMP who might have been exposed to the source of radiation
discussed in this TBD were employed during the period starting in late 1951. Of most
concern are those employed from the late 1950s to the mid 1970s.

No early radiological policy documentation at FEMP was found during the TBD
investigations. However, individual doses from personal dosimeters worn by the workers
are available, and the TBD pertains tc -

6.2 (ese limits changed.)
- FEMP became DOELAP accredited in 1987. While this accreditation is of
significant value in validating data from 1987 and later, there is-no analogous validation

dosimetty system(s), their reconded roses, cad their comparability to current stems
depend on: 1) Administrative practices and requirements, 2) Workplace radiation field,
materials, quantities, etc. 3) Dosimetry technologies and calibrations. 4) Process
technologies and5) Training and practices

Note: Fernald documents demonstrate the record keeping, practices in PE330B, PE760.
[ORAU failed to recognize accurately the radiation fields, materials, and
quantities in regard to thorium and probably other exposure potentials.) The sccuac of

Fernald docurmeat indicoted that a werkar ae cbcerted orci, wits es hood ineide the
equipment. His breathing zone obviously wasn’t near the dosimeter. [This definitely
demonstrates the need for improved training and safety practices.]



12-12-05p 19.34 Revp
SEC Petition

Office Of Compensation Analysis and Support

NIOSH

4627 Columbia Parkway, MS-C-47

Cincinnati, OH 45226

Attention: SEC Review Board

respectfully submit this petition on behalf of the Fernald workers; the living, the
deceased and their families.

T believe that NIOSH was not able to determine with reasonable accuracy the
radiation doses incurred by the workers at Fernald. Based on insufficient accurate
information, they were unable to estimate the maximum radiation dose that could have
been incurred by any member of this class.

Documents indicate there was no monitoring for specific types of ionizing
radiation known to be present, The monitoring was limited in frequency and to limited
groups of workers. The monitoring was inaccurate due to sampling techniques and
dosimeter limitations. Some data could not be interpreted due to deficiencies in the
record keeping procedures. Worker assignments often changed as they were rotated to
different locations in an attempt to limit exposure levels.

Dose reconstructors believed ‘Good housekeeping’ practices were followed at the
site. This misconception and limited data resulted in inaccurate default assumptions.
Data was reconstructed for the thorium processes because the records had been destroyed
in 1970, but it lacks validity due to gross error.

Therefore, I believe it is not feasible to estimate with sufficient accuracy the

radiation dose that the workers at Fernald received and that those radiation doses
endangered the health of those workers, and possibly their families.

Respectfully submitted,



16. My first actual insight into how things were to be under
Westinghouse came with my first major assignment - -
investigation of the shipment of radioactive materials in vessels
called "T-Hoppers." A T-hopper is a transportation vessel used
to transport radioactive materials. I was to investigate the

overall operation of transporting T-hopper vessels.

17. It is important to explain the background behind this

incident. A shipment of an externally contaminated T-hopper from
Fernald to the DOE's Hanford Washington facility in July of last
year sparked a DOE investigation which heavily criticized Fernald
for lack of procedures, training, quality assurance and more. I

would like to submit the DOE Investigation Report for the record.

18. On January 14, 1986, DOE sent the DOE Investigation
Report to Westinghouse management, and instructed them to comply
with the Report's recommendations within a month. On January 28,
‘1586, Westinghouse responded to DOE with a letter that the ~
guaranteed that Westinghouse was in compliance with the DOE

mandate.

19. On January 31, 1986 Mr. Grumski approached me and assigned -
me the task of evaluating the "Action Plan" developed by NLO in
response te the DOE report, as well as the Transportation
Department’s compliance with the Plan. The Action Plan
guaranteed to DOE that corrections had been made and that the
mistake of shipping contaminated and leaking T-hoppers would

net be repeated in the future.

3128772


the MAC. I am submitting this document for the record.

This chart [slide #2] shows the proportion of workers at the Fernald plant
‘who were exposed to more than the allowable limits due to lung burdens of
‘uranium. It summarizes IEER's conclusions: that doses due to uranium
inhaled by workers between 1952 and 1962 were above then-allowable limits
(15 em per year to the lung) in more than half the cases in every year but
ons. In 1955, the worst year for worker exposure, IEER estimated that almost
90 percent of workers were exposed to more than the allowable lung dose
limit. As you can see, significant proportions of workers continued to suffer
overexposure after 1962.

2) Similar to our analysis of worker doses at the 3 private uranium processing
facilities, Fernald workers were not told about their internal radiation
overexposures by AEC and its successor agencies nor by contractor officials
until at least 1989. One of the most startling findings in the course of this
study was that the urine and lung counting data (in other words, internal dose
measurements) of the Fernald workers had never been converted into,
radiation dose estimates. Worker radiation dose records - that is, the records
actually given to workers when they ask for them — contained only external
radiation doses, such as those recorded on film badges worn by workers.
Therefore, we found that the assurances given to workers by that they were,
on the whole, well protected, were based on very partial information. In the
case of Femald, these assurances did not even take account of the most
importarit route of exposure: inhalation of contaminated dust.”

Just after the presentation of IEER's findings in court in 1994, the
Department of Energy settled the lawsuit on behalf of National Lead of Ohio,

Our suspicion that the situation at Fernald may not have been an exception in

: this-regard was-confirmed when, three years later, the

Department-of j
finally admitted that from the beginning of the nuclear era until 1989,
radiation doses from radioactive materials inhaled or ingested by workers
were not calculated or included in worker dose records, even though the data
had been collected and was available to the DOE and its contractors.

While there was no regulatory requirement until 1989 for DOE to actually
calculate worker doses, the lack of internal radiation dose estimates in worker
dose records means that the records of workers who were at risk of internal
exposures are incomplete, misleading, and inaccurate. The overall result is
that large numbers of workers have received information about their radiation
exposures systematically understating their actual exposures.

The state of the external dose records is also troubling. For instance, in a 2-
1/2 page document titled "Deficiencies in Reporting of Worker Exposure to
Radiation and Toxic Material," the DOE admitted that:

“The type, use, and positioning of dosimetry was poor in some cases,
resuiting in inaccurate determination of radiation exposures.”


INDEX Section 1. Summary Notes

PE 330B Charles Dees, Industrial Case Study: [Acknowledges not having up to date
records.]

PE 760 Questionnaire on Radiation Record Keeping Systems: [Excretion Urinalysis
data recorded but can’t be used to calculate internal dose. }[Average recorded
doses per worker per year is 2.6.]

PE 901 Information on Forthcoming Feasibility Study. [Exposure to internal emitters
is the more serious type of exposure.][We do not consider the urinary uranium
excretion measurement as an accurate method to estimating either body
burden or exposure.]

INDEX Section 2.

PE 515e GAO; Testimony. [Data quality requirements.]

INDEX Section 3. TEER.

‘Written Testimony for the Subcommittee on Immigration and Claims,
‘Committee on the Judiciary, U.S. House of Representatives.’

*Worker Radiation Dose Records Deeply Flawed.’

‘Health and Environmental Impacts of Nuclear Weapons Production.’
“‘Femald Workers’ Radiation Exposure.’

INDEX Section 4. Attitudes and Practices of FMPC

PE 108A Health Conditions in the Various Plants. [Permitting certain conditions for the
sake of production.]

PE 149a_ Refinery NO2 Fume Releases. [Tell them what they want to hear.}

PE 386 Standard Operating Procedures for the Collection of Air Dust Samples.
[Provide your own respirator.}

PE 387 Changes in Terminology. [We'll do it our way.]

PE 391 Testimony of Daniel J. Arthur, before The Subcommittee on Energy,
Conservation & Power. [Methods Analysts/ Lead Auditor at Fernald.]

PE 397u Health Protection Appraisal; National Lead of Ohio, August 1972.
[Hazardous work environment; Contaminated wrist badges/ uncertainties;
Limited monitoring; Urinalysis used to monitor operating conditions.]

PE 507 Letter. [Findings from visit.] [They don’t know what constitutes an incident.]

PE 509c Comment on Health Physics Appraisal. [Failure to commit to ALAP/ALARA


Attached to this petition are many documents that reflect a portion of the evidence
@ against NLO as presented in the class-action lawsuit in 1990. They demonstrate the gross
dis-regard for human safety. They also give a glimpse into the workplace and it’s
excessive radiation exposure potential.

Included by section are:

1.) The TBD summary and evidence as noted from the summary.

2.) GAO statement concerning ‘data’ requirements.

3.) Institute for Energy and Environmental Research (IEER) documents.

4.) Documents that reveal the attitudes and practices of the FMPC management
that endangered workers and permitted high levels of exposure to exist.

5.) Thorium processing documents. { Most were reported to be destroyed in
1970.)

6.) Thorium processing documents for Plant 6. ( This data was omitted from the
@ reconstructed data used for dose reconstruction.)

7.) Documents that reflect plant operations and exposure potential at various
production, technical, and storage sites. (Also documents on Plutonium.)

8.) Reference document for F1 of SEC petition.

It was my desire to best represent ‘All’ the workers at FMPC with this petition.
The time span is a vast one, some 38 years, and the documents are numerous. Exposures
occurred through the production years by way of new releases of ionizing fadiation; but it
also continued through contamination to later workers. In many cases the data is limited,
which makes it impossible to fairly assess the exposure to any individual at any given
time except as noted by reported incidents.

There was one document that I found especially interesting . (PE 745s) mentions
increased fallout on site from “WEAPONS TESTING”. I didn’t know if this was part of
the program at Fernald.

Lhope this petition holds some information previously unavailable. I have tried to
index it for easier referencing.

e Thank you for your consideration.


Cm. Institute for Energy and Environmental Research
e Comments to Outreach Coordinator: icer@ieer.org
‘Takoma Park, Maryland, USA
January, 1993
ENDNOTES

1. The background paper was faxed to IEER on April 7, 1997 as preparation for a meeting an TEER staff member was
attending with the staff of DOE's Office of Worker Protection Programs and Hazards Management on April 14,
1997.

2. This model is referred to as the "ICRP 30 dosimetric model.” ICRP is the International Committee on Radiological
Protection. The model was announced in publication 30.

3. This kind of situation is quite possible because many important radionuclides, including uranium-238, ptutoniam-
239, strontium-90, and tritium would typically provide low extemal doses but high internal doses.

