for work evolutions occurring in the Building 774, [ ], containment tent.
Furthermore, radiological contamination surveys within the room [ ] tent
were required by RWPs 00-771-5216, -5218, and -5250 before, during, and

after the completion of a work activity. KH_was unable to locate
contamination survey records for the period of Septel ugh
Oc! 15, 2000, though radiological work activities were occurring in the

roorn { } tent during that time.

3. Manual MAN-102-SCRM, “Rocky Fiats Environmental Technology Site
Radiological Control Manual,” version 1, dated October 15, 2000, requires in
section 322.7 that “[wjorkers shall acknowledge by signature or through
electronic means...that they have read, understand and will comply with the
RWP prior to initial entry to the area and after any revisions to the
RWP.” However, multiple instances were identified where several RCTs
entered Building 771 controlled areas during calendar year 2000 without
acknowledging (by signature or electronic means) that they had read,
understood, and would comply with the applicable RWP.

This violation constitutes a Severity Level i problem.
Civil Penalty - $27,500

B. 10 CFR 830(c}(2}(i) states that “[wlork shall be performed to established
technical standards and administrative controls using approved instructions,
procedures, or other appropriate means.”

Contrary to the above, work was not performed to established technical
standards and administrative controls using approved instructions, procedures,
or other appropriate means in that+

4. Manual MAN-071-IWCP, “Integrated Work Control Program,” revision 2, dated
March 30, 2000, States in section 4.3.6.3 that “Pen and Ink changes SHALL
be reviewed and concurred with by the affected organization(s)...

However, the original Building 771 berm removal work package, Work Control
Number #T0102407, was approved on February 25, 2000, and was intended
for the removal of 12 uncontaminated berms. The work package was later
modified by “pen and ink” changes, on May 17, 2000, to add additional berms
including those for room [ J, and on August 21, 2000, to permit the use of an
electric saw and jackhammer for berm removal. These changes were not
submitted to all affected organizations for review and concurrence.

2. ALARA Job Review (AJR) 00-771-012 states the only acceptable concrete

demolition method for the removal of berms in Building 771 are “...hammer,
chisel, hammer drill or any combination of the three.”

However, an electric jackhammer was used to facilitate concrete berm



Potential Health Problems from Exposure to Selected Radionuclides ~ Hanford Health J... Page 13 of 13

Last Update : 07/16/2004 11:35 AM
Send inquires about DOH and its programs to the Heaith Consumer Assistance Office
Comments or questions regarding this web site? Send mail to Teresa Lohr

SPOCHHOSHSHSHSHSHSHSHHHHHHSHHHOHOHSHHHOHHHHOHHHOCOOOOOECE



"Years later, in 1974, dad discovered that the Hanford doctors had for four years withheld evidence

SCHOHOSHSHSHHOHHSHSHHOHSHHHHOHSHOHHHOHHOHOOHOOOHEOOREOE

Fotental Health #robiems rom bxposure to Selected Kadionuchdes - Hantord Heatth int... fage ¥ of Lo

Cancer

Very little information is available on the potential for ruthenium to induce cancers. One study that
considered the possible health effects from ruthenium did not distinguish between mthenium-103 and
ruthenium-106. In animals exposed to ruthenium, cancers did develop. However, a report on the study
by R. Masse, a veterinarian and Chief of the Experimental Toxicology Laboratory in Montrouge,
France, did not specify where m the body the cancers developed.2+

RUTHENIUM
Skin Burns

Ruthenium particles released from Hanford posed a hazard if any of the particles had fallen onto a
person's exposed skin. This could have caused skin bums.

downwinder perspective |

Many callers t Hanford Health Information Lines have questions and concerns about the
release of plutonium and other radioactive materials from Hanford. Some downwinders have
health problems and believe that they are, or might be, related to Hanford. The following
personal perspective is offered to help readers anderstand these experiences and concerns.

"My father worked at Hanford as an ironworker/rigger, heavy equipment operator and supervisor
from 1947 until his death from lung cancer in 1985. He was 60 years old when he died. Thirty-four
of his years at Hanford were spent in the 200 Areas (where the plutonium was processed and
separated). He and his crew buried contaminated dry waste such as lab equipment or, in some cases,
even trucks and cranes in the ground. He helped to construct the tank farms and was involved in the
transfer of liquid wastes to the underground tanks.

"Dad was aware of the problems with the stacks and release of plutonium particles onto the ground
and he worried because his crew was there. .

that he had scarring in his lungs. During his annual medical checkup, a new doctor mentioned that
the scarring in his lungs was getting worse. He asked the doctor, "What scarring?" Being concemed
about getting proper medical care, dad went to Seattle for another exam. After a thorough work-up
at the Virginia Mason Clinic, he was diagnosed with ‘silicosis, caused by particles im the hmgs.' His
condition continued to deteriorate, eventually becoming hmg cancer.

"I can't help but wonder, what were those particles? Were they ‘hot’ particles released from the
stacks at Hanford decades earlier? Were they just sand? And why did the Hanford doctors, year after
year for four years, withhold my dad's medical condition from him?”

This perspective was contributed by a woman whose father worked at Hanford. She was born in
1948 in Richland and lived there until 1966. She recalls that much of ber family’s milk and
vegetables came from her uncle's farm in Kennewick. Name withheld by request.

hittn://www.doh.wa.gov/hanford/publications/overview/radionuclides btml 01/07/2005



OMB 40920-0639 Expires 05/31/07

Special Exposure Cohort Petition, Form 8
Appendix — Continuation Page

SOURCES OF INFORMATION

Defense Nuclear Facilities Safety Board, Report on Radiation Protection Review at the
Rocky Flats Plant, December 1, 1993.

Foster, P.P, 1991. “Study of plutonium oxide fuel inhalation case.” Radiation Protection
Dosimetry 38 (1-3): 141-146.

Investigation Team Report: Investigating the source of potential internal radiological
exposures involving eleven personnel in Building 771, Rocky Flats Environmental
Technology Site, March 15, 2001.

Newman, Lee; Mroz, Margaret; Ruttenber, James, Lung Fibrosis in Plutonium Workers,
May 31, 2002.

Office of Enforcement and Investigation, U.S. DOE, Consent Order, April 14, 1998.
PNNL-MA-860, Chapter 8.0: 8.13, Jan. 31, 2003.

Potential Health Problems from Exposure to Selected Radionuclides, Hanford Health
Information Network, May 2000.

Preliminary Notice of Violation and Proposed Imposition of Civil Penalty, Office of
Price Anderson Enforcement, July 17, 2001.

Roth, Herrick S. 1989. Local 8031: Its Struggles and Its Victories. A.B Hirschfield Press,
Denver, CO.

Sullivan, M.T. Lifetime Dose Limitation and Neutron Dose Reconstruction, Letter, July
26, 1994.

Tontodonato, R.E., Trip to Review Feed Characterization for RFP Building 707 Thermal
Stabilization Process, Jan. 20, 1994, Letter, February 8, 1994.

Toxicological Profile for Plutonium, Agency for Toxic Substances and Disease Registry,
TP-90-21, December 1990. .

Voelz, Gedrge, “Health Considerations for Workers Exposed to Plutonium,”
Occupational Medicine: State of the Art Reviews. October-December 1991, pp. 694.
Wilkinson, Gregg, “Mortality Among Plutonium and Other Radiation Workers at a
Plutonium Weapons Facility,” American Journal of Epidemiology, 1987, pp. 231-250.

Worker Testimony included as additional response to SEC Section F: Cindy Schubert,
Leonard Homan, Gary Burback, William Jordan, Don Williams, Howard Long, Harry
Charles Wolf, Robert Carlson.

‘The USWA, Local 8031 reserves the right to provide additional information beyond that which is included in this petition
and in support of our bility fo obtain Special Exposure Cohort designation for the Rocky Flats class of workers,
29



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CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Enclosures:

Preliminary Notice of Violation
Enforcement Conference Summary
List of Attendees

ce: B. Mazurowski, DOE-RFFO

S. Cary, EH-1
M. Zacchero, EH-1

S. Hurley, OE

P. Rodrik, OF

A. Weadock, OF

S. Zobel, OF

O. Stadler, EH-2

F. Russo, EH-3

R. Jones, EH-5

C. Huntoon, EM-1

H. Hirnpler, EM PAAA Coordinator

L. Bresster, DOE-RFFO PAAA Coordinator
R. Farrell, DOE-WIPP PAAA Coordinator
F, Casella, KH PAAA Coordinator

R. Azzaro, DNFSB

Docket Clerk, OE



Page 1 of 1
Portal Directory PortalSearch Portal Sitemap

Welcome,
Steve Trujillo
Home > Databases > Radiological improvement Reports (RIR)
2 Radiological: Improvement Report Details Rae Protection Site Links,
@ tation Protection
RIR No. 00-031 @ Alpha Group
Originator: . z cans
a 0
Project: RMRS 2 Databases
Date Entered: 1124/2000 12:00:00 AM # Documents
Event Date: 9/23/1999 12:00:00 AM & final Surveys
‘Status: CLOSED @ Mission
DateClosed: 2/2/2000 12:00:00 AM & Procurement
Buliding: TM 2 Toned
yi @ Training
Location: # Video Library
Description: Following an entry into a plastic house on 9/23/99, RCT .
submitted routine nasal swabs, On e swab was slightly Database Links
above decision level so fecal samples were requested. @ Create RIR .
Initial fecal samples showed an intake did occur but were Ra anton Generating Devices
not supported by other workplace indicators so additional
samples were requested. Analysis of all data indicates that wen” Radioactive Sources
an intake of 270 mrem did occur. This brings employee's
CY99 exposure to 369 mrem, Contact
IRS Supervisor —_ K. Harrawood ; - a . McGinley, Pam
e immediate Employee was restricted from work in radiological area Webmaster
Corrective while determining exposure up until Jan 1, 2000 when his PHONE: x6878
Action: allowable exposure was reset. Investigation is complete. PAGER: (303) 212-5374
Primary Event Savitz, Kenneth R
Code: Al Aitemate Webmaster
. PHONE x4686_
Secondary Event PAGER: (303) 212-4443
[Apparent Cause: OTHER/ No identified cause
Facility Mgr: A_B. Adams_
~ IDOE
Categorization: Completed
Occurrence Rpt.
Now: 2000-0005
Menonsiole K Harrawood
Responsible Dir.: A.C. Crawford
Target Date: 2/23/2008 12:00:00 AM
Corrective There are no apparent indicators of how this occurred. The
Actions: entry into the ten and the doffing were iaw all procedures

PATS No.:
‘Comments:

and no abnormai conditions were identified. Corrective
actions were completed in the form of a bioassay program
for employee. This RIR was filed for training purposes only.
RIR 00-031 clased out by referencing Occurrence Report
RFO-KHLL-7710PS-0005 per HSP 3.02

2000-000115
PA Screen # RMRS-0-1135

uttp://rfetshp/portal/Default.aspx?PID=25&MID=335

7/19/04



Radiation Protection - Radiological Improvement Reports (RIR)
[BSE Monday, July 19, 2004 9:09:13 AM

Page 1 of 1
Portal Directory Portal Search Portal Sitemap

Welcome,
Steve Trujillo

Home > Databases > Radiological Improvement Reports (RIR)
Radiological-Improvement Report Details

RIR No. 00-251

Originator:

Project: 7

Date Entered: 6/27/2000 12:00:00 AM

Event Date: 6/22/2000 12:00:00 AM

Status: CLOSED

|DateClosed: 711112000 12:00:00 AM

Building: 771

Location: soP

Description: After the employee removed anti-cs and proceeded to self

monitor hand carried items, identified elevated reading on
bump cap. Employee contacted RCT and the RCT
confirmed 4,200 dpm/100cm2 alpha on the rear portion of
the cap. No other contamination was detected on the
employee or other items in an attempt to locate a source
of the contamination, RCT discovered 2,000 dpm ona
phone that the employee had used. No other contamination,
could be found in any other areas that the employee
worked.

e IRS Supervisor = J.Harris

immediate Calculated the PIF @ 2.6 and requested nasal and mouth
‘Corrective samples. The telephone was immediately decontaminated,
(Action: A Survey of ear muffs emplayee had worn earlier and the

employee's locker that stores the bump cap in, no |
contamination found. The activity was confirmed to be PU
239 using Alpha Spectrometry.

Primary Event
Code: 56

Secondary Event .,

Codes: BS
Apparent Cause: PERSONNEL
Facility Mgr: T. R. Hergert

DOE

Categorization: Completed
Occurrence Rpt. “2000-0356
No.:

Maeonsible M. Brown

Responsible Dir.: K. Trice

Target Date: 712212000 12:00:00 AM

Corrective Area was deconned and all crews were briefed on proper

Actions: rad practices covering touching areas on their bodies in the
CA. This briefing was conducted during Pre Evs.

t ) PATS No.:

1ttp://rfetshp/portal/Default.aspx?PID=25&MID=335

Pe

|Comments: CEDE-5 mrem

Rad Protection Site Links

® Radiation Protection
# Alpha Group
@ Briefings

@ Calc Log

2 Databases

# Documents

a Final Surveys
2 Forms

@ Mission

@ Procurement
@ TBD Log

# Training

@ Video Library

Database Links

® Create RIR

@ Radiation Generating Devices
(RGD)

# Sealed Radioactive Sources
(SRS)

Contact
McGinley, Pam

Webmaster
PHONE. x6818
PAGER: (303) 212-5374

Savitz, Kenneth R
Altermate Webmaster
PHONE: x4686
PAGER: (303) 212-4443

TAIN4



Radiation Protection - Radiological Improvement Reports (RIR)

Monday, July 19, 2004 9-20-49 AM

Page 1 of 1
Portal Directory Portal Search Portal Sitemap

Radiation Protactian

Welcome,
Steve Trujillo

i Back }< | Create RIR

Home> Databases > Radiologicat Improvement Reports (RIR}

7

Radiological Improvement Report Details

RIR No.: 00-412

Originator: -

Project: 7714

Date Entered: 10/31/2000 12:00:00 AM

Event Date: 40/30/2000 12:00:00 AM

‘Status: CLOSED

DateClosed: 42/48/2000 12:00:00 AM

Building: 77

Location: 180K

Description: Upon receiving sample results from Internal Dosimetry lab,
it has been determined that the employee has exceeded
the ACL for annual exposure.

IRS Supervisor —_M. Fitzpatrick

immediate informed employee of the lab results and started the

Corrective extension process.

Action:

Primary Event 82

Code:

Secondary Event

Codes:

Apparent Cause: PERSONNEL

Facility Mgr: H. Lerum

DOE- :

Categorization: Completed

nocurence RPE 2000-0484

eo D. Boone

Responsible Dir.: K. Trice

Target Date: 11/30/2000 12:00:00 AM

Corrective The uptake is documented on a previous RIR. The

Actions: extension has been granted. TLD re-instated. There will be
no actions of this occurrence.

PATS No.:

|Comments: Cross reference RIR# 00-332 -bjs

ittp://rfetshp/portal/Default.aspx?PID=25 &MID=335

Rad Protection Site Links

# Radiation Protection
@ Alpha Group
2B

2 Calc Log

@ Databases

2 Documents
# Final Surveys
@ Forms

# Mission

2 Procurement
# TBD Log

@ Training

# Video Library

Database Links
@ Create RIR
@ Radiation Generating Devices

(RGD)
® Sealed Radioactive Sources
(SRS)

Contact

McGinley, Pam
Webmaster

PHONE: x6818

PAGER: (303) 212-5374

Savitz, Kenneth R
Alternate Webmaster
PHONE: x4686 -
PAGER: (303) 212-4443

T9104

7



%adiation Protection - Radiological Improvement Reports (RIR)

Page 1 of 1

Portal Directory Portal Search Portal Sitemap

|
| {BBE Monday, July 19, 2004 9:05:59 AM
|
!

Welcome,
Steve Trujillo
>
"Home > Databases > Radiological Improvement Reports (RIR)
i ., .
Radiological-Improvement Report Details Rad Protection Site Links
! ? Radiation Protection
RIR No. 99-538 2 Alpha Group
Originator: z Briefings
Project: RMRS » Datepats
Date Entered: 12/9/1999 12:00:00 AM @ Documents
Event Date: 121711999 12:00:00 AM & Final Surveys
Status: CLOSED @ Mission
DateCiosed: 414f2000 12:00:00 AM * Procurement
- 2 TBD Log
Building: 774 ® Training
Location: # Video Library
' (Description: Employee entered CA without TLD and failed to sign in .
. under a RWP. Employee was in the work area for Database Links
approximately one hour. * Create RIR . .
' IRS Supervisor J. Harris we Generating Devices.
‘ immediate Locked out the employee from the HIS 20 system. @ Sealed Radioactive Sources
Corrective Performed a micro rem survey to support a dose (SRS)
Action: reconstruction.
Primary Event 3 Contact
Code: McGinley, Pam
master
® Secondary Event co PHONE: x6818
Codes: PAGER: (303) 212-5374
|Apparent Cause; PERSONNEL Savi neth
Facility Mgr: ‘KD, Blake Savitz, Kenneth R
DOE , - PHONE: x4686
Categorization: Completed PAGER: (303) 212-4443
Qccurrence Rpt. 99.0838
Responsible ‘
Mgr: R. Cautfield
Responsible Dir.: A. Crawford
Target Date: 1/6/2000 12:00:00 AM
‘Corrective Atthough this incident was an individual personal error. The
Actions: 771 project has instituted a check point Charlie which
consists of project personnel just outside the SOP checking]
io ensure personne! have TLDs,
PATS No.:
Comments: RMRS PA Screen No. RMRS-99-1053

xttp://rfetshp/portal/Default.aspx?PID=25&MID=335

| |

8

TAIIO4



10

Price-Anderson Enforcement, Attention: Office of the Docketing Clerk, at the above
address. Should KH fail to answer within the time specified, KH wiit be issued an Order
imposing the civil penalty. In requesting additional mitigation of the proposed civil
penalty, KH should address the adjustment factors described in 10 CFR 820,

Appendix A, section IX.

KR kith Cfrictepphory
R. Keith Christopher
Director

Office of Price-Anderson Enforcement

Dated at Washington, DC,
this 17th day of July 2001



OOOOH HOHSSHSHHHHHHHHHHOHHHOOOOOHOOEOCOOOOO

BUILDING 771 HISTORICAL WORKPLACE : bese oe a
SURVEY
Name: Date:
Org: ne Director:
Bldg: Job Title:
Plant Extension/Digital Page:

seevauaiel

Supervisor/Manager

Supervisor/Manager: ExvDP:

4.

Were you hired at Rocky Flats prior to 1968? If not, when?

2. Did you have a routine work assignment in Building 777 prior to 1968? If so, what was
your specific work assignment in Building 771 and where in Building 771 was your work
routinely performed? (be as specific as you can)

3. Were you a chemical process operator or assigned to chemical processing jobs in Building
774 prior to 1968? If so, what lines, rooms, or processes were you assigned to?

4. Were there other buildings in which you worked prior to 1968 where you were also
exposed to neutrons? : os

5. Have you worked at another nuclear facility where you may have been exposed to neutrons?

6. Please list any additional questions or concerns which you would like answered (use back of
page if necessary).

Signature Date

We appreciate your assistance in completing this questionnaire. The questionnaire will be used

for completion of a dose reconstruction and to update your radiation exposure records.