4. Formore on problems with DOE's extemal dose data see A. Makhijani, H. Hu, and K. Yih, eds., Nuclear
Wastelands, (Cambridge: MIT Press, 1995), pp. 262-63.


@

e

a 1991‘ report by the Office of Technology Assessment.’ - The
report noted that a review of six weapons facilities by DOE’s own
Tiger Teams through December 1989 revealed many problems with the
practices for monitoring radiation and assessing doses. For
example, air sampling techniques were isjdequate at 83 percent of
the facilities assessed and shortages of personnel trained in
xadiation measurements were found at several sites.

We also found information in the technical safety appraisals
xegarding problems with the completeness of the exposure data
coliected at the sites. For example, at Rocky Flats, some
dosimeters were not returned to the contractor prior to final
processing. Yet in these instances, the contractor did not
require an estimate of exposure. This situation can result in
errors in the data reported to DOE and to the employees in their
exposure report cards.

During our review of the Health Surveillance Program, we
interviewed the Pacific Northwest Labs staff scientist who chairs
a DOE group working on issues concerning the radiation dosimetry
data to be included in a comprehensive data base. He noted
problems with the comparability and accessibility of exposure
data. Specifically, he pointed out thag for most DOE facilities,
the methods used to calculate recorded radiation doses for
workers varied considerably over the years and that the
documentation of historical dosimetry practices is fragmented.
The documentation for workers employed in the early periods of
DOE‘s operations is particularly uncertain and individuals with
direct knowledge about workers’ exposure are rapidly retiring and
leaving DOE. He also noted that the status of radiation
protection records is highly variable among DOE facilities. In
many cases, electronic files of dosimetry information do not
exist, and manual retrieval is difficult, expensive, and time-
consuming.

the National Research Council addressed the issue
of data quality in its 1989 review of workers’ health and safety
in the weapons complex. The council stated that the data :
collected at DOE sites during ongoing monitoring and surveillance
programs are useful _in assessing risks to workers’ health only tp
the extent the data are accurate, comprghensive, accessible and
comparabic- Yhe data collected tmthe past, .the Council
cr

concluded, are jnadequate--because of both the kinds of data
¢goliected and the means in which they are stored.

"Complex Cleanup: The Environmental Legacy of Nuclear Weapons
Production, Office of Technology Assessment (Feb. 1991}.



31. The implications of this disarray became immediately evident
in the very building where I worked. The uranium dust in the
Eaboratory Building was unusually thick, and I asked why *

such conditions were tolerated. I was informed that there was
only one dust collector and that it was in the basement. A dust
collector is supposed to clean the air in the building, and
filter out the excess radioactive dust. I went to the basement.
and took a look at the dust collector, and then asked who was
xesponsible for changing the bag on this particular collector.
ebody knew. So I asked where the procedures were for changing
the collector's filter bag. I discovered that there were no
procedures. The bag, as far as I could determine,

nad never, in the life of the plant, been replaced. Months went

by, and finally, in June 1985, I insisted that the bag be
replaced, which it was. Mr. Graver, Mr. Fallings and I
witnessed the removal of the old bag which literally fell apart

as it was removed. Uranium dust had not only been building up in

thé Lab BUiIding for years, but dust was bypassing the bag ard

going straight up the stack. Again, there was no radiation

monitor on this stack, either. Upon further inquiry, I
discovered that many of the dust collectors in the production

Plants lacked procedures, notably the portable dust collectors.

31287693



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“In some cases, occupational radiation exposure records are missing years of
radiological dose data."

“Radiation exposure data stored on electronic media did not accurately reflect
the data on the original record.”

“Employee files do not contain the required information related to
occupational radiation exposure and radiological working conditions."

“Internal and external occupational exposure records were found to be
incomplete."
“Because of inadequate administrative procedures and practices employees

that had lost their dosimetry badges were able to enter radiation areas before
obtaining replacement dosimetry.”

According to the document, this information was obtained from Technical
Safety Appraisals conducted during the period 1989 to 1992. It was
submitted by the Department of Energy at a hearing of the House
Subcommittee on Oversight and Investigations on March 17, 1994.

This photo {slide #3] further illustrates some possible flaws in external
worker dose data. This worker is stamping a label on a uranium ingot, a job
that was done routinely throughout the history of the Fernald plant. The
external dose to the worker's gonads, and hence the effective whole body
dose equivalent that might be calculated from that, are likely to be far in
excess of what was recorded on the film badge. First, the film badge is not
facing the radiation source, which allows some of the radiation to escape
detection. Second, the distance between the radiation source and his gonads
deposits its energy relative to distance, the dose to this worker's gonads is
likely much greater than what his film badge would indicate.

The Fernald worker study was actually the second Fernald study performed
by IEER. The first one, completed in the late 1980's, was done as part of
expert work in a lawsuit filed by neighbors of the Fernald plant. This study
was the first ever independent assessment of radiation releases form a nuclear
weapons plant. IEER focused its work on estimating uranium losses because
uranium was the main material processed there and because data on other
materials released to the air were scarce or non-existent.

TEER found that radioactive releases of uranium from Fernald were at least
double the official calculations by the Department of Energy and its
contractors. After the study was released, the Centers for Disease Control and
Prevention commissioned an independent study of the radiation doses to the
public arising from Fernald's operation. That study, done by John Till,
corroborated IEER's findings in regard to uranium releases. As shown in this
table [slide #4], the official sources (NLO and Westinghouse) had greatly and
systematically underestimated releases.




poor science, and calculational mistakes and inaccuracies.

Despite the settling of the lawsuit against the contractor of Fernald for $78 million of
taxpayer money, concerns remain. Many studies have repudiated DOE and
contractor work, showing elementary scientific flaws in it, but neither the DOE nor
any of its contractors have discussed what went wrong, much less how the
recurrence of scientifically dubious and misleading studies might be prevented.
Many issues, such as the exposure of residents to non-radioactive pollutants and
non-compliance of the plant with environmental regulations, remain unaddressed.

The DOE needs to put its own work and that of its contractors in the perspective of
the findings of the independent Fernald studies. That should be the first in a series of
steps that it must take to create a system that would do environmental science with at
Jeast the same vigor that DOE and its contractors addressed bomb-making.

to SDA Vol. 5 No. 3 Main Menu
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Return to IEER Home Page

amp | Institute for Energy and Environmental Research
Comments to: Ce) Outreach Coordinator: ieer@ieer.org
Takoma Park, Maryland, USA

Posted March 1997
Corrected September 2000

ENDNOTES
1, For details see Arjun Makhijani, Release Estimates of Radioactive and Non-Radioactive
Materials to the Environment by the Feed Materials Production Center 1951-85, (Takoma
Park: Institute for Energy and Environmental Research, 1988); and Arjun Makhijani and .
Bernd Franke, Addendum to the Report ‘Release Estimates of Radioactive and Non-
Radioactive Materials to the Environment by the Feed Materials Production Center 1951-
85,' (Takoma Park: Institute for Energy and Environmental Research, 1989).

2. RH. Starkey, memorandum to A. Meredith, “Estimated Stack Losses for December
{1955]", National Lead of Ohio, 10 January 1956.

3. K.N, Ross to J.E. Beckelheimer, "Thorium Metal Production Housekeeping," National
Lead of Ohio, 8 June 1970.

4, Unfortunately, the CDC did not ask for an evaluation of exposures to non-radioactive
materials in its request for proposals. .

5. RAC prepared a number of draft and final reports leading up to the draft 1996 report. The
ones most relevant to this article are: Voillequé et al., Fernald Dosimetry Reconstruction
Project: Tasks 2 and 3: Radionuclide Source Terms and Uncertainties, Draft Report
(Neeses, South Carolina: Radiological Assessments Coporation, 1993); and Killough et al,
Fernald Dosimetry Reconstruction Project: Task 6: Radiation Doses and Risks to Residents
from FMPC Operations fom 1951-1988, Draft Report (Neeses, South Carolina:
Radiological Assessments Coporation, 1996).


Act National Institute for Occupational Sefety and Health:

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 7 of?)
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address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
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Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

‘The Energy Employees Occupational tliness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(GEOICPA) authorizes the President to designate additional classes of employees to be included in the
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assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
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provide required information may not be considered by HHS.

Name or Social Security Number of First Petitioner:



5.2.4 K-65 Silo Processes.

Silo 1&2 disposed of raffinates from Plant 2/3 and received pitchblende raffinate
wastes shipped from MCW in 55-gallon drums. Shipping began in 1951 and by July
1952, 13,000 drums had been stored on the pad around Plant 1. The waste was
transferred into the silos from July 1952 through Sept. 1958. The total radium
-containing residue from processing uranium ore is 10,000MT.

Silo 3 stored ‘cold metal oxide’ extraction separations and contains approximately
138,000 cu-ft. of raffinate.

Silo 4 contained contaminated water. ( The concrete silos cracked and leaked.)

Information on the K-65 silo processes is derived from air sample and external

ais seat te mens Bee osd nl 193.
pg26 Ona couple of data sheets there was a note that no respirators were worn. It
is presumed that the note was made to record an unusual event.

Note: There is no basis for that assumption. However, it seems to run throughout the
dose reconstruction. Repeatedly doses based on airborne exposure have been calculated
on the assumption that all workers were protected with respirators. I haven’t seen any
indication that the effectiveness of the respirators was ever considered.

The information on the data sheet indicates that in spite of the fact that the
contents of the drums were wet, the operation resulted in significant airbome

” Calonlations assume that doses above ‘rem would not tbe administratively planned
to avoid exceeding the Srem/year limit.

that they “often do not have a ‘complete work history’. (PE330b)

pg27 Radon gas was released as the drum lids were removed.

It is evident that these estimates are based upon assumptions that are cumulatively
conservative,

5.3.1 Radiological Controls Pregram was in place from the beginning of FEMP
operations. The internal dose control program consisted of 1) An air sampling program
in all processing areas to evaluate internal exposure potential via inhalation 2) Urine
samples submitted after at least a two-day work break to allow elimination of uranium
cleared rapidly via the GI tract, 3) In vivo analysis.