PLEASE RETURN COMPLETED FORM TO M. R. PROCHOWNIK, BLDG 123



SPOOOOOHOHOOHOOHOSOHHOOHOOHOOHOOOOOOOOOCOOHOOOOOE

DOE has also evaiuated and agrees with the adequacy of the corrective actions
completed and scheduled for implementation to correct work control deficiencies and to
prevent recurrence of these or similar events in the future. As a result of the Kaiser-Hill
team’s aggressive response to these three events and during previous events, and to
encourage similar responsiveness in the future, DOE has elected to issue the enclosed
Consent Order in accordance with 10 CFR 820.23 in lieu of possible enforcement
proceedings, Notice of Violation, or civil penalties. With this Consent Order, Kaiser-Hill
has agreed to remit a $100,000 monetary remedy in recognition of the programmatic
work planning and contro! problems identified as a result of their internal investigations.

No written response fo this letter is required. As provided by Section VI of the enclosed
Consent Order, the Kaiser-Hilf team is to remit the $100,000 monetary remedy to the
Treasurer of the United States.

In accordance with the terms and conditions of the enclosed Consent Order, any
required changes to corrective action completion dates regarding these three events
must receive prior written approval from the Manager, DOE Rocky Flats Field Office.
The original of the Consent Order signed by the parties has been filed with the Office of
the Docket Clerk.

Sincerely,

Peter N. Brush
Acting Assistant Secretary .
Environment, Safety and Health


SPOCOOHHOHOOOOHOHOOOOOHOHOOOOOOOOOOSOOSOOO OOOO

rolcnlal neann sTODIeMs MOM BXposure to Setecied Kadionuchdes - Hantord Health int... rage / or 13

Engiand, did a study of the chromosomes of 54 plutonium workers who were exposed to plutonium
mnainly by inhalation. Each plutonium worker had a higher number of chromosome aberrations
compared with workers not exposed to plutonium. The scientists concluded that the exposure to
plutonium increased the number of aberrations.3

Strontiom —

Possible Health Effects: Leukemia, bone cancer, weakened immune system

Description: The isotope of strontiam for which the Dose Reconstraction Project is calculating dose
estimates is strontium-90. In the body, strontium is chemically similar to calcium. Therefore, the body
is likely to use strontium in the same way it would use calcium.

Estimated Amount Released from Hanford: 64.3 curies

Chemical Form of Release: unknown

Range of Representative Dose Estimates: 0.0007 mrem EDE to 0.07 mrem EDE

Summary of Scientific Studies
STRONTIUM
Leukemia

Strontium may cause leukemia. 1¢ More than 90 percent of the strontium that remains in the body is in
the bones 14

According to M. Thomasset, MD, Director of Research at the National Center of Scientific Research,
National Institute for Health and Medical Research, Le Vesinet, France, "continuous low doses” of
strontium cause relatively more cases of leukemia than high, one-time doses.16

STRONTIUM

Cancer

Because strontium deposits in the bones, bone cancer is also a possible health effect. Animal studies
have shown that high doses of strontium produce a relatively large number of bone cancers. At lower
levels of exposure, there are very few cases or none. A Utah study conducted on beagles did not find
bone cancers at low doses.

STRONTIUM.

Immune System

Thomasset reported that continuous low doses of strontium weakened the immune system for up to one
year after the exposure.1®

hittp://www.doh.wa.gow/hanford/publications/overview/radionuclides html 01/07/2005



COOOOOOOOOOHOOOOOSOOOOOOOOEOOOOOO OOO OOCOCEE

removal in Building 771 but its use was not authorized on the controlling AJR.
No revisions were made to the AJR to allow its use, and no approvais from
Radiological Engineering were obtained to resolve this conflict with the AJR:

3. Procedure 3-PRO-229-RSP-01.01, “Radiological Work Permit,” revision 0,
dated March 10, 1998, states in section 3 thai “[s]pecific RWPs are written to
controf work in a radiologically controlied area.” Section 2.1 of this procedure
tequires that it is a RCT’s responsibility to terminate work activities if work
*,_.fs performed beyond the original scope of work stated on...” the RWP.

However, radiological work within the Building 771,[ ], containment tent was
not always controlled by a specific or applicable RWP or AJR. For example,
drum repackaging activities were conducted for several weeks using the RWP
originally developed for glovebox removal until the drum repackaging RWP.
was finally approved on June 14, 2000. Pre-evolution briefing records
indicate piping was size-reduced in the room [ ] tent on September 27, 2000,
though the RWP and AJR for that activity was not approved until October 18,
2000. Work activities were not terminated despite the lack of a work scope-
specific RWP.

4. Procedure PRO-405-RSP-01.03, “Soft Sided Containment (Plastic House),”
ravision 2, dated January 20, 2000, states in section 3 that Radiolagicai
Engineering will design the containment, and the Job Supervisor will ensure
that all prerequisites, assessments, and inspections have been performed.

However, during removal of one of the Bullding 771, [ ], berms, the use of an
electric saw generated sufficient quantities of contaminated dust such that a
nearby continuous air monitor (CAM) would occasionally alarm. The work
crew then independently constructed a half-tent to aid in dust control. No
pertinent reviews and approvals.were performed, and a Radiological Engineer
was not involved in the half-tent’s design until after the half-tent had been in
use and CAM alarms continued to occur.

This violation constitutes a Severity Level !! problem.
Civil Penalty - $27,500

C. 10 CFR 835.1001(a) states that “[mjeasures shall be taken to maintain radiation
exposure in controlled areas ALARA through physical design features and
administrative control.”

Contrary to the above, measures were not taken to maintain radiation exposure
in controjied areas ALARA through physical design features and administrative
control in thats

4. On September 14, 2000, construction workers breached a contaminated
instrument airline as part of a wall removal conducted under a minor



Referenced NTS Numbers

NTS-RFO--KHLL-771 OPS-2000-0002,
NTS-RFO-KHLL-771OPS-2000-0003,
NTS-RFO-KHLL-D&DOPS-2000-0001,
NTS-RFO-—KHLL-KHILL-2000-0001,
NTS-RFO-—KHLL-KHILL-2000-0002,
NTS-RFO-KHLL-PUFAB-2000-0002
NTS-RFO-—KHLL-PUFAB-2001-0001,
NTS-RFO~KHLL-REGWSTOPS-2000-0001
NTS-RFO-KHLL-SITEWIDE-2000-0008, and
NTS-RFO-KHLL-SITEWIDE-2001-0002



Building 707 [radioactive material] sizing event were limited in scope and did not
prevent the occurrence of similar deficiencies during the tater TRU waste
container loading event.

B. TRU Waste Facility Work Controls

KH corrective actions have been ineffective in preventing the recurrence of work
Control deficiencies similar fo those described in section If of this PNOV.
Specifically, Building 440 deficiencies described in section I! are similar to those
identified during the original 1997 Basis for Operation Operational Readiness
Review (ORR). The KH Cause Analysis, dated Septernber 28, 2000, indicates
that line management's corrective action process did not adequately address
ORR concerns.

C. Procurement

KH corrective actions have been ineffective in preventing the recurrence of long-

standing and repetitive noncompliances in the area of Procurement. Specifically,
those noncompliances described in section Ill of this PNOV have been previously
identified to KH by DOE through multiple Enforcement Actions (EA-1999-06; EA-
2000-01) and an Enforcement Letter (September 11, 2000).

This violation constitutes a Severity Level I! problem.
Civil Penalty - $55,000

Pursuant to the provisions of 10 CFR 820.24, KH is hereby required within 30 days of
the date of this Preliminary Notice of Violation and Proposed imposition of Civil Penalty
to submit a written statement or explanation to the Director, Office of Price-Anderson
Enforcement, Attention: Office of the Docketing Clerk, P.O, Box 2225, Germantown,
MD 20875-2225. Copies should also be sent to the Manager, DOE Rocky Flats Field
Office; and to'thie Cognizant Secretarial Offices at Headquarters for the facilities that are
subjects of this notice. This reply should be clearly marked as a “Reply to a Preliminary
Notice of Violation” and should include the following for each violation: (1) admission or
denial of the alleged violation, (2) any facts set forth that are not correct; and (3) the
reasons for the violation if admitted, or the basis for denial if denied. Corrective actions
that have been or will be taken to avoid any future violation will be delineated with target
and completion dates in DOE’s Noncompliance Tracking System. In the event the
violations set forth in the Preliminary Notice of Violation are admitted, this Notice will
constitute a Final Notice of Violation in compliance with the requirements of

10 CFR 820.25.

Any request for remission or mitigation of civil penalty must be accompanied by a
substantive justification demonstrating extenuating circumstances or other reasons why
the assessed penalty should noi be paid in full. Within the 30 days after the issuance of
this Notice, unless the violations are denied, or remission or mitigation is requested, KH
shall pay the civil penalty of $385,000 imposed under section 234a of the Atomic
Energy Act of 1954, as amended, by check, draft, or money order payable to the
Treasurer of the United States (Account 891099) and mailed to the Director, Office of



FOLCHUGL Meat, CLOVIELIS LULL CXPUSULE LO OUIELICU KAQIODUCHOCS ~ MANLOLG Mealul LL. Pays o OL 12

Cerium
Possible Health Effects: Leukemia; and bone, liver, and nasal cavity cancers

Description: The isotope of cerium for which the Dose Reconstruction Project is calculating dose
estimates is cerium-144.

Estimated Amount Released from Hanford: 3,770 curies
Chemical Form of Release: Assumed to be soluble?

Range of Representative Dose Estimates: 0.05 mrem EDE to 5.4 mrem EDE

Summary of Scientific Studies
CERIUM
Cancer

All of the information on cerium's health effects comes from animal studies. Cerium concentrates in the
bone marrow. Because of this, the risk of leukemia is the predominant potential health problem.

When insoluble cerium is inhaled, it remains in the mg. When soluble forms are inhaled, certum
moves into the bones and liver. Bone and liver cancers, as well as liver damage, are possible. The
National Council on Radiation Protection has stated that cancers of the nasal cavity are also possible.22
Rutheniwn

Possible Health Effects: Cancer, skin burns

Description: There are two isotopes of ruthenium for which the Dose Reconstruction Project is
calculating dose estimates: ruthenium-103 and ruthenium-106.

Estimated Amount Released from Hanford:
rathenium-103; 1,160 curies

ruthenium-106: 388 curies

Chemical Form of Release: unknown

Range of Representative Dose Estimates: 0.009 mrem EDE to 0.89 mrem EDE

Summary of Scientific Studies

RUTHENIUM

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hittp://www.dob.wa.gov/hanford/publications/overview/radionuclides html 01/07/2005



Civil Penalty ~ $41,250
ill, Procurement

A. 10 CFR 830.120(c}(2)(i) requires, in part, that “{wjork shalt be performed ta
established technical standards and administrative controls using approved
instructions, procedures, or other appropriate means.”

Contrary to the above, work was not performed to established technical
standards and administrative controls using approved instructions, procedures,
or other appropriate means in that»

1. The Rocky Flats Environmental Technology Site Acquisition Procedure for
Requisitioning Commodities and Services, Revision 1, 1-W36-APR-111,
requires that requisitions for “closure commodity” procurements be reviewed
and signed by the Requisitioning Manager or Material Acquisition Member,
the WADLET Manager and the Customer Service Organization. Waste
isolation Pilot Plant (WiPP) related procurements must also be reviewed and
signed by the TRU Waste Project Quality Assurance Officer.

However, on August 23, 2000, KH placed a telephone order with Myers |
Container Corporation for 500 55-gallon replacement waste drum lids without |
first obtaining ail required quality assurance reviews and approvals of the |
related requisition. Specifically, KH ordered the drum lids after the TRU |
Waste Project Quality Assurance Officer and the Customer Service |
Organization withdrew their approvals of the requisition for the waste drum

lids. The drum lids are designated as “closure commodity” and WIPP-related

items and were intended for use in the storage and movement of transuranic

radioactive waste and eventual shipment of the waste to WIPP.

2. The KH Procurement System Manual establishes. procurement procedures for
the acquisition of items for the Rocky Flats Environmental! Technology Site.
Revision 1 of Volume 1, Part 2, section 1.201-2, requires that the buyer of
items shall assure that no subcontract shall be entered into, modified, or
terminated unless all required reviews, clearances, or approvals have been
obtained.

However, on August 23, 2000, KH failed to obtain all required approvals
before procuring 500 55-gallon replacement waste drum lids.

This violation constitutes a Severity Level !! problem.
Civil Penalty - $82,500

B. 10 CFR 830.120(c)(2)(iil) requires, in part, that “[pjrocured items and services
shail meet established requirements and perform as specified.”

Contrary to the above, procured items and services did not meet established
requirements and perform as specified in that+

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7

completion dates established in the subject NTS reports shail receive the prior approval
of the Manager, Rocky Flats Field Office. The subsequent failure to timely complete
such corrective actions may, in the sole discretion of DOE, constitute a sufficient basis
to reopen the investigation with respect to the subject potential violations.

2. Kaiser-Hill agrees to pay $100,000 to the Treasurer of the United States within 15
days of the issuance of this Order. It shall be mailed to the Director, Office of
Enforcement and Investigation, Office of the Assistant Secretary for Environment,
Safety and Health, U.S. Department of Energy, P-O. Box 2225, Germantown, MD
20874-2225, Atiention: Office of the Docketing Clerk.

3. Upon completion of all corrective actions to the satisfaction of DOE, the payment
made to DOE under this Consent,Order shall completely resolve and serve as a full
and final setttement of any and all enforcement actions taken under 10 CFR 820
arising from the referenced NTS reporis.

4. This Consent Order shall become a Final Order upon receipt of said amount
referenced in Item 2.

5. Kaiser-Hill hereby waives any and all rights to appeal or otherwise seek judicial
review of this Consent Order. However, both DOE and Kaiser-Hill retain the right to
judicially enforce the provisions hereof by all legal means.

On behalf of my respective organization, | hereby agree to and accept the terms of the
foregoing Consent Order.

FOR DOE-EH FOR Rocky Fiats Field Office
. “os {198 : _/ 198
R. Keith Christopher Jessie M. Roberson
Director, Office of Enforcement Manager, Rocky Flats Field Office
and Investigation U.S. Department of Energy
U.S. Department of Energy
FOR Kaiser-Hill
i 198
Robert G. Card
{1

Kaiser-Hill Company, L.L.C.
Rocky Flats Environmental Technology Site



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FOLCIMAL ACL FIQUIEIS LOU PAVUDULE LO SCIOLLEU KAUIONUCHUES - Mantord Mean wa... Frage o OL 19

Reconstruction Project has not yet reconstructed the amount of the four radionuclides released on
particles; (2) the computer model used in the study did not simulate the behavior of particles; and (3)
the Dose Reconstruction Project has not yet estimated doses frora the hot particle releases. This work is
now underway. The federal Centers for Disease Control and Prevention (CDC) is now working with the
HEDR Task Completion Working Group to continue public participation and to assure completion of
the remaining HEDR activities.

its chemical form as released from Hanford's weapons plants

The chemical form of the radionuclide is very important in assessing how the body might handle the
material. The chemical form may significantly affect the dose a person receives from incorporating the
material into the body. One aspect of the chemical form is whether it is soluble or insoluble. The
Hanford Environmental Dose Reconstruction Project assumed that plutonium and cerium were released.
in soluble forms.

the range of representative doses

The dose estimates are cumulative for 1944-1992, whole body in rem EDE (effective dose equivalent).

a summary of health studies

Platonium

Possible Health Effects: Bone, liver and lung cancer; leukemia; chromosome aberrations

Description: The isotope of plutonium for which the Dose Reconstruction Project is calculating dose
estimates is plutonium-239.

Estimated Amount Released from Hanford: 1.78 curies
Chemical Form of Release: Assumed to be soluble*

Range of Representative Dose Estimates: 0.03 mrem EDE to 3.6 mrem EDE

Summary of Scientific Studies

PLUTONIUM:

Cancer

Studies of plutonium workers and many animal studies have focused on exposure to insoluble forms of
phitonium. The Hanford Environmental Dose Reconstruction Project assumed that the plutonium

released to the air was in a soluble form. The potential health problems of soluble and insoluble
plutonium are described below.

http://www.doh.wa.gov/hanford/publications/overview/radionuclides.html 01/07/2005



UOTE PTE ROCTUTET COTO TCDNEUIVOIDOD NUNEITISCTCH OL ONUTCOT EP LOTTETLUTONUITTTTOC ESE TUN TULU/CUW Uler TReEUCCEIERD a oC eEE Rn CraECeS

according to the Technical Steering Panel.

The Hanford Environmental Dose Reconstruction (HEDR) Project was established to estimate
what radiation dose people living near Hanford some time between 1944 and 1992 might have teceived
from releases of radioactive materials. The Technical Steering Paned, which directed the study,
cormpleted its role in 1995. The federal Centers for Disease Control and Prevention (CDC) is now
working with the EDR Task Completion Working Group to continue public participation and to
assure completion of the remaining HEDR activities. When using information from this and other
studies, readers should keep in mind that research results depend on a number of factors, such as the
information available, and the methods and type of analysis used.

What are the possible health problems from exposure to plutonium, strontium, cerium and
ruthenium? Most of the information on health effects from these materials has come from studies of
plutonium workers and research involving animals. None of these studies contains information that
relates to the specific situation of those people who lived downwind from Hanford. While comparisons
to the Hanford situation are uncertain, the information in this report may help identify potential health
problems which may have been caused or could be caused by exposure to these radionuclides.

Radiation health scientists generally believe that any dose of radiation, however small, carries with it an
increased risk of some adverse health effect, such as cancer. This does not mean that everyone who
receives an exposure will suffer an effect. It means the risk of a radiation-induced health problem is
increased. Even if a particular effect does occur in an individual, it is not possible to determine, with
cutrent scientific methods, that it was caused by radiation exposure.

History of Hanford's Hot Particles

Unlike iodine-131 - which was released as 2 gas - plutonium, strontium, cerium and ruthenium,
became attached to particles of rust or dust and were then released. There were two time periods in
Hanford's operation when there were major releases of radioactive particles:

» From late 1944 through at least 1951, there were large releases of particles containing plutonium,
strontium and ceriuns. . .

From 1952 to 1954, there were large releases of particles containing ruthenium.
Plutonium, Cerium and Strontium

Starting in 1944, Hanford produced plutonium for use in nuclear weapons. Uranium fuel was partially
transformed into plutonium inside the nuclear reactors along the Columbia River. The irradiation of
uranium not only created plutonium but also created numerous other radioactive elements, including the
radionuclides of cerium, strontium and ruthenium, which are the subject of this report. After irradiation,
the uranium fuel (now containing plutonium and the other radionuclides) was transported several miles
to the separations plants at the center of the Hanford Site. It was here that the fuel was dissolved in.
nitric acid. After numerous chemical steps, the plutonium was separated from the fuel and purified for
use in nuclear weapons.

The process of separating the plutonium released pollution to the air and the ground. This report

focuses or the potential health effects from exposure to those radionuclides that were released to the air
on particles. These particles are called "hot" because they were radioactive.

http://www.doh.wa.gov/hanford/publications/overview/radionuclides html 01/07/2005



detect changes in radiological canditions-of the warkplace: inadequate As Low As
Reasonably Achievable (ALARA) measures including.both the use of ventilation and

* corifinement; failure to follow ures ALARA; failure to

generate and maintain radiologi > than adequate area monitoring for
airborne radioactive materials.