12. Recordkeeping in the area of DOE orders was also literally
a joke. DOE "regulates" its plants through directives in the ;
form of Orders. A DOE order is supposed to set the requirements
for the total operation and maintenance in the areas of worker
protection, environmental, health and safety, reporting of
accidents, and in almost every area of operation. I discovered
just how seriously Fernald management viewed the DOE Order systen
in January, 1986, after Westinghouse took over operations at

Fernald,

13. I was ordered by Mr. Grumski to get the DOE orders out, as
the Orders would be needed in performing investigations. r
searched for hours but could not locate the orders. 1 finally
found them in the Legal Department. I discovered that the Orders
were literally heaped on a shelf, in total disarray. The binders
that held the Orders were not in any order, and many labels that
titled the binders were on the floor. Many Orders were missing,
some were not filed, and some were also on the floor. I
discovered that the Legal Department had not kept up the files
for over five years. I reported the problem to Westinghouse, but

at the time of my departure, nothing had yet been done.

312877C



exposure!? Such a study would be misleading and tend to underestimate risk
estimates, By contrast, ifthe high external exposure group had even higher
( ) internal exposures, the study would also be misleading and would tend to
overestimate radiation risk.

The April 1997 DOE background paper also points out that lifetime dose
records have not been carefully maintained though the risk to workers is
contractor to the next at a plant, or from one plant to another when the
worker changes jobs, worker health as well as public health is compromised
because it becomes impossible to accurately track the health effects of
occupational exposure. Of course, this is another complicating factor in doing
epidemiological studies and assessing radiation risk.

External Exposure Data

The state of external dose data also needs to be carefully examined. The DOE
has admitted the following problems*:

e External exposure data are often incomplete and unreliable.

« Raw dose data and electronic versions of the data (which are often.
used by researchers in studies) do not always agree.

e In some cases, worker dose records contain entries stating that the dose
@ has zero, regardless of what the actual dosimeter reading may have
a.

Finally, there were very few measurements made of worker exposure to non-
radioactive hazardous materials. But we do know from the nature of work
done at nuclear weapons plants that many workers were exposed to or were
at risk-of exposure to.acids, organic solvents, beryllium, fluorine and
fluorides, and heavy metals.

As a result of aff of these problems we can conclude that knowledge of
workplace exposure during nuclear weapons production and testing was
poor, and the results of at least some epidemiological studies are likely to be
misleading. At present, it is impossible to say what health effects might be
revealed by properly conducted studies. But we can say with confidence that
the radiation doses for large numbers of workers were higher than those that
are apparent from their dose records because internal doses were omitted
until 1989, and because there were many deficiencies in other dose records.

Return to SDA. Vol..6 No. 2, Main Page
Return to SDA Main Page
e@ Return to IEER Homepage



6. In Fernald's Quality Assurance Department, I discovered that
there was no comprehensive audit program in place. I found that
the department was understaffed; only three audit department
personnel had responsibility for performing literally hundreds of
audits, updating and revising procedures, and performing a
variety of other functions. The audit department had no
independence from, and in fact took orders from, production;
under NLO, in particular, the Quality Assurance Department. was at
the bottom of the organizational chart. I was not allowed to
pursue audits in certain critical areas of plant operations. on
some of the audits that I performed, I was not allowed to

undertake follow-ups, or I was restricted to looking at a limited
area of plant operations.

7. I stated that from the beginning I was uncomfortable with
the audit arrangement. Occasionally, I would perform an audit on
my own which resulted in complaints from production, and in turn
pressure from’ Mr. “Tippehhauer, the héad of the department, to
alter, or even stop the audit entirely.

8. The bulk of ny responsibilities within the first year
involved audits of procedures. Procedures are like recipes for a
cook. They tell the chef the steps to take to arrive at the
perfect souffle. At Fernald, the chefs often cooked by memory
or used faulty and incomplete recipes. This often resulted

in lots of black smoke from the kitchen.

3128767


PERSONAL BACKGROUND

I am originally from Iowa, and I graduated from high school
there in 1970, and entered directly into military service with
the Army. I was stationed at Ft. Lewis, Washington, for basic
training, and received advanced individual training as an
electronics technician at Ft. Monmouth, New Jersey. In 1972 I
was granted a tep secret clearance and worked as a communications
technician on cypher equipmens at the backup for the Fentacon,
Ft. Ritchie, Maryland. _ in November 1972 I was sent te Korea
where I performed essentially the same functions in the
communications area. In June 1973 I received a letter of
appreciation stating ". . . Your technical expertise and
professionalism, coupled with your willingness to work long hours
have evoked many favorable comments from NCO's and Commanders
alike. . .. I left Korea and the service three months early
to attend Iowa Central College, where I completed a two-year
program with an Asseciated Arts degree in 1976. Upon graduation,
.= enrolled in. the University of Northern Iowa, and earned my B.A.
in economics in 1978.

From 1981 to 1983, I was Quality Control Unit Manager with
Control Data Corperation in Minnesota where my job responsibli-
ties included supervising 15 electronic technicians, determining
test goals and the yearly budget, ana initiating and revising
Standard Operating Precedures and Manufacturing Specifi- f
cations. Previous to that, I was Production Control ‘
Supervisor at Nortronics Company, Inc., where I established

short and long term production goals and schedules, programmed

-26

3128782


20. .On February 7, 1986, I submitted my investigation report to
Mr. Grumski personally. He was impressed enough with the report
that he came into my office that same day and congratulated me on
what he called one of the best audits to come cut of Fernald. My
investigation, performed seven months after the July T-Hopper
incident, revealed fourteen areas that were deficient. on
February 18, the Hanford facility again received another
contaminated T-Hopper from Fernald. Lessons were not being

learned.

21. Immediately following this incident, I was assigned what was
to be my last project at Fernald. For me, it was the inal straw
which led to my resignation and convinced me that I had to come

forward to expose the intolerable situation there.

22. The assignment was to develop procedures for processing
“plutonium out of ‘specification". The assignment was =~
initiated because Fernald had received a shipment of plutonium-

contaminated ash in 1980, and had processed a portion of that
plutonium-bearing material in a manner which jeopardized the
workers' health and safety. A September, 1985 DOE investigation

of Fernald's handling of the plutonium-bearing material in the
past was highly critical, and serves as background information
for this incident. I would like to submit that report for the

record.

10

3128773


40. Without an effective regulatory system, Fernald will remain
a quagmire of environmental poisons. I hope and pray that this
committee, the U.S. Congress and the public put a stop to DOE's
neglect and incompetence. Failure to act will allow the Fernald
slow-motion bomb to continue its shower of deadly fallout on the

Cincinnati community and the Fernald workforce.

Thank you.

17

3128780


materials released to the air were scarce or non-existent. We re-estimated losses
from several important sources, notably scrubbers in the scrap recovery plant (Plant
8). We also made an estimate of uranium releases based on measurements of
uranium in the soil around the plant. Our work was admittedly very preliminary,
mainly since IEER was unable to obtain most of the crucial documents regarding
plant operation and pollution control equipment efficiencies. Moreover, the quality
of the data that we had was poor and some of it was internally inconsistent.

Still, we concluded that the official estimates were almost certainly wrong, that the
releases were higher than the upper end of the official estimate of 552,000 pounds,
and that uranium air concentration standards had been violated on at least some
occasions. IEER estimated that uranium releases were in the range of 600,000 to 3
million pounds, with a middle estimate of 900,000 pounds. [EER also recommended
further detailed work, since these estimates were of a very preliminary nature.

The DOE, which defended the lawsuit on behalf of the contractor, NLO, settled the
suit for $78 million in mid-1989, but admitted no wrong-doing, or even any
technical problems in its own or its contractors’ work. (Under the terms of its
contract with the government, NLO was immune from all liability, including that
arising from negligence or violations of regulations.)

But the Centers for Disease Control and Prevention (CDC) initiated an independent
study of the radiation doses to the public arising from Fernald's operation. The final
draft report of that $4 million study, prepared by Radiological Assessments
Corporation (RAC), was released in August 1996.5 It corroborated IEER's critique of
the official estimates of uranium releases to the air and greatly narrowed the range,
estimating it to be 590,000 to 790,000 pounds, with a best estimate of 680,000

po .

The following table summarizes the various estimates for uranium releases from
Femald. id. Only the best estimate, or middle estimate, made the by source is sown:

Summary of Estimates of Uranium Releases

Institution Uranium releases to the |} Uranium releases to surface
air, pounds water, pounds

O, early 1985 _ | 200,000 160,000
estinghouse 1987_ || 300,000 | 160,000
inghouse, 1989 400,000 160,000
IIEER 1989 900,000 not made
[RAC 1993 | 1,000,000 180,000
C 1996 |__ 680,000 sd 180,000

‘Sources: For discussion of all release estimates and detailed references, except RAC 1993 and RAC
11996, see Makhijani 1988 and Makhijani and Franke 1989. Note that RAC published draft estimates|
jin 1993, which it revised in 1995 and again (slightly) in 1996.

[Note: Figures are rounded to one or two significant digits, as indicated.

Radon releases


+ SPAT ee eRe RARE ne oe

’

o~

£. GENERAL

The purpose of these questions is_to assist in determining the presen:

state of recordkeeping Systems

The data which these questions wilh

provide will help to estimate costs to automate the records systems at
DOE facilities. These Costs will include not only the size of machines
which may be required to process the data but aiso the time Recessary to

1.

2.

3.

4

5.

0036467

z i enter the exposure data into the computer on a continuing basis and, if -
& necessary, all past exposure records.

What is the number of currently employed workers for which you have
radiation dosimetry records? (Please list the numbers separately

for each DOE/DOE contractor facility)
997

What {s the tota? number of workers (current and terminated) for
which you have records?___6165

what is the average number of dese entries per worker per year?

506,280 total entries/ (6165 workers x 32 yes) 42.6)
Is al data for cutrent employees maintained (check all that apply)?

x. on site .
x government storage center

other, (please describe)

Is all data for past (terminated) employees maintained (check a1
that apply),

«onsite
x" government storage center
_____ other, (please describe).



Changes in Terminology, Absorption Factor and Airborne Alpha

Activity Limit -
J. H. Noyes —
April 5, 1963 Page 2

time ig harmful - that there is some magic line between
fsafe® and "sorry." ‘This is definitely not the case in
these applications. The new terms should correct the
error in interpretation; however, it will probably require
some time for people to become accustomed to them.

Work carried out by Biowassay Laboratory personnel on air
dust samples collected at NLO operations demonstrate the
need to change the absorption factor used in the calculation
of alpha air dust levels. Extensive investigation indicates
the absorption loss to be 50% rather than the 30% that has
been used since the start-up ef the FMPC. ‘This change will
cause an increase of 40% in the calculated levels of alpha
activity for air dust levels.