Wome facoacine Matera
The uptakes were discovered through routine bi ne worker and by special
request for biog: ond worker; i. the intake event was unrecognized. *:

The investigation report points out that a significant amount of time lapsed between the
submittal of excreta and notification of the workers of their bioassay results--more than
one year. The report states that confirmation that an intake occurred requires the
recount of the original positive sample, and acquisition of two additional follow-up urine
samples. In this case, the confirmatory process was lengthy: For one worker, recount
of the original positive urine sample required seven weeks, acquisition of the first
follow-up urine sample was not initiated for an additional fen weeks, and acquisition of
the second follow-up sample occurred 25 weeks after that. Consequently, the internal
dose evaluation program was not adequate to demonsirate timely compliance with
1996 occupational exposure limits.

[Buildings] Area Monitoring
NTS-RFO~KHLL-SITEWIDE-1997-0009

Fo e individuals in 1996 and 39 in 1997 (including one declared pregnant worker)
vote avaluated for unmonitorad radiation Sxiecures oe a resort of meteors
assessment of area monitoring data for several offices adjacent to rooms containing
radioactive materials. Six individuals for 1996 and 11 for 1997 were assigned doses
greater than Ja specified amount] effective dose equivalent (EDE) (maximum doses
were [specified amounts] EDE, respectively). Safe Sites of Colorado (SSOC) was
assigned-responsibility for the RFETS radiological control program in late February
1997. The area monitoring report for the first quarter of 1997 was issued on July 30,
1997, and described high dosimeter measurements for several office areas in Buildings
{ ]. On September 15, 1997, the second quarter area monitoring report was issued
and conveyed similar results. SSOC initiated an investigation and utilized a
combination of area postings, personnel relocations, and interim administrative conirols
to reduce occupational exposures within the affected office areas. Dose
reconstructions began in mid-September 1997. The reconstructions revealed two
pregnant workers who were within the office areas; one was working in an affected area
for a short period of time and was assigned [a specified amount] EDE, and the second
employee, a declared pregnant worker, received an estimated [specified amount] EDE.
SSOC's root cause analysis identified the following radiological control programmatic
deficiencies: monitoring of individuals and areas, monitoring of declared pregnant
workers, administrative controls, and work processes.



Ee”

U.S. Department of Energy

Office of Enforcement and Investigation
ay

In the matter of )} Report No. NTS-RFO--KHLL-ENVOPS-1 997-0001
) NTS-RFO--KHLL-SITEWIDE-1997-0009
Kaiser-Hill Company, LLC.) NTS-RFO--KHLL-371OPS-1998-0001
Rocky Flats Environmental)
Technology Site ) Enforcement Action 98-03

CONSENT ORDER INCORPORATING AGREEMENT BETWEEN
U.S. DEPARTMENT OF ENERGY AND KAISER-HILL COMPANY, L.L.C.

j

Kaiser-Hil] Company, L.L.C. (Kaiser-Hil), is the integrating management contractor for
the Department of Energy (DOE) at the Rocky Flats Environmental Technology Site
(RFETS), Golden, Colorado. Kaiser-Hill is responsible for all activities related to the
environmental restoration of contaminated areas and facilities, and maintaining
{radioactive materials] at RFETS.

u

The following incidents were reported voluntarily by Kaiser-Hill to the DOE
Noncompliance Tracking System (NTS) for evaluation:

CERCLA Tank Remediation Project
NTS-RFO-~KHLL-ENVOPS-1997-0001

Internal intakes of [radioactive material] occurred in two workers participating in

Rocky Mountain Remediation Sérvices' underground tank remediation activities on
August 12, 1996. Doses of [specified amounts] committed effective dose equivalent
were assigned. Although radiological hazards associated with the work had escalated
over a period of severaj months, compensatory radiologica) planning and controls were
not adequately reviewed and implemented. Radiological work control

program nesses identified by iser-Hil is included
inadequate monitoring to document radiological conditions in the work place and to



1. On August 23, 2000, KH procured 500 55-galion replacement waste drum lids
to a specification that was not designed for drum lid replacement parts and
did not establish requirements for drum lid replacement parts.

2. On or about August 28, 2000, KH received 500 55-gallon replacement waste
drum lids that did not meet requirements to Subject Matter Expert criteria.
Specifically, 83 percent of the lids failed for nonconformance to convexity, for
dents/bends, or for gasket adhesion nonconformance. The remaining lids
failed due to markings, paint thickness, and paint coverage.

This violation constitutes a Severity Level li problem.
Civil Penalty - $82,500

IV. Building 7714 Radiation Safety Program

A. 10 CFR 835.104 states that “[wjritten procedures shall be developed and
implemented as necessary to ensure compliance with this part, commensurate
with the radiological hazards created by the activity and consistent with the
education, training, and skills of the individuals exposed to those hazards.”

Contrary to the above, written procedures were not developed and implemented
as necessary to ensure compliance with 10 CFR 835 in that.

4. Manual MAN-102-SCRM, “Rocky Flats Environmental Technology Site
Radiological Control Manual,” version 1, dated October 15, 2000, requires in
section 551.2 that “{mJonitoring shall be performed only by trained and
qualified individuals using instruments that are properly calibrated and
routinely tested for operabiity.”

However, equipment used for process monitoring or data collection was not
calibrated and maintained in that on October 16, 2000, a DO! ity
Representative observed a low- VOLTS SPSeSSP Teaeveb ia ie Beilding
771, | ), tent that was in use beyond its calibration expiration date. KH’s
broader investigation of this finding in Building 777 resulted in the
identification of Several survey meters and other low-vols in this same

situatis in USe despite that
instrument having failed_a performance check.

2, Procedure RSP-01,01, section 4.1.2[1] requires a RCT to “[p]erform and
properly document surveys.” Section 7.6 of this procedure requires that
worker DAC-hr tracking be performed when powered air purifying respirators
are used. Such respirators were used from the September 7 through
October 17, 2000. rn

However, records were not specified, prepared, reviewed, approved, and
maintai i through October 17, 2000,

documentatio iolagis fork Permit (RWP; wired airborne
radioactivity measurements and worker DAC-hr tracking was not pérformed

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by Kaiser-Hill to these maiters, the payment included by Kaiser-Hill has been
significantly reduced from what could have been proposed through the formal
enforcement process.

Vv

DOE acknowledges that Kaiser-Hill’s execution of and payment in accordance with this
Consent Order does not constitute or imply admission by Kaiser-Hill of potential
regulatory violations. Both DOE and Kaiser-Hill agree that the sum paid by Kaiser-Hill
to resolve this matter shall not be considered a reimbursable cost.

Mi

This Consent Order is issued under DOE's authority in Section 234A of the Atomic.
Energy Act of 1954, as amended (42 U.S.C. 2282a), and 10 CFR Part 820.23. Kaiser-
Hill agrees to pay to the Treasurer of the United States (Account Number 891099),
mailed to the Director, Office of Enforcement and Investigation, U.S. Department of
Energy, an amount of $100,000 reflecting an agreed amount in lieu of any subsequent
investigation, Notice of Violation, and imposition of civil penalty.

This Consent Order does not preclude DOE from investigating or pursuing enforcement
action against Kaiser-Hill for cases other than those described in the above referenced
NTS reports, or if Kaiser-Hill fails to proceed with corrective actions as ouilined in their
plans as described in the above referenced NTS reports.

DOE agrees that it will not pursue an enforcement action or civil penalty for any
potential violations pertaining to the above referenced matters. DOE may subsequently
consider enforcement action if it later becomes known that any of the facts or
information provided regarding the described events were knowingly false or inaccurate
in any material way.

ACCORDINGLY, it is hereby Ordered as follows:

1. In accordance with its authority under the Price-Anderson Amendments Act
(42 U.S.C. 2282a) and 10 CFR 820.23, DOE issues this Consent Order. In
accordance herewith, Kaiser-Hill will proceed with the corrective actions detailed in
NTS reports NTS-RFO-KH-ENVOPS-1997-0001, NTS-RFO—KHLL-SITEWIDE-
1997-0009, and NTS-RFO—KHLL-3710PS-1998-0001. Any required changes to



SSCHOSHHSHHHHHHSHHOHHHHHHOHOHHOHHHHHOHHHOHOCOO

Enforcement Conference Summary

The Department of Energy's (DOE) Office of Price-Anderson Enforcement (OE) held an
Enforcement Conference with Kaiser-Hill Company, L.L.C. (KH), personnel on

June 5-6, 2001, in Germantown, Maryland, fo discuss the circumstances of the events
described in the OE Investigation Summary Report in addition to KH’s proposed and
implemented corrective actions pertaining to the various events. Mr. Keith Christopher,
OE Director, began the conference by explaining this meeting would be an opportunity
for KH to make its case for enforcement mitigation. Mr. Christopher further stated that
material provided by KH would be incorporated into the docket file.

Mr. Alan Parker, [ J, in his opening statement said that through schedule pressures
personnel had lost focus of the details associated with various work activities. Mr.
Parker, though, emphasized that KH’s employees can follow procedures. Mr. Parker
then gave an overview of the timeline for the various events and corrective actions.

Mr. Kelly Trice, [ ], spoke about the Building 771 radiation safety program deficiencies.
He acknowledged that the continued use of the room [ ] containment enclosure was
aliowed by management, but also stated that the necessary approvals were not
obtained. Mr. Trice then described the revision of the self-assessment program for
Building 771; this program is simpler to use, is now done on a scheduled basis, and
assessments will go beyond determining what procedures are in place by also
assessing procedure implementation.

Mr. Paul Kreitz, [ ], provided an overview of the current procurement process-at the-site
and spoke of the previous efforcement actions concerning procurement deficiencies. A
discussion ensued between Mr. Kreitz and OE staff regarding procedural
noncompliances associated with the expedited purchase of drum lids. Due to time
constraints, Mr. Christopher directed this discussion to be continued outside of the
conference. Mr. Christopher then adjoumed the conference for the day.

The conference resumed the following morning (June 6) with Mr. Marvin Brailsford, [ ],
discussing the [nuclear] safety and authorization basis deficiencies described in the
DOE's investigation summary report. Mr. Brailsford then followed this discussion with
an overview of the corrective actions taken to date. Mr. David De! Vecchio, [ J,
provided a similar overview and discussion regarding [nucleas} safety and authorization
basis deficiencies in Building 707 activities.

Mr. Ken Powers, | ], addressed the management assessment deficiencies.

Mr. Lincoln Hall, [ ], provided his perspective of the events and described the corrective



Cy

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

February 8, 1994
MEMORANDUM FOR: _ Technical Director
COPIES: Board Members
FROM: Richard BE. Tontodonato
SUBJECT: Trip to Review Feed Characterization for Rocky Flats Plant

Building 707 Thermal Stabilization Process, January 20, 1994

1. Purpose: This memorandum is a report by the DNFSB staff (Richard Tontodonato and
Davis Hurt) on a visit to the Rocky Flats Plant on January 20, 1994 to review the
characterization of feed materials for the Building 707 thermal stabilization process.

2. Summary: EG&G has completed characterization of the brushings and other ordinary
plutonium oxide materials currently identified as feed for thermal stabilization, and has
characterized some of the duct residues planned to be stabilized. Results from testing

oxides indicate, as expected, that these materials will be safe to process in the Building 707

calciners. Plutonium-bearing duct residues, however, undergo large weight losses when

heated and may not be adequately stabilized if only heated to 500°C. Reduced batch sizes,

slower heat-up rates, and a higher stabilization temperature may be required to safely
stabilize them. The Stabilization Technical Review Group, a group of EG&G piutonium

‘experts assigned to evaluate ‘the characterization results, has not yet decided what testing or

analysis is needed to determine how to process the duct residues.

3. Background: The Department of Energy plans to restart two calcining furnaces in
Building 707 for urpose of converting potentially unstable plutonium materials to

le plutonium Office (DOE-RFO) and EG&G-Rocky

"FIGS (EGR) personnel did hot originally plan to perform any chemical analysis or other

objective characterization of the feed materials. However, the Board believed it would be

tisky to process some of the materials, particularly the oily duct residues, without

understanding more about their compositions. After significant discussion, DOE-Office of

Defense Programs (DOE- ‘DP) management agreed that feed characterization was
warranted. Subsequently, at the Board's February 1993 public meeting in Boulder,

Colorado, DOE representatives stated that they had developed a plan to sample each can of

duct residue and perform selected chemical analyses to ensure these materials could be
safely stabilized. In March 1993, the DNFSB staff reviewed the characterization program



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procurement processes occurring during the August 2000 procurement of 500 55-gallon
replacement drum lids. The drum lids were intended for use in nuclear wasie interim
storage and eventual shipment of the waste to the Waste Isolation Pitot Program
(WIPP). Durihg the procurement action, Kaiser-Hill Company (KH) ordered the drum
lids despite the fact that two mandatory quality assurance reviews of the drum lid
requisition had not been completed. Furthermore, ihe drum lids were ordered to a
specification that was not designed for drum Sid replacement parts and KH did not
formally establish receipt inspection criteria. Al} 500 drum ids were ultimately rejected
for use due to design and fabrication defects, and transportation damage.

Section IV of the PNOV describes procedural! imptementafion and As Low As.
Reasonably Achievable (ALARA) deficiencies associated with the implementation of the

Buildi lation Safety Progra m. These deficiencies were identified in
association with specific event: mber 2000 involving

inadequatel ssaciated with contaminated air-mover

preparation and airline removal. Your investigation into an Ostoher 2000 event

involving an out-of-calibration air sampler identified additional concerns related to

* radiological procedural compliance, adequacy and compliance with work controls, and

éffectivenéss oF management oversight.

Section V of the PNOV describes violations of the quality improvement provisions of

10 CFR 830. The breakdowns cited in this section demonstrate a failure by KH to
correct previously identified and long-standing quality problems in the areas of
Procurement, [Nuclear] Safety, and Authorization Basis implementation. Effective
correction of these problems upon their initial identification would have prevented the
majority of the events and deficiencies cited in the PNOV. An associated underlying
weakness is the ineffective implementation of your assessment programs. This concern
was recognized by several of the KH root cause determinations performed in
conjunction with the subject events.

-In-accordance with 10 CFR 820, Appendix A, “General Statement of Enforcement
Policy,” the violations described in the enclosed PNOV have been classified as eight
Severity Level f] problems with an aggregate civil penalty of $385,000. In determining
these Severity Levels, DOE considered the actual and potential safety significance
associated with each event under consideration, the programmatic and recurring nature
of the violations, and other factors.

With respect to the [Nuclear] Safety and Waste Facility Work Control violations,

25 percent mitigation of civil penalties was awarded as several of the events were self-
identified by the contractor. Full mitigation for self-identification was not warranted
because some of the events were self-disclosing. No mitigation was awarded for
corrective actions, since the deficiencies were largely long-standing and recurrent in
nature.

No mitigation for identification or for corrective actions was awarded for the cited
Procurement violations. KH did not initially recognize the 55-gallon drum lid



~\
vs

Department of Energy
Washington, DC 20858

July 17, 2001

Mr. Alan Parker

U]

Kaiser-Hill Company, L-L.C.

Rocky Flats Environmental Technology Site
10808 Highway 93, Unit B

Golden, CO 80403-8200

EA-2001-04

Subject: Preliminary Notice of Violation and Proposed Imposition of Civil Penalty,
$385,000

Dear Mr. Parker:

This letter refers to the Department of Energy’s (DOE, Department) evaluation of the
facts and circumstances concerning a number of events and programmatic failures
affecting nuclear safety at the Department's Rocky Flats Environmental Technology
Site. The DOE Office of Price-Anderson Enforcement, in coordination with the DOE
Rocky Flats Field Office (RFFO), conducted an on-site investigation during

April 3-5, 2001. The results of this investigation were provided to you on May 14, 2001;
and an enforcement conference was held with you and members of your staff on

June 5-6, 2001, fo discuss these findings. The conference’s summary report is
enclosed. Look noe coe .

Based on the Department's investigation and information you provided during the
enforcement conference and thereafter, the DOE has concluded that violations of

10 CFR 830, “Nuclear Safety Management,” and 10 CFR 835, “Occupational Radiation
Protection,” likely occurred. These violations are described in the enclosed Preliminary
Notice of Violation (PNOV).

Sections | and If of the PNOV describe deficiencies related to the implementation of
{Nuclear] Safety and Waste Facility work control requirements. These deficiencies were
associated with a series of recent events involving fransuranic material size reduction,
container loading, and assay activities. Although the safety significance of the individual
events was relatively jow, the recurring nature and supervisory involvement associated
with several of the events reflects more fundamental concems requiring management
attention.

Section If] of the PNOV describes violations associated with the breakdown of work and

Tee


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Description: Employee was supporting removal of electrical items in the
overhead in room 149 of building 771 by line #40. Database Links
Employee's lapel air sample read 7.6 DAC and employee @ Create RIR ; ;
was without respirator protection. “ Radiation Generating Devices
IRS Supervisor —_M. Welling f Sealed Radioactve Sources
immediate PIF calculated, nasal smears taken, contamination surveys (SRS)
‘Corrective performed in the affected area, air samples taken
Action: throughout room 149, Contact
Primary Event McGinley, Pam
@ ioe: event BENE
PI x68"
: eacondary Event . PAGER: (303) 212-5374
Apparent Cause: OTHERINo source located Savitz, Kenneth R
ster
Facility Mgr: TR. Hergert ao. _| BHONe wees
IDOE 5
Categorization: Not Applicable
Occurrence Rpt.
= Now:
Responsible
Magr.: D. Boone
Responsible Dir.: K. Trice
Target Date: 42/31/2000 12:00:00 AM
Corrective P| performed, bioassay submitted for intemal disposition.
‘Actions: ‘There were no CAM/SAAM alarms. Ongoing investigation
to locate source.
PATS No.:
Comments:

ittp://rfetshp/portal/Default.aspx?PID=25&MID=335 T/A9/04



Prior to the DOE Order N5480.6, Radiological Control) Manual, no legal or
reguiatory requirement existed to control an employee's total lifetime
occupational radiation dose. Section 212 of the Radiological Control Manual
requires administrative control of a worker's lifetime occupation dose to a
total exposure equal to that worker's age in years (N rem): In addition,
Section 216 requires that special control levels be established for those
personnel who have doses exceeding their age in years. These requirements are
scheduled for implementation by January 1996, pursuant to the EG&G
Radiological Control Manual Implementation Plan.

However, due to this recently identified neutron dose concern, early
implementation of the lifetime control level and the special control level
requirements as outlined in the Radiological Control Manual will be
imp}emented soon. This wil) control future exposures to all effected
individuals until the re-evaluation of the film and/or a dose reconstruction
can be completed for each individual. This action would also include
approximately 60 additional active employees due to current internal dose
exceeding the Radiological Control Manual Vifetime control level. Special
control jevels will be established in accordance with the Radiological Contro}
Manual based upon the appropriate controls determined from these evaluations.

The special contro} level will be applied to all employees whose dose is above
the N rem control Jevel. These employees wil] have an administrative control
level of 100 mrem per year additional exposure (internal + externa)). This
control level will stay in effect until the employee falls below their N rem
level at which time the employee will be limited to the current plant
Administrative Dose Guideline.



A VE LA UU UE eI Oe DUI DUES = AUR A dude SE

around the base of the stack.

The largest reported release was in January 1954 when about 200 curies of ruthenium were released.
Hanford radiation technicians tracked the particles as far as Spokane, Washington, about 150 miles to
the northeast. In April 1954, airbome radiation equipment tracked the particles as far as northeastem
Montana.

Inhaling ruthenium particles posed a health danger. In addition, the ruthenium particles posed a hazard
if any of the large particles had fallen onto a person's exposed skin.