Pinally, NCG for airborne alpha aetivity is peing changed
from 70 alpha disintegrations per m: ute per cubic meter

of air (70 a-d/m/M3) to 100 a-d/w/M>. ‘mis change will
@ almost (ro ee ae neste 9 o-oo M oeptien faotor change

and is still well below the "special curteTM number of
approximately 270 a-d/u/#3 as outlined by the FRC.
In summary, the proposed changes are:
1) Change MPD to RPG.
fo) Change MAC and MPC to NCG.... . -
z Change the absorption factor fpom Oe7 to 0.56
Change the NCG from 70 a-d/n, to 100 ad, .

These changes are being made retroactive to January 1, 1963.

aes

RHS/mjs
ccs G,. W. Wunder

J. H. Noyes - 1x
All Division Directors

o188ssi


_-- : . we

we? a“
Te ert CENTRAL FILES
=
8 NATIONAL LEAD COMPANY OF OHIO ¢ ea 4
z atts
a enna Aw. Seaeore é ae
MR © SALTER SE ETD C-=a"”
P.O, BOX 39158 a CINCINNATI. 39, OHIO

Nevernber 1, 1963 c

2151983

Subject: Information as Forthcoming Feasibility Study on “ Carreiztion of
Lifetime Heaith and Mortality Experience of AEC and AEC eoa-

tracter Employees with Radistion Exposure
@ Deer Bill:
Tt was a pleasure to see im Pittsburgh and to discuss with you
the subject feasibility study. to our meeting I had been somewhat con-

to "amounts of radiation" and the reference to NCHRP standards regarding life-
time expoeure to' penetrating radiation. Thad postponed answering the latter
from Mr. Karl to our Manager, Mr. Noyes, peading some clarification of

ree ee

First of all I would like to say that I very much favor the proposal to uadertaks
a feasibility study. I quite agree that radiation in its broed sense should encom-

id should not be toe difficult, though it certainty will be time-couseming and

Ee work, Relating these findings to external or penetrating radiztion

5S will be relatively imple, since at all AERC eoutractor sites complete

23 date to penetrating radiztion hap dean accumulated since the days of the Manhatten
z 3 am somewhat more concerned, however, with the adding of a factcr or

o1eisga


fraction of the gamma rays emitted by radionuclides inside the body escape
outside it. This is measured by putting the worker or part of his or her body
into a "counter," which is a chamber that measures gamma radiation. Thus,
we have “whole body counters," "lung counters," and so on. Care must be
taken to exclude or adjust for other sources of environmental radioactivity in
the measurement of internal body burdens, notably radon and its decay
products.

Internal doses can also be assessed indirectly by measuring the
concentrations of radionuclides in the air in the plant. In areas where
exposure is more likely, workers can wear portable air monitoring devices to
measure concentrations of radionuclides in the "breathing zone” -- that is, in
the air very close to their faces. Internal worker doses can be estimated if
breathing rates, efficiencies of protective devices worn by workers (if any),
and other factors are known.

Tt is essential that radiation monitoring be carried out accurately and in
sufficient detail. For instance, film badges and TLDs must be stored properly
when not in use, so that they are not contaminated between worker exposure
times. Also, workers at risk of internal exposures must be monitored
frequently enongh to accurately determine internal body burdens of
radionuclides. This is because over time the body eliminates radionuclides;
some are excreted in a very short time, while others are eliminated very

slowly. (The amount of time it takes to eliminate half of the body burden of a
radionuclide is called its biological half-life.) It is also important to know the
chemical form of the inhaled or mgested radionuclide because the rate at
which it is eliminated from the body depends on the solubility of the
particular chemical compound,

Failure to Monitor

The April 7, 1997 background paper sent to IEER by the US Department of
Energy Office of Worker Protection Programis and Hazards Management
clearly set forth what IEER had suspected for several years, that

..{ujatit 1989 in DOE, and 1991-1994 in the nuciear industry (NRC and
Agreement States) internal radiation doses were not calculate [sic] for
workers. Radiation activity in excreta or percent of body burdens were

recorded in the DOE prior te 1989.

Thus, while workers were being monitored for internal body burdens, these
body burdens were not being translated into radiation dose estimates; nor
‘were any radiation dose estimates corresponding to internal radionuclide
body burdens entered into the dose records of workers.

While there was no regulatory requirement to actually calculate worker
doses, the lack of internal radiation dose estimates in worker dose records
ameans that the records of workers who were at risk of internal exposures are
incomplete, misleading, and inaccurate. The degree of incompleteness and
inaccuracy will vary from one worker to the next, from one historical period
to the next, and from one facility to the next. But the overall result is that


Coveralls worn by workers reduced uranium beta exposure to the skin by
approximately 20%. .

pgl5 The forms of radiation encountered at FEMP varied from plant to plant with
plants 5 and 9 exhibiting the highest potential workplace dose rate. These plants were
involved with metal reduction, casting and rolling, end these processes. generated the

this material accumulated euled inthe ott or higher exposure ae Other areas
of potential high radiation exposure included areas where daughte aminates
other materials (.e. crucibles, saw, and rolling mills, where large quantities of parent
material were present.

Note: Thorium is one of those daughter products mentioned. [ The areas TBD-5 failed
to discover were given no dose consideration in this exposure.] .

pgi5 These dose rates were established for plants 5, 6, and 9 being the highest
and 5 the lowest.

6.3.5 FEMP Neutron

FEMP did not include any reference to neutron dosimetry with exception of
high-range, gamma sensitive 1290 film.

Even though there were large quantities of UF4 and UF6. Enrichments were low
enough (typically <2%)

Note: Earlier TBD-5 reported enrichment levels up to 20% with levels not documented
as to quantity.

6.3.5.1 Neutron to Photon Ratio
: It was determined that the vast majority of‘entiched material at Fernald was
approximately 1% enrichment.

To develop a neutron to photon ratio for UF4 (green salt), photon survey data is
also required. Unfortunately Baker (1995) only measured the neutron dose rate of
individual canisters.

The factors that affect an individual’s neutron dose include: 1) the quantity of
uranium processed, 2) the enrichment, and 3) the time an employee worked within a
process or storage area,

Most of the uranium work prior to about 1965 was natural uranium witha
decrease beginning around 1960 at which time the percentage of enriched uranium
received increased. By 1970, relatively little work with natural uranium was conducted
by Femald. Beginning in the mid 1960°s, work with depleted uranium began to increase.
By the 1970s, work with depleted uranium constituted the majority of the uranium work
at Fernald. In order to simplify the dose reconstruction, the low enriched uranium
neutron to photon ratio should be used. Fernaid is known to have processed large
quantities of uranium metal, yellow cake, black oxide, etc.


assumed to have been demonstrated.

In the period since the late 1980s, the regulatory practice has been to use
"committed effective dose equivalents.”? In this model, "effective dose” is
calculated by multiplying doses to individual organs or tissues, like the

relative likelihood of cancer mortality from exposure to a particular organ.

This allows exposures to a single organ and exposure of the whole body to be
considered together. Further, internal organ doses are calculated on the basis
of a fifty-year "committed" dose — that is, the entire dose from a radionuclide
to an organ over a fifty year period (in most cases, the majority of the dose is
delivered in a few years or less). These two concepts, "effective dose
equivalent” and “committed dose" are put together to arrive at “committed
effective dose equivalent." For regulatory purposes, the entire committed
dose is attributed to the year in which the radionuclide is incorporated into
the body. But even in this new practice, the organ doses arising from intemal
radiation must be known, besavee without thay data, the correct effective
dose equivalent cannot be calculated. This change in regulations requiring
calculation of effective dose equivalents caused DOE to begin to move to a
policy of integrating internal and external radiation doses.

While the unavailability of precise scientific techniques before the mid-1960s
would have precluded accurate internal dose assessment, the doses could
have been inferred from urine data and integrated into dose records, but were
not. After the mid-1960s, the AEC and its contractors could have made
relatively accurate worker dose estimates, but still failed to do so. It would
appear that the same institutional outlook that put weapons production before
environmental protection also relegated sound worker dose records into
second place until the Cold Wer began to wind down.

Consequences of Underestimating Dose

Underestimation of intemal doses is not just poor practice for worker health
protection. It also creates problems for epidemiological studies. Accurate
epidemiological work is needed to estimate the health risk of radiation
exposure, and this requires studies with sound data on doses to various
groups of workers.

Cohort studies, for example, compare the health status of people with various.
degrees of exposure. Such studies are common among worker populations
and heip to assess the risk of exposure to radiation (or other disease-causing
agents). But if worker dose records are distorted by omission of a crucial
component of dose, highly exposed workers and workers with low exposures
could be jumbled up in ways for which no statistical control is possible.

For instance, studies that consider external exposure only would group
workers with low external doses together and those with high external doses
in another group. If some or all of the low external exposure group workers
had higher internal doses than the high external exposure group, the study
would be comparing workers with high exposure to others also with high


The RAC stady also estimated releases of other radioactive materials. The most
important was radon-222 releases from the K-65 silos used for storing high radium-
content waste from Belgian Congo ores. The radium-226 in the silos decayed into
radon gas (as it continues to do). The deteriorating structures and poor storage
conditions and practices (which were partly rectified in 1979 and then again in the
1990s) led to huge radon releases from the silos, notably in the period up to 1979.
‘There were a few environmental measurements of radon made in 1979. TEER's
preliminary work, which was focused on uranium releases and plant compliance
‘with regulations, missed this significant source term. RAC's estimate of the radon
source term for the period up to 1979 is several thousand curies per year. The
cumulative radon source term estimate is 170,000 curies for the 1951-1988 period.

Radiation doses

While official DOE and contractor reports claimed that no harm had been done and
that exposures to the neighbors of the plant were well under allowable limits, IEER's
work found that hypothetical maximally exposed individuals near the site boundary
were likely to have been exposed above allowable limits, especially during
accidents. Because IEER lacked the documents regarding pollution control
efficiencies, particle sizes, and chemical composition of the pollutants, as well as
other factors, a reliable detailed evaluation of population risk could not be made.
Moreover, the main goal of IEER's work was compliance assessment rather than
population risk assessment,

In August 1996, the Radiological Assessments. Corporation made public its estimates
of exposures to various hypothetical individuals in scenarios designed to typify
living and working patterns of people in the area. The findings were that radon
exposures due to huge releases of radon gas from the K-65 silos were the main
source of increased radiation risk to the population, especially for people who lived
there prior to 1980. It is noteworthy that radon was not even evaluated as a source of.
pollution caused by the Fernald plant until the series of RAC studies in the 1990s.
Radon probably also caused significant exposures to workers at the plant, a matter
that remains to be‘addressed (see accompanying article otf workers}.