Hanford Assessment Not Yet Completed

Since the release of the first 19,000 pages of Hanford historical documents in 1986, much has been
learned. However, it is not enough to form a complete assessment of the impact of the Hanford releases.
This is especially true in the matter of Hanford's particle problems. For example, the HEDR Project has
not yet estimated doses from the hot particle releases.

Possible Health Problems of Plutonium, Strontium, Cerium and Ruthenium

Keep the following points in mind when reading the sections on the possible health problems of the
selected radionuclides:
animal studies. For cerium, ruthenium and strontium, the only data available are from animal studies.

+ Comparing the health effects on animals and on people exposed to radiation from Hanford is

|
|
|
e Researchers have done a few studies involving human exposure to plutonium, as well as several |
|
|
|
problematic for three main reasons: |

1. The life span of human beings is much longer than that of the animals used in studies:

|
2. Itis uncertain if humans are affected in the same way as animals. |

3. Most of the animal studies involved exposure to very high levels of radiation (equivalent to a human.
exposure of thousands of rem). Hanford exposed people to generally lower levels of radiation but over a
Jong time.

This report provides information about each of the four radionuclides. The same categories of
information are presented for each:

|

|

|

|

the possible health effects |

¢ a general description of the radionuclide

the estimated amount released from Hanford from 1944 to 1972 |

|

The dose estimates are cumulative for 1944-1992, whole body in rem EDE (effective dose equivalent). ;
The release estimates are cumulative for 1944-1972. These numbers are taken from the Hanford

Environmental Dose Reconstruction draft reports released in April 1994. Both the release and dose

estimates for the four radionuclides are not complete because: (1) the Hanford Environmental Dose

OOOH OOOHHSEOHHHHHHHHHHOHHOHOHOHHHOHHOCHOOOOOOOEO

http://swww.doh-wa.gov/hanford/publications/overview/radionuclides htm! 01/07/2005 |!


Radiation Protection - Radiological Improvement Reports (RIR)

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Db

Home > Databases > Radiological improvement Reports (RIR)

- Radiological Improvement Report Details

RIR No.:
Originator:
Project:

Date Entered:
Event Date:
Status:
DateClosed:

‘Building:
Location:
Description: —

IRS Supervisor
immediate
Corrective
(Action:

Primary Event
Code:
Secondary Event
Codes:
Apparent Cause:
Facility Mgr:
DOE
Categorization:

Occurrence Rpt,
No.

Responsible
Mgr:
Responsible Dir.:
Target Date:
Corrective
Actions:

PATS No.:
|Comments:

~ 1916 @ RCT performed a whole body frisk and discovered ©

99-485

RMRS

41/2/1999 42:00:00 AM

10/28/1999 12:00:60 AM

CLOSED

44/18/1999 12:00:00 AM

7

146B

Upon completing of the containment construction for HV-

a tiquid spot on the right forearm. Contamination was
detected at 40K dpm/100cm2. The coverails were removed:
and the same liquid and contamination was found on the
skin. The employee was immediately taken to the
decontamination room for a fifteen minute flush and then
transported to the on-site medica! facility. Surveys of the
affected area were 6K after the fifteen minute rinse.
Decontamination was completed at the medical facility.

J. Harris

Fifteen minute flush and transported the employee to
medical for further decontamination.

B4

BS, B15

EQUIPMENT
J. Obrien

Completed
99-0756

D. Burks

C. Crawford
11/27/1998 12:00:00 AM

Employee successfully deconned. A nearby valve was
found to be contaminated. It was deconned and contained.

RMRS PA Screen No. RMRS-99-897. CEDE <100 mrem
confirmed, B15 event code added 2/16/00, (das) |

ittp://rfetshp/portal/Default.aspx?PID=25&MID=335

Rad Protection Site Links

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® Video Library

——Database Links— --—-—

# Create RIR

2 Radiation Generating Devices
(RGD)

® Sealed Radioactive Sources.
(SRS)

Contact

McGinley, Pam
Webmaster

PHONE. x6818
PAGER: (303) 212-5374

Savitz, Kenneth R
Alternate Webmaster
PHONE. x4686
PAGER: (303) 212-4443

a

719104

ee


A UIE LAGU 2 AULD AP VOUS WY QUILL INCU HUCMULS 7 ALLE LIVI Aitken LEBL YUL A

Plutonium, cerium and strontium were released to the air from the original plutonium separations
plants from late 1944 through at least 1951. In the fall of 1947, monitoring equipment revealed
radioactive particles on the ground surrounding the stacks of the plutonium plants. The ventilation
system in the radioactive processing area was the source of the problem. The interior of the plants’
ventilation system had started to rust in places. Plutonium and the other radioactive materials attached
to the rust. Later, parts of the contaminated rust broke off and went up and out the stacks. The sections
inside the plants in which the operators worked had a separate ventilation system that was not affected
by the particle problem.

The particles contained plutonium, cerium and strontium. Other radioactive materials were also
present in at least some samples of the particles but in lower concentrations. Most of the particle was
rust or other non-radioactive material.

In January 1948, Hanford replaced the ventilation system. The number of relatively large
particles decreased, but smaller particles continued to escape. Hanford scientists believed that the
smaller particles had been released from the start of plutonium separations in December 1944. In March
1948, Hanford documents reported the release of as many as 100 million particles per month.

Because of their size and weight, many of the particles landed on the ground within the Hanford
Site boundaries. However, Hanford technicians detected some particles as far away as Mullan Pass
(now known as Lookout Pass) in Idaho; and Spokane and Mt. Rainier in Washington. The
concentrations of the particles at these locations were "comparable" to those in Richland (Richland is
located about 25 miles southeast of the separations plants)

Hanford officials were concemed about possible health effects on workers from hot particles. They
considered lung cancer (from the inhalation of particles) to be the most serious health threat.

Hanford radiation protection officials inaposed several work restrictions and ordered that some
workers be given filter masks. However, most workers, including construction workers and security
guards, were not issued filter masks. Hanford officials considered the plutonium particle problem so
serious in October 1948 that they stopped separating plutonium for at least three days?

; It is uncertain how long the problem with the plutoninm particles continued. According to a U.S. Senate

report, the last reference to the problem was at a meeting in 1951. Herbert M. Parker, Hanford's chief
health physicist, said at the meeting: “The particle problem still remains, in my opinion, a very serious
health problem."=

Ruthenium

After World War Il, 2 new type of chemical process was developed to recover plutonium for use
in nuclear weapons. An unintended effect of this process was that flakes of material, including
Tathenium, accumulated on the inside lining of the stack at Hanford's Redox plant. "Redox" stood for
"reduction-oxidation” and described the kind of chemistry used to separate the plutonium. As in the
case of plutonium particles, the ruthenium built up within the process ventilation system, which was
separate from the building ventilation system.

The Redox plant began operations in 1952. Shortly afterward, technicians discovered the
ruthenium particle problem. Material containing ruthenium had deposited on the inside of the stack. As
the material built up on the stack lining, some of it broke off in the form of flakes and was carried up
and out the stack. Radiation surveys found very large flakes, some several inches across, on the ground

ttp://www.doh.wa.gov/hanford/publications/overview/radionuclides. html 01/07/2005



SCOOHHHHOHHSHSOHSHHOHHHHOHOHOHOOHOCHOOHOEOEHOOOES

Exceedance of RWP Suspension Limits
NTS-RFO—KHLL-37 1 OPS-1998-0001 . |

On January 14, 1998, a sealed source custodian conducted a semi-annual inventory
and leak test of several [radioactive material] sealed sources, and was supported by a
radiological contro! technician (RCT) who had no prior source inventory experience.
The general radiological work permit for the job required a pre-job briefing and
established a 100 mrem/hour beta/gamma dose rate limiting condition of operation. No
pre-job briefing was conducted. Prior to the inventory and leak testing, the RCT
measured exposure rates in excess of 100 mrem/hour yet failed to halt any further
work. The custodian proceeded to verify each source's labeling by physically handling
each source and then swabbing it for leak testing purposes. One source had an
exposure rate of (a specified amount] at 30 centimeters. Afterwards, the RCT
discussed the event with another RCT to verify proper procedures. Dose estimates for
the custodian were [a specified amount] EDE fo the hand, {a specified amount] EDE to
the wrist, and [a specified amount} EDE to the lens-of-eye. The following radiological
control deficiencies were identified: area monitoring of the workplace, radiation safety
training, administrative controls, and work processes,

WW

DOE has evaluated the results of the investigations conducted by Kaiser-Hill and has
concluded that the findings and conclusions with respect fo these incidents are
comprehensive. DOE has concluded that these investigations fully and accurately
disclose all relevant facts, including the identification of potential violations of nuclear
safety requirements in the areas of radiation protection and quality assurance, and
objectively assess the actual, potential, or programmatic safety significance of these
poiential violations. DOE's approval of Kaiser-Hill's aggressive investigation of these
events, coupled with.similar results in a number of priof cases, leads DOE to conclude
that a full independent investigation by DOE into these matters is unnecessary and
unwarranted.

VV

DOE acknowledges Kaiser-Hill’s aggressive and comprehensive investigation to
determine the causes of these incidents, and open and objective assessment of the
operational shortcomings involved. DOE has also evaluated and agrees with the
adequacy of the corrective actions completed and the schedule for implementation of
those corrective actions that remain yet to be completed as described in the above
referenced NTS reports. In consideration of the foregoing, DOE and Kaiser-Hill have
reached agreement on this matter under which both have agreed to issuance of this
Consent Order to avoid potentially protracted and otherwise unnecessary additional
investigation by DOE; and potential challenges on the part of Kaiser-Hill to findings by
DOE, possible enforcement proceedings, Notice of Violation, and any imposed civil
penalties. DOE and Kaiser-Hill agree and recognize that in recognition of the response


SCOOHOOHHOOHEHSOHHSOSHOHOHOHOHOOOHOOEHOOOEOE

maintenance work package in room| }. Hazards associaied with the airline
removat were not recognized during the work activity and no physical design
or administrative radiological controls specific to the breach were utilized
{workers were wearing respiratory protection due to other work activities in
the room). The line breach resulted in an airborne release of [radioactive
material] and the spread of [radioactive material] contamination to the
immediate work area.