Doses due to uranium exposure by inhalation were the next most important factor,
with other radioactive materials and pathways being judged relatively low. The
table, "Comparison of Cumulative Effective Dose Contributions from Uranium
Exposure Mode and Radon Decay Products" in the centerfold shows the exposures
for various scenarios as calculated by RAC. The increased risk of cancer ( especially
lung cancer ( are substantial in all cases. In many cases, they are comparable to the
tisks from smoking.

Concluding observations

The history of studies of exposure to Fernald’s neighbors show that the reassurances
of the DOE and its contractors -—- that the nuclear weapons plants were operated
safely and in compliance with applicable health and safety laws and regulations —
should not be taken at face value. The work of EER, RAC, and others at other
nuclear weapons plants indicates that DOE and contractor estimates of releases of
radioactive materials are generally underestimates, and are riddled with faulty data,


D4
DS
bE

D7

Apt # P.O. Box

Telephone Number of Petition Representative: (__
Email Address of Petition Representative:

Zip Code
d -

Farlod during which labor organization represented employees covered by this petition

(please attach documentation): Start

Monty of other bor engentzatione tat way romecontor have represented this class of

employees (if known):

—
Go to Part E.

Name or Social Security Number of First Petitioner: ,



have the lowest worker doses.

2) IEER's study also found evidence that plant authorities and the Atomic
Energy Commission (AEC), which contracted with these private companies
to process material for its nuclear weapons program, were aware that workers
at these plants were being overexposed over prolonged periods of time.
Furthermore, there is no indication that the authorities shared this
overexposure information with the plant workers. In fact, there are
documents that indicate that plant authorities and AEC personnel lied to the
workers about the levels of radiation to which they were being exposed. For
example, in a January 1948 letter to the Vice President of Harshaw Chemical
Co., Harshaw's Medical Manager wrote: "...it is obvious that concentrations
considerably above the preferred level are common in Area C." (Area C is an.
area in the Harshaw plant.) He also wrote, ”...a distinct hazard does exist in
Area C." In the same letter he states that the Medical office "still believes"
that the “logical method of approach” is to continue telling the employees at
Area C "that all of our records indicated that no unusual hazard existed..."

3) One of the most surprising outcomes of our findings is that they call into
question whether the doses to these workers were less than their Soviet
counterparts. Until now, we have assumed, based on available evidence, that
worker exposures were far higher in the Soviet Union than in the United
States. But the partial estimates that we have made in this study are so high
that this assumption may need to be revisited for many of the workers at
these nuclear weapons plants. A comparative evaluation of US and Soviet
nuclear materials processing plants of that era should be done.

Femald Worker Study

In 1994, IEER performed a study of worker doses at the Feed Materials
Production Center, located in Fernald, Ohio, near Cincinnati. The Femald
_plant is similar to the three facilities that IEER analyzed for USA Today in
that uranium processing took place there. This study was completed as part
of expert testimony in a class action lawsuit filed by Fernald workers against
National Lead of Ohio, the Department of Energy's contractor there until
1985. The aim of the study was to examine whether then-prevailing dose
limits had been violated. This study was, to our knowledge, the first
independent assessment of internal radiation doses based on raw data from
official DOE and contractor records of the workers. We are submitting this
study and request that it be part of the record.

Til describe 2 findings of IEER's Fernald worker study:

J) Similar to the 3 aforementioned facilities, IEER found that the working
conditions at the Fernald uranium processing plant were appalling, especially
in the 1950s and early 1960s. They were typified by high air concentrations
of uranium in many areas of the plant. They often exceeded the Maximum
Allowable Concentration (MAC) by tens, hundreds, even thousands of times.
One 1960 plant document lists the air dust concentration in the breathing
zone of a worker cleaning under a certain piece of equipment as 97,000 times

PEI789


le e f INSTITUTE FOR ENE

Written Testimony for the Subcommittee on Immigration and
. Claims,

Committee on the Judiciary, U.S. House of Representatives

_ Delivered by Lisa Ledwidge, Outreach Coordinator and Editor of Science for Democratic
Action,
Institute for Energy and Environmental Research
Tepreseating

Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research

September 21, 2000

My name is Lisa Ledwidge. I am the Outreach Coordinator of the Institute
for Energy and Environmental Research and editor of its quarterly newsletter
Science for Democratic Action. TEER is a non-profit technical institute that
provides the public and policy-makers with thoughtful, clear, and sound
scientific and technical studies on a wide range of issues. Our aim is to bring
scientific excellence to public policy issues to promote the democratization
of science and 2 healthier environment.

My education includes Masters' degrees in environmental science and public
affairs, and a Bachelor of Science in Biology. 1 am here representing Arjun.
Makhijani, the president of IEER, who is away. Dr. Makhijani, as well as his
colleague Bernd Franke, are among the authors of the studies and articles that
I will be discussing in this testimony, and have worked in the radiation and
health field for about 20 years each.

I prepared this testimony under Dr. Makhijani's guidance. You may have
questions that I am not able answer here. I that case, I or other IEER staff
will provide answers to the subcommittee for the record as soon as possible
Dr. Makhijani and I appreciate this opportunity to present some of the
findings of the work of the Institute for Energy and Environmental Research
before you.

I will be discussing 3 IEER studies of nuclear worker exposures and off-site
radiation releases. I will conclude with recommendations.

USA Today Study


oa

In many plant situations, proper respiratory protection to prevent inhalation of this
radioactive dust was not available. IEER's review revealed that workers were not properly
trained regarding when to use respirators, and consequently did not wear them in many
situations when air dust concentrations were high. In fact, in the early years of plant
operation, workers were not even issued respirators as long as air concentrations of
radioactivity remained less than ten times the MAC. In addition, a significant number of
respirators cleaned for reissue remained contaminated. In some cases, the insides of
respirétors were contaminated. A plant doctor on an impromptu plant tour characterized

some of the respirators as “the epitome of filth."+
Internal exposure estimates

Fernald worker dose records are highly misleading because they contain no mention of
notably their lungs. These doses were not included in worker records despite the urine
sampling that was done throughout the plant's history and the lung counting that was done
after 1968. Thus, when workers requested dose records, they were only given information on
external doses (see below).

The urinalysis program used at the Fernald plant bad several shortcomings. Twenty-four
hour urine samples provide a good indication of how much uranium is in a person's bedy.
However, 24-hour samples were not regularly taken at Fernald. Instead, the program relied
on "Monday morning" single samples. It was not recorded which workers drank coffee and
therefore possibly diluted their urine samples.

Another problem with the program was the infrequency of the samples, especially in the
early years of plant operation. After uranium is inhaled, it is excreted from the body in
diminishing amounts over a period of time. The amount of time it takes for an inhaled
material to be excreted depends on its chemical form. When samples are taken only every
few months or even just once a year, as they were in early years of Femald operations, it is
possible for large exposures to go undetected. As a result, infrequent monitoring makes it

impossible to accurately determine the magnitude of the exposure.

TEER developed a method to estimate radiation doses to the lung from urine data by
calibrating that data to the direct lung count data that was available after 1968. The concept
was developed by Bernd Franke in collaboration with an IEER consultant, Mike Throne,
who also created the mathematical formulation of the method. Kevin Gumey wrote the
computer program to manage the enormous volume of data and run it through the
mathematical model.

IEER's conclusions were that doses due to uranium inhaled by workers were above then-
allowable limits (15 rem per year) in more than fifty percent of the cases in every year but
one between 1952 and 1962. Significant proportions of workers continued to suffer
overexposure after that. A chart of the proportion of workers exposed to more than the
allowable limits due to lung burdens of uranium is shown below.



PE 3658
PE 366
PE 367
PE 124
PE 368

PE 369
NA85
WEST

Plant 6. [6468 MAC in 1952-154 MAC in 1953.}
High Dust Exposure (March,1963). [608 MAC-nothing in progress to

improve.

Plant 6. [1SOMAC.}

Plant 7 Urine Sampling Program

Labor Pool Operations. [Up to 1100 NCG.]

Plant 8 Thorium Reverter

Plant 8.

Plant 8

Plant 8. [89.5% of the personnel are exceeding the desired MAC.]

Plant 8. [0.9 NCG in 1965—2.2 NCG in 1966.]

Plant 8. [Stack filter loaded with material.]

Chip Furnace. [Contamination.]

Comparable Weighted Exposure of Plant 9 Personnel. {685 MAC high.]
Removing Mortar and Bricks. {Done twice a week.][958 MAC]

Rough Grinder Operator

Development Machine Shop

Laboratory. [729 MAC.]

Laboratory Bldg.

Sample Preparation Room. [20 MAC.]

Q-11 to Temporary Hopper

Meeting to Discuss Pit Area Dust Control

Contaminated Industrial Vehicles

Vehicle Contamination Survey Results.

Industrial Truck Operator Job Assignment

Transfer of K-65 from Deteriorated to Solid Drums

Cleaning Subcontract Laundry Area. [Working in street clothes, Told they
‘weren't contaminated}

Master Painters. [Overexposed.] ;
Task Force on Recycle Material Processing. [No Plutonium accountability.]
POOS History and Risk Assessment.

INDEX Section 8. Radiation Hazards/ Reference F1 SEC Petition.

PE 555
NA~

What NLO Knew About Radiation in 1950’s
Radiation Hazards at Fernald. [3290296-3290305.]


after they were brought into use, for example in. 1968 at Fernald, urine
measurements continued to be the main method for monitoring internal dose.

Unfortunately, the monitoring procedure adopted by the DOE and its
contractors was flawed. IEER's analysis of Fernald dose records in 1985
revealed the following problems: .

© The lung burden inferred from urine data was consistently
underestimated because of improper assumptions about the ratio of
urinary excretion per unit of uranium lodged in lung tissues.

Urine was not monitored for all radionuclides.

¢ Urine monitoring was generally too infrequent to allow for accurate
chemical forms of radionuclides are excreted relatively rapidly,
infrequent monitoring was likely to miss doses from accidents and
other occasional but high exposures. Further, in many cases, urine
measurements were so infrequent that even chemical forms with
relatively long biological half-lives would not have been accurately
detected. As a result, low urine concentrations may not have
corresponded to low exposure, but merely to a long time lapse between
the intake of the radionuclide and the taking of urine samples (or lung
counts).

The solubility of the compound inhaled or ingested was not determined
or, if known, was not recorded.

© The relationship of urine sampling time to exposure was, in most
cases, unknown.

As a result of all these factors, the assumption that the dose was below
allowable limits if the concentration of a radionuclide in urine was below the
action level was scientifically unsound. Even when the actual doses were
below allowable limits, the internal doses should have been entered into
worker dose records and added to external doses in appropriate ways.

Whole-Body and Organ-Specific Doses

Radiation standards limit dose both to specific organs as well as to the whole
body. Consider, for example, doses to the lung. The lung may be exposed by
external gamma radiation from sources outside the body, resulting in doses
essentially equal to those for other organs in the body. It may also be exposed
from inhaled radionuclides. In order to ensure compliance with the lung dose
limit, which was 15 rem in the 1950s through 1980s, DOE and its contractors
only had to consider internal body burdens of radionuclides. (However, as we
have indicated, before 1989 internal doses were not calculated from these
data.) In most cases, such as at the Fernald plant, lung doses were inferred
from measurements of uranium in urine. If these were found to be below
allowable concentrations, compliance with the 15 rem/year limit was



uranium processing operations at Fernald.

FIGURE 1: Uranium Processing at the Fernald Plant

(Operating dates:

G54 t0 56) i
{ ‘Voilleqné ot al., Fernakd Dosimetry Reconstruction Project, Tasks 2 und 3; Redsonuctide Source Tenens anc
j Uncertatatios (Necss, SC: Radkalogical Assessments Corporation, 1995}, p. B-2 .

L

Source: Voilleque et al., Fernald Dosimetry Reconstruction Project, Tasks 2 and 3: Radionuclide
Source Terms and Uncertainties (Neeses, SC: Radiological Assessments Corporation, 1995), p. B-2.

Throughout the history of the plant's operation the DOE and its contractors
consistently asserted that the offsite residents were not harmed by its operation and
‘were within.allowable limits. These assertions-were challenged in a.

. thatexposures. I
1985 class-action lawsuit brought against NLO by neighbors of the plant. In that

year, Lisa Crawford, the lead plaintiff, had discovered that the well that she and her
family had been using for drinking water was contaminated with uranium. She also
found out that the DOE and NLO had discovered the contamination four years
earlier but had not informed her. Ms. Crawford realized her well was contaminated
after she requested monitoring data in the aftermath of a highly publicized accidental
uranium release from the plant in late 1984.

The Fernald plant had, in fact, released a number of radioactive and non-radioactive
pollutants to the air and water, but DOE had very partial data for some of these
materials, and none at all for many others. Among the pollutants were: uranium,
thorium, radon gas, radium, technetium-99, ammonia, hydrofluoric acid, fluorine,
nitric acid, kerosene, chromium, and Jead. The most important radioactive pollution
consisted of releases of uranium and radon gas to the air. Detailed evaluations of
non-radioactive pollutant releases have not yet been done and few data exist on
which such evaluations can be based.

Uranium releases


Plant 5, the metal production plant. Chemical conversion of UF4 powder to
uranium metal derby by a thermite furnace reduction process with magnesium metal.

Plant 6, the metal fabrication plant, began operations in 1953. Uranium metal
fires were common and resulted in airbome uranium concentrations

Plant 7, hexafluoride reduction plant, operated from 1954 to 1957. Provided UF4
by reducing UF6.

Plant 8, scrap recovery, began in 1954. Scrap recovery of uranium and was
ranked in the higher air activity level at the site. Thorium scrap and residue was
processed in 1966, 1969, 1970, and 1971.

Plant 9, special products, began in 1953. Cast uranium metal and high purity
recycled metal scraps into ingots. Thorium was processed as metal and briquettes in 1954
and 1955.

5.2.1.1 Uranium Enrichment. First production in 1964.

The following production years uranium was processed in a variety of
enrichments ranging from depleted to as high as 20%.

Quantities of enriched material above 2% was not documented but was
qualitatively reported to be small and/or insignificant in total mass.

Table 5-3 Uranium enrichments and associated i isotopes.

g a default assumptions for time period

after 1964 is 2% enrichment for bioassay data in milligram quantities of uranium. Prior
to 1964 natural uranium should be assumed.

5.2.1.2 Chemical forms and compounds. There are approximately seven steps
in the process of conversion of uranium ore or other scrap recovery material to metallic

Table ‘od identifies the uranium chemical forms at Fernald.
Most of the compounds were dry or granular in form and represented a dust
hazard potential as the material was processed, transferred and otherwise handled.

5.2.1.3 Airborne dust potential. Production operations that involved handling
dry uranium materials were generally equipped with engineered ventilation systems for
controlling dust.

Standard operation procedures required the use of respiratory equipment when
dusty conditions were anticipated. Good housekeeping involved the immediate cleanup
of spilled uranium products was also a standing policy and practice.

: There were frequent ‘upset’ conditions (spills, filter ruptures, etc.) that produced.
episodic airbome activity of the magnitude that the ventilation systems were unable to
contain alt the releases.


U.S. Department of Health and Human Services
Centers for Disease Control and Prevention

OMB Number: 0920-0639 Expires: 8/51/2007

severe 5 teen sea Middle Initial” Last Name

B.2 Soclal Security Number of Survivor:
B.3 Address of Survivor:

Att P.O, Box

cry orate 7in Code
B.4 Telephone Number of Survivor:
B.S Email Address of Survivor:

B.6 Relationship to Employee: Q Parent

labor or

Complete $

C.1 Name of Emnlavaa:

RERUNS. CSE NETTIE miaaie inmat Last Name
C.2 Former Name of Employee (e.g., maiden name/legal name change/other):

Mr./MrsJ/Ms. First Name Middle initial Last Name
©.3 Social Security Number of Employee:
C4 Address of Employee {if living):

Neceased
: SSG

Street P.O. Box’

City State Zip Code
C.5 Telephone Number of Employee: ( ) =
C.6 Email Address of Employee:

C.7 Employment Information Related to Petition:
C.7a Employee Number (if known):

C.7b Dates of Employment: Start 252. End 763
C.7c¢ EmplyerName: National Lead of Onin

C.7d_ Work Site Location:

CEMPC ) Evernald, Ghio
C.7e Supervisors Name: N&

Go to Part E.

Name or Social Security Number of First Petitioner: _. ——


s.

il.

13.

=

If the data requested in 81 oF 82 can be provided for sone workers
put not for others, please explain the reasons for the differences
and provide datz Similar to 83. 84, and 85 for each category.
available for some bot ot all present snd former suplovact ais
Date cole, entire employsest petiod is ususily sot covered. Complete
a

7 4
would include about 250 workers~_ {Continued at bottom of page)
to short-lived: emitters, such as 2h

125;

Lo how is this data recorded and how is the dose integrated into

an annual dose?
B/R

Does your facility include tnternally deposited ragtonuct ides. for
which the whole body is the critical organ, €.9-» “H, into the whol:

body penetrating cose category?
Yes

x Ne

If the answer to question 89 is Yes, how do you indicate that such
an addition has been made (e.g., do you have a separate category fc
jnternal emitters)? . —_— 2 Me eee

5

Which radionuclides do you include in the whole body penetrating
dese category?

BA.

9. Continued:


LT TEN IE OTT

TESTIMONY OF DANIEL J. ARTHUR
Before

@ THE SUBCOMMITTEE ON
ENERGY, CONSERVATION & POWER

August 12, 1986

2643277 3128764


6.3.1 Site History
Some of the raw ores contained considerable amounts of radium that Jater became

Table 6-2 lists the quantities of recycled materials along with radionuclides and
their sources from key shipping sites.
The radiological properties of thorium are different than those of uranium since it
has higher energy gamma favs and a shorter time to re-establish equilibrium with its

daughters after processing.

Note: The workers in areas where thorium processes were not known to exist would not
have doses attributed to them for this beta exposure potential. The TBD does not
differentiate metering for uranium vs. metering for thorium.

{ The table also indicates years of uncertainty.}

pg? During these periods dose or exposure limits changed with the lowering of
limits as more knowledge was gained with respect to radiation protection practices.
pgl0 While current minimum detection limits (MDLs) are well defined, earlier
limits were not. Since it is difficult to estimate MDLs
the values provided in this TBD are those given for the analogous ORNL system..
Important dose reconstruction parameters for FEMP workers are based on
administrative practices.

6.3.2 Site Dosimetry Technology.
FEMP followed the ORNL program for dosimeter design and calibration.

‘There was.no neutron dosimetry at FEMP.
Extremity dosimetry involved the use of wrist rather than finger dosimeters. A
correction factor was applied to the wrist dosimeter value to estimate dose to extremity.

However, it was not a particularly accurate practice,

Note: Extremity dosimetry is mentioned but the dates of implementation are not
indicated. I have a copy of a clothing issue record for my father, it indicates no gloves
were issued even though he routinely handled uranium metal for testing. His records
show he was not monitored for hand exposure during almost 12 years of employment.

After reviewing the tables in this TBD it is possible to determine that the
preponderance of the radiation consists of beta particles and while this form of radiation
can deliver substantial dose to bare skin in proximity it does not penetrate deeply into the
body.

Note: Scientific documents state that high energy beta particles can penetrate the skin up
to 1 inch in depth. If it enters veins or arteries near the skin’s surface, the particles could
be transported via the bloodstream.


‘Special Exposure Cohort Petition U.S. Department of Health and Human Services.
under the Enesgy Employees Occupational Centers for Disease Control and Prevention
Mines Compensation Act Nationa nfte for Oocupationel Safety ane oath

xa structions on Gonsieting thie Form (compote hebutions are avaliable in a soparate packed):

Except for signatures, please PRINT all information clearly and neatly on the form.

Please read each of Parts A— G in this form and complete the parts appropriate to you. {f there is more
then each petitioner should complete those sections of parts A — C of the form that apply

‘than one petitioner,
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-
pose. A maximum of three petitioners is allowed.

fo n, use the continuation page provided at the end of
the form and atach the completed continuation page(s) to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and

request to speak to someone in the Office of Compensation Analysis and Support about an SEC petition:
1-800-356-4674.

(A Labor Organization, Start atD on Page 3
you Q An Energy Emptoyee (current or former), StartatC on Page2
are: DSi cuntor a ornar Envy Empives Start atB on Page 2

OA Representative (of a current or former Eneray Employee), StartatA on Page1

1 Empieyee or

‘Are you 2 contact person for an organization? O Yes (Go to A.2) Q No (Go to A.3)
A.2 Organization information:

Name of Organization

Position of Contact Person
A3 Name of Petition Representative:

Mr/MrsJMs. First Name Middle Initial Last Name

A4 = Address:
Street Apt # P.O, Box
City State Zip Code

A5 Telephone Number: ( ) =
A& Email Address:

AT @ Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

if you are representing a Survivor, go to Part B; if you are representing an Employee, go to Part C.

Name or Social Security Number of First Petitioner: _{


38. I never saw any DOE personnel, except at the T-Hopper
meeting, and they aid not come in to look at the audits. To my
knowledge, the audits that I performed did not make it to DOE.

As the lead auditor, I would have expected some communication

from the owner of the facility.

39. In conclusion, I can hardly blame a corporation like
Westinghouse for attempting to maximize production. I
understand that their award fee depends upon keeping up their
end. It is DOE, the regulator, which is supposed to oversee
these contractors and assure that the worker's health and safety
and the environment is protected. Instead, DOE itself has a
built-in conflict. It too is responsible for maintaining

production goals. When the inevitable clash between maintaining

production and protecting human safety occurs, it is clear that

production, at least at Fernald, has won out. The quality

assurance program at Fernald is in itself a mini~model.of the -
whole system of nuclear weapons production, Quality concerns

that serve the function of protecting human health and safety are
controlled by a management that has to worry about the ledger
sheet. The entire quality assurance system is simply advisory - —

~it has no real power, no real independence.

16

3128776


These underestimates were largely due to scientific flaws in the estimates and
in the way in which the records were kept and the measurements were made
(er not made). For exampie, for a number of years, many entries showed zero
releases when no measurements had actually been made, As another
example, the plant made an assumption that scrubbers, designed to remove
specified efficiency, despite internal plant date to the contrary. The formula
used by the contractor to calculate releases from the scrubber was wrong
under conditions of variable efficiency and resulted in high release estimates
when actual releases were low and low release estimates when actual releases
were high. Moreover, this method was known to plant officials to be wrong,
since it was described in a 1971 plant document as “inherently deceptive."

The DOE, which defended the lawsuit on bebaif of the contractor, National
Lead of Ohio, settled the suit for $78 million in mid-1989, but admitted no
-wrong-doing or even any technical problems in its own or its contractors
work. (Under the terms of its contract with the government, National Lead of
Ohio was immune from all liability, including that arising from negligence or
violations of regulations.)

These two Femald studies are summarized in TEER's newsletter from
October 1996, which I am submitting for the record. Information on the
serious flaws in Department of Energy worker data is described in the
November 1997 issue of Science for Democratic Action, which I am also
submitting for the committee's record.

In conclusion, TEER has found that when worker exposures and off-site
releases are carefully and independently studied, the results indicate that
worker overexposure and environmental releases of radioactivity are larger
than officially acknowledged. These, as well as other, similar findings over
the past several years have been important pieces leading up to the official

* arinownvertient that was tiade in’ April by Energy Secietary Bilt Richardsori

after decades of denial by the US government —~ that the production of
nuclear weapons has harmed workers.

I wilt conclude with 3 recommendations for your consideration:

1, First, health monitoring, treatment, and where appropriate
compensation of the affected workers, is an urgent priority because
many are very sick and dying. Practical recognition of the role of the
government and its contractors in their suffering is long overdue.

2. It is important to not force workers to prove their exposure to the last
decimal point. The burden of proof should be on the government and
its contractors, which failed to keep good records, failed to make
sufficient measurements, and all too often assured workers of their
safety when conditions were unsafe. Where there are large
uncertainties due to lack of sound data, the benefit of the doubt should
be given to the sick workers,


all
‘ay "

QUESTIONNAIRE ON RADIATION RECORDKEEPING SYSTEMS
AT DOE/DOE CONTRACTOR FACILITIES

oe

0036454


United States General Accounting Office

Testimony

Before the Subcommittee on Oversight and Investigations,
Committee on Energy and Commerce, House of
Representatives

For Release on Delivery
Expected at
16:00a.m. EST

‘Thursday
March 17, 1994

HEALTH AND SAFETY

Protecting Department
of Energy Workers’ Health
and Safety

Statement of Jim Wells, Associate Director,
Energy and Science Issues,

Resources, Community, and Economic
Development Division

GAOST-RCEN-94.143


32. Later that day my supervisors called me to a meeting to
discuss my overtime. I told them that I could handle only five
to eight hours a week because I was not feeling well. I was told
by them that that was not enough to get the plutonium project
completed. At that time Mr. Grumski accused me of not putting
out the effort needed to complete the procedures. I responded:
"In the last four weeks I have worked 49 hours cf overtime to
complete the T-Hopper investigation and work on Poos. procedures.”
The meeting then ended.

33. I was ill again on March 6 and 7 (Thursday and Friday) and I
called Mr. Weichold to say that I was too sick to come in, that I
was on medication, and that I would probably not be_in on Friday.
I returned to work Monday, March 10, and on Wednesday, March 12,

I was given a letter from Mr. Grumski. The letter was a
reprimand that questioned my commitment to the plutonium program

and put the future of my career with the company in doubt. I

‘realized at this point that Westinghouse was beginning to build a

paper trail in preparation for firing me. The time sheets
provided by the company were not entirely accurate. They left
out certain periods of overtime and put in a period that: they

claimed was not included. I was outraged.

14

3128771


63.5.2 Workplace Neuron Radiation Fields
To date, specific neutron energy spectra of UF4 has not been located or modeled.

65 Adjustments to Recorded Dose.
Corrections to the FEMP reported dose are required due to uncertainties in the
recorded data and lack of significant data especially prior to 1980.

Note; I was under the impression that adjustments in dose were necessary solely for the
purpose of adaptation to the IREP software used to determine the probability of
causation.

6.61 Missed Beta/Photon Dose

It can be assumed with some certainty that there have been missed doses in the
recorded doses for FEMP workers. Missed dose from MDLs is especially important then.
there are short exchange periods, generally through the 1950s and 1960s. That period
also had higher MDLs,

6.6.2 Missed Neutron Dose.
It is not known for certain how the neutron dosimeters used by Baker (1995) were
calibrated.

6.6.3 Missed Dose for Unmonitored Workers
Female workers at FEMP were not routinely monitored. (500mrem per year will
be assigned as an upper bound.)

6.7 Organ Dose
Worker orientation is a primary consideration for this process; howevet no
definite method is available to evaluate this factor.

68 Bias and Uncertainty
No information was identified to address the uncertainties in the positive recorded
photon dose for FEMP workers during the years that film dosimeters were used..


eS ir

LEER ES LACS,

e 34. The next day, Thursday, March 13, 1986, after Seeing my
physician during a scheduled appointment, I was admitted to the
University Hospital for tests. My physician suspected that a
tumor was causing the problems. I was released from the hospital
Sunday, March 16, 1986, after an extensive series of tests. The
doctors concluded that I was worn out from anxiety, stress, and
fatigue. At that point, I decided that my health and the health
of my fellow workers was more important than helping Westinghouse

ram through a possibly dangerous program, and I resigned.

35. I felt as if a great pressure had been lifted from me. I
resolved to do something about what I had seen.. It was clear to
me that it was going to be business as usual at Fernald, and that

. e the change of contractors was purely a cosmetic move. Production
concerns were going to continue to take precedence over

environmental, health and safety concerns.

me .: 36. While Westinghouse's assertion that it "was a whole new ball
game" at Fernald may be true, it was the same umpires calling the

shots ~- ~ DOE, the Department of Energy. —_

37. Over the two years that I worked at Fernald, no one with the
audit department and QA department except the QA Manager, Mr.
Tippenhauer, ever saw or met with a DOE representative. To my
knowledge, a DOE representative never audited our procedures, or
set foot in our office, even though our department was in

charge of upkeep of all procedures. DOE had a very low profile

eS at Fernald.

15

3128778


PE 5272
PE 5358
PE 560
PE 720a
PE 744r
PE 745s
PE 745y

PE 745¢g

Standard for Thorium 230. [Don’t want to abide by DOE .]
Letter. [Continue to use workers for cancer research.]
Letter. [Non-soluble uranium compounds.}

‘Weekly report. {Happy/ no overexposures.]

Monthly report. [Black oxide mistaken for soot/ sewer.][No notice of
incident.]

PE 74Seee Monthly report. [Contaminated gloves. }[254lbs, uranium/ via the sewer.]

PE 747
PE 782
PE 793
PE 900

PES9I7
NA—

Trial Affidavit. [Air monitoring practices.]

Proposed Record System. [Oppose uniformity in record keeping.]
Random Thoughts on Uranium.

“A Continued Program of Analysis for Uranium in Human and Animal
Tissue’. [Autopsy agreement.]

Letter. [Possible autopsy study.]

Dosimetry Assessment Fact Sheet. [3455935-3455940.]

INDEX Section 5. Thorium Processes

PE 527b
PE 547b
PE 536

PE 534
‘PE SOL
PE 547a
PE 543h
PE 543f
PE 541
PE 537¢
PE 135

Intemal Radiation Levels from Uranium and Thorium.(1955)
Thorium Inventory. [Almost 350 tons.}(1961)
Authorization to Remove Thorium Residues from Inventory to Burial

Ground. [9,747!bs. to Morehead, Ky] (1968)

Thorium NCG. [FMPC decides.] (July,1964)

Health Protection Aspects of Thorium Production.

Radiation Levels of More Than 0.05% Thorium Residues (Oct.,1958)

Air Dust Concentrations in the Pilot Plant Thorium Process (1970)

Air Dust Levels at Thorium Metal Operations. (1970)

Monthly Thorium Inventory Position at NLO as of August 1, 1978
Thorium Processing at FMPC. (1970)

Annual Storage Inventory of Normal Uranium Concentrates and Thorium.
[Leaks.](June,1968)

Thorium Metal Production Housekeeping.(1970)

Ventilation for Redrumming of Thorium Residues. [Corrosion.] (1965)
Thorium Operations at NLO - Present and Future (April,1963)
Thorium Operations - Pilot Plant (July, 1964). [BeO.]

BeO Air Dust Evaluation of Plasma Flame Spray Facility.(Sept.,1966)


3 2

Scrubber ubber effciency %

an

A 1955 document pointed to early problems with uranium release estimates: "We
realize in most instances that these estimates [for stack losses from plants 4 and 7}
are far below your true stack losses."” Plant 7 was shut down in 1956 due to
operational problems. Plant 4 continued to operate until Fernald shut down, and the
problem of corrosion of dust collector equipment by acidic exhaust continued for
decades.

The following example also illustrates the poor industrial hygiene practices at the
plant;

Probably the worst housekeeping problem in the facility is the Bal] Mill. The
equipment leaks excessively at practically every joint. All horizontal surfaces have a
thick covering of dust....Since the ventilation is inadequate and these is no proper

enclosure, a bucket was placed under the largest leak to help contain the spilled dust?

Such discharges of radioactive materials were not measured and were disregarded in
the official release estimates and public reassurances.

Under the glare of public scrutiny and the class-action lawsuit, Westinghouse, the
new contractor (and not named as a defendant), revised the official figures for the
1951-1985 period again and stated that the releases were in the range of 395,000 to
552,000 pounds. While these estimates were higher, they still disregarded many
known facts. For instance, unmeasured losses over the plant's entire 37-year history
were estimated at about 700 pounds, while an internal plant document stated that
unmeasured losses were more than that in a single month.

During work on the lawsuit in 1988 and 1989, IEER focused its work on estimating
uranium losses, since that was the main material processed and data on other


STATEMENT OF DANIEL 3. ARTHUR

i. My name is Daniel J. Arthur and I would like to thank the
Subcommittee for the opportunity to testify today. I understand
that I am limited in my time for testimony, and unfortunately, ny
story is very long. I would like to submit for the record my
affidavit and supporting exhibits so that the record is complete.

2. I intend to detail my experiences while I was a Methods
Analyst/Lead Auditor at the Department of Energy's Feed Materials
Production Center located near Fernald, Ohie. I am dismayed and
outraged at how the United States government allowed this uranium
reprocessing facility, so vital to our nation's defense, to
degrade into a major polluter that is threatening the lives and
well-being of Fernald's workers and neighbors. I hope to
persuade the government to recognize not only the immensity of
the problems facing Fernald, but their root causes as well. In
short, it is my belief ‘that the u-s. Department of Energy has
placed production over environmental and health and safety
concerns, and in so doing has needlessly jeopardized human lives.
The U.S. government has created a toxic and radioactive hazard
whose legacy will be feit in health and economic impacts far into
the future. I hope te contribute to an understanding of why and
how this situation has come to be, and I look to Congress

to rectify this mess.

3128765


There also is limited understanding about the health effects of exposure
to chemicals used in nuclear weapons production. Examples include
fluorine gas, carbon tetrachloride, tricloroethylene (TCE), hydroftuoric
acid, nitric acid, chlorine trifluoride, and beryllium. According to the
Agency for Toxic Substances and Diseases Registry, high exposures to
these substances, which might be expected for at least some workers,

some cases death. Exposure to toxic substances could also aggravate
the health effects of radiation exposure (and vice versa) yet there is
little or no research on the possible synergisms.

3. A process should be created for fairly and responsibly addressing the
Cold War health legacy. There is a lot of information out there about
the harm to human health and the environment from nuclear weapons
production, and this is typical of all nuclear weapons states. To its
credit, the United States so far has been more forthcoming about this
problem, but problems continue to fester and many are still coming to
light in a haphazard fashion, through efforts of public interest groups,
media stories, congressional investigations, and lawsuits, Workers
should be centrally involved in creating this process, because they
were, on the whole, the most exposed group of people. But it should be
acknowledged that non-workers were also exposed, including workers’
family members, downwinders, those downstream, and other
neighbors. The process for deciding how community exposures can be
fairly and responsibly addressed, without the anguish and expense of
lawsuits like the one at Fernald, should begin.

Attachments

« Slide #1; Estimated Cumulative Lung Doses at Harshaw for Different
Multiples of Maximum Allowable Air Concentration and Differing
Times of Exposure

Slide #2: Percent of workers with an Inferred Annual, Average
Uranium Lung Burden Corresponding to a Lung Dose of 15 Rem or

More (Fernald)

« Slide #3: Worker Sitting on Depleted Uranium Metal Ingot
(Photograph by Robert Del Tredici)

Slide #4: Summary of Estimates of Uranium Releases (Fernald)
Supporting documents

« Arjun Makhijani, Bernd Franke and Hisham Zerriffi, Preliminary
Partial Dose Estimates from the Processing of Nuclear Materials at
Three Plants during the 1940s and 1950s. Prepared by the Institute for
Energy and Environmental Research under contract to USA TODAY,
6 September 2000.



“4

ae

IEER
ST

@ WA VLENe2
Worker Radiation Dose Records Deeply Flawed
By: Arjun Makhijani and Berd Franke

As part of its responsibility for the production and testing of nuclear
weapons, the Department of Energy (DOE) and its predecessor agencies (the
Atomic Energy Commission, 1947 -1974; and the Energy Research and
Development Administration, 1974-1977) have been responsible for ensuring
that workers were not exposed to more than the allowable amounts of
radiation. The DOE has also been responsible to adhere to what is called the
"ALARA’ principle -- the idea that radiation exposures should be kept "As
Low As Reasonably Achievable" with available technology.

The goal of setting radiation dose limits and following the ALARA guideline
is to protect worker health by limiting exposure. But if exposure is not
properly measured, radiation exposure regulations cannot be enforced, nor
can guidelines be followed. Health monitoring personnel may not be aware
of instances when workers are overexposed. Diseases that workers may be at
greater risk of contracting may go undetected, harming them and their
e@ families. Health studies based on worker dose data would produce

is ing results because dose records would be incomplete and knowledge

of doses would be inaccurate.

From the beginning of the nuclear era until 1989, radiation doses from
radioactive materials inhaled or ingested by workers were not calculated
orincluded in. worker dose.records, This was revealed by DOE ina. .
background paper sent to IEER on April 7, 1997.! DOE and its predecessor
agencies did make measurements of intemal exposure to radioactive
materials, though often sporadic (see below), mainly by taking urine samples.
After the mid-to-late 1960s, there was also selective use of more
sophisticated counters that directly measure radionuclides in workers’ bodies.
The DOE was not required by regulations to calculate worker doses, but only
to keep records of whether workers were internally exposed to more than
certain amounts of radionuclides,

The lack of historical internal dose data in worker dose records has important
consequences for public policy on health issues, for scientific investigations
of radiation risk, and most of all for the more than half-a-million workers
(and their families) who have been involved since the Manhattan Project in
making and testing US nuclear warheads. In 1989, DOE began to correct this
historical problem by initiating a program of integrating internal and external
worker doses.

Exposure Limits


BEST COPY AVAILABLE

AFFIDAVIT OF DANIEL 3. ARTHUR

My name is Daniel 3. Arthur and I an submitting this
affidavit freely and voluntarily to Tom Carpenter of the
Government Accountability Project. I am 24 years old,

and currently reside in cin

4, Chic. <I am subnitting this
sworn statement to detail my exceriences while I was a Metheds
Analyst/Lead Auditor at the Department of Energy's Feed Materials
Preduction Center (hereinafter, "Fernald") located near Fernald,
Ohio. Through this statement, I hope to express my feelings of
disgust and outrage at how the United States government allowed
this uranium reprocessing facility, so vital to our nation's
defense, to degrade into a major polluter that is threatening the
lives and well-being of Fernald's workers and neighbors. Through
this statement, I hope te persuade the government to recognize
not only the immensity of the problems facing Fernald, but their
-ceot causes. as. well. In short, it is ny ‘belief that the'v.s.'
Department of Energy has placed production over environmental

and health and safety concerns, and in so doing has needlessly
jeopardized human lives. The U.S. government has created a toxic
and radioactive hazard whose legacy will be felt in health and ~
economic impacts far into the future. I hope to contribute to PP
understanding of why and how this situation has come to be, and I

look to Congress to rectify this mess.

37]
3128781


Based on my review of the NIOSH Site Profile, I submit the
of statements and paraphrases, based on the Document No. ORAUT-TKBS-0017, A
Technical Basis Document for the Fernald Environmental Management Project (FEMP),
It will demonstrate limitations in data and information available for dose reconsiraction
and provide a glimpse of the workplace, as stated by the ORAU Team. I have also
included some personal notes.

Section 5-Occupational Internal Dose

‘This TBD provides information and assumptions for use in reconstructing
Seer een dh ideatibine nee 1) outining specie dewasisinics tS)
{dentifying types and quantities of radioactive materials involved, 4) evaluating
production processes and safety procedures, 5) identifying locations and activities of
exposed individuals, 6) identifying comparable exposure circumstances for which data is
available on which to base assumptions.

5.1 The information provided includes: operational documentation and
professional judgment applied to fill in areas where data was z ate

Operations involved thousands of metric tons of ore, dry powder products and
corrosive chemicals in processes that were inherently dusty, producing an environment
with internal intake potential.

pg7 During early years, plant workers were routinely required to wear respiratory
protection because of significant radioactive dust levels approaching or exceeding FEMP
airbome alpha activity guidelines referred to as maximum allowable concentration
(MAC).

Femald processed thorium from 1954 to 1979 and was the national thorium
materials repository for the DOE starting in 1972.

pg8 Personnel exposed to uranium contamination could also be exposed to the
RU contaminants, which could have contributed to unmonitored internal exposure.’ °

Table 5-2 lists the primary radionuclides that could have led to intemal doses

during the production history of FEMP.

5.2.1 Processes were conducted in 10 plants.
Pilot Plant, UF6 was converted to UF4. An accident released 1200kg of
uranium, resulting in elevated personnel exposure. The enrichment is unknown, and 2%

should be sen for coy citbeant denticd ans sober af hte

More than 70% of thorium at FEMP was handled and processed from 1964-1979
in the Pilot Plant.

Plant, the sampling plant, started operations in Dec.,1953. Involved dusty
operations of mixing and blending etc., large quantities of uranium and thorium materials

Piant 2/3, the ore refining plants, began operations in Dec.,1953.

Plant 4, the green salt plant, converted U03 to UF4 (green salt). Began in
Oct.,1953. Some sir sample date sheotisformatson indicates that a least 2 Hinited amount