2. On August 21, 2000, personnel were swapping contaminated hoses between
two radiological air movers in preparation for using one of the air movers.
The work was conducted in an informal fashion; no procedure was in place to
control the activity, and the work had not been formally reviewed nor
approved. No formally established and effective physical design or
administrative controls appropriate to the work activity were utilized. The
activity resulted in an airborne release of [radioactive material], the spread of
minor [radioactive material] to the immediate work area, and detectable
uptakes of [radioactive material] by four individuals (two resulting in significant
doses). None of the individuals received a dose in excess of DOE regulatory
fimits.

This violation constitutes a Severity Level it problem.
Civil Penalty - $27,500

V. Quality Improvement

10 CFR 830.120(c)(1){iil) requires that “[pjrocesses to detect and prevent quality
problems shall be established and implemented. Items, services and processes that
do not meet established requirements shall be identified, controlled, and corrected
according to the importance of the problem and the work affected. Correction shall
include identifying the causes of problems.and working to prevent recurrence.”

Contrary to the above, correction fof items, services and processes] did not include
identifying the causes of problems and working to prevent recurrence in that+

A. [Nuclear] Safety

KH corrective actions have been ineffective in preventing the recurrence of long-
standing and repetitive noncompliances in the area of [nuclear] safety.
Specifically, those [nuclear] safety procedural noncompliances described in
section | of this PNOV are similar to [nuclear] safety infractions previously
reported to DOE in 1996, 1997, and 1998. DOE elected not to pursue
enforcement action based on KH’s commitment to implement corrective actions.
In the 1998 report (NTS-RFO-KHLL-SITEWIDE-1998-0003), KH acknowledged
that corrective actions were not adequately comprehensive to prevent the current
problems. During 2000 and 2001, numerous additional incidents of jnuctear]
safety problems have been identified and reported, thereby demonstrating that
prior corrective actions have been ineffective in correcting problems and
preventing recurrence. For example, corrective actions taken in response to the



Radiation Protection - Radiological Improvement Reports (RIR)
(Ell Monday, July 19, 2004 9.19:58 AM

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Radiological improvement Report Details

Project: ra)

Date Entered: 10/26/2000 12.00:00 AM

Event Date: 10/25/2000 12:00:00 AM

‘Status: CLOSED

DateClosed: 3/8/2001 42:00:00 AM

Building: 77

Location: 114

Description: While performing cut out operations of lines 8 & 9, worker
became tired and was exiting the tent. While the RCT was
doing whole body check out of the D&D worker, it was
discovered that the PAPR filter was low and employee had
contamination of 2,000 dpm on the face piece of the
respirator and 67 dpm on filter.

RS Supervisor. D. Sinner

Immediate Stopped job, checked all PAPR filters, PIF completed,

Corrective Notificaitons made. RIR written. PIF level 1.

Action:

{Primary Event

Code: BI3

Secondary Event

Codes: a“

[Apparent Cause: EQUIPMENT 2 ~

Facility Mgr: T. R. Hergert

DOE Completed

Categorization:

noourmence Rpt. 2000-0636

Mere onsible D. Boone

Responsible Dir: K Trice

Target Date: 11/24/2000 12:00:00 AM

Corrective PAPR use was investigated across the site. Bioassay

Actions: sampling was performed. PAPR unit contamination is not
unusual in the given work conditions.

PATS No.: 2000-00156

Comments:

ittp://rfetshp/portal/Default.aspx?7PID=25&MID=335

Tee

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Database Links

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# Radiation Generating Devices

RGD)
2 Sealed Radioactive Sources
(SRS)

Contact

McGinley, Pam
Webmaster

PHONE: x6818

PAGER: (303) 212-6374

Savitz, Kenneth R
Alternate Webmaster
PHONE: x4686-
PAGER: (303) 212-4443

TN 9/04



SPOHOHSHHHSHOHHOSHOSHHESNOHHOSHOHSHHHHOHHOHSHOOHSOOEOO

FOCRUAl Mealle FLOOLEUIS LOM BAPOSUFE (O DELECLED KAQLONUCIIGES - MANIOTA MedlUn L... Fags LL OL La

"Request for Independent Calculations on the Active Particle Problem.” April 20, 1992.

Till, John, Ph.D., and Charles Miller, Ph-D. Memo to the Technical Steering Panel: “Active Particle
Problem at Hanford." Undated.

USS. Senate, Majority Staff of the Committee on Governmental Affairs. “Early Health Problems of the
U.S. Nuclear Weapons Industry and Their Implications for Today." December 1989.

NOTES

1 - HW-11348. "Action Taken with Respect to Apparent Enhanced Active Particle Hazard." H.M.
Parker. October 25, 1948; p.2.

2 - HW-11348, p.2.

3 - "Early Health Problems of the U.S. Nuclear Weapons Industry and Their Implications for Today.”
Report of the Majority Staff of the Committee on Governmental Affairs, U.S. Senate, December 1989;
p. 9 - Referring to meeting notes from the Advisory Committee for Biology and Medicine, Jan. 12,
1951.

4 - Telephone conversation with Bruce Napier, June 13, 1994. Napier is a scientist with Battelle Pacific
Northwest Laboratory and worked extensively on the Hanford Environmental Dose Reconstruction
Project.

5 - There have been human plutonium studies by several groups of researchers. Three of these are:
George L. Voelz, Occupational Medicine Group, Los Alamos National Laboratory, et al. who studied
26 Manhattan Project workers at Los Alamos with 37-year follow-up after exposure (Voelz 1985); J. F.
Acquavella et al. who also considered Los Alamos workers (Acquavella 1983); and Gregg S. Wilkinson
et al. who studied Rocky Flats workers (Wilkinson 1987) .

6 - H. Metivier in Radionuclide Metabolism and Toxicity; Galle, P. and R. Masse {eds.); Paris: Masson,
1982; p. 184. The book is a compilation of papers presented at a 1982 symposium that was organized
by the French Society of Biophysics and Nuclear Medicine and the University of Paris.

7 - Gregg Wilkinson, Ph.D. "Mortality Among Plutonium and Other Radiation Workers at a Plutonium
Weapons Facility." American Journal of Epidemiology. 1987; p. 231-250.

8 - Committee on the Biological Effects of Ionizing Radiations (BEIR IV); Health Risks of Radon and
Other Internally Deposited Alpha-Emitters; Washington, DC; National Academy Press, 1988; p. 328.

«9 - Telephone conversation with Prof. Ronald Kathren, U.S. Uranium and Transuranium Registries,
July 22, 1994..

10 - George L. Voelz, MD. "Health Considerations for Workers Exposed to Plutonium.” Occupational
Medicine: State of the Art Reviews. Oct-Dec 1991; p. 694.

14 - H. Metivier in Galle and Masse, p. 193.

http:/Awww.doh.wa.cov/banford/publications/overview/radionuclides html 01/07/2005



00000000 0000000000000000000000000CCCCOCOEOe

votential Heaiwn rroblems mom Exposure to Selected Radionuclides ~ Hantord Health L... Page LZ ot 15

12 -BEIR IV, p. 325.

13 - Tawn, E.J. et al. "Chromosome Studies in Plutonium Workers.” Jnternational Journal on Radiation
Biology and Related Studies in Physics, Chemistry and Medicine, May 1985; p. 599-610.

14 -MC. Thome and J. Vennart; "The Toxicity of Sr-90, Ra-226 and Pu-239." Nature; October 14,
1976; p. 555-8. Thome is with the Radiobiology Unit in Hardwell, England.

15 - M. Thomasset. “Strontium: Metabolism and Toxicity of Strontium" in Galle and Masse, p. 104.
16 - M. Thomasset in Galle and Masse, p. 111.

17 - National Committee on Radiation Protection (NCRP) No. 110; Some Aspects of Strontium
Radiobiology; 1991; p. 32.

18 - M. Thomasset. "Strontium: Metabolism and Toxicity of Strontium” in Galle and Masse, p. 110.
19 - Telephone conversation with Bruce Napier, June 13, 1994.

20 - National Committee on Radiation Protection (NCRP) No. 60; Physical, Chemical, and Biological
Properties of Radiocerium Relevant to Radiation Protection Guidelines; 1978; p. 55.

21 -R Masse, “Ruthenium and Activated Metals" in Galle and Masse, p. 131-142.
References for Selected Radionuclides

Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Plutonium, TP-
90-21. December 1990.

Galle, P. and R. Masse, eds. Radionuclide, Metabolism and Toxicity. Paris: Masson, 1982.

NCRP Report No: 60. Physical, Chemical, and Biological Properties of Radiocerium Relevant to
Radiation Protection Guidelines. Washington, DC: National Council on Radiation Protection and
Measurements, 1978.

NCRP Report No. 110. Some Aspects of Strontium Radiobiology. Bethesda, MD: National Council on
Radiation Protection and Measurements, 1991.

Published Fall 1994

DOH Home | Access Washington | Privacy Notice | Disclaimer /Copyright Information

Office of Radiation Protection
7171 Cleanwater Lane, Building 5
PO Box 47827

Olympia, WA 98504-7827

(360) 236-3220

hitn-jww Anh wa cov/hanford/nnbiicatiandaverview/radiannetides htm? O1NTMANS



Radiation Protection - Radiological Improvement Reports (RIR)
BSB Monday, July 49, 2004 9 10:51 AM

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Welcome,
Steve Trujillo

Back |< | Greate BIR

pS

Home > Databases > Radiological Improvement Reports (RIR)
Radiological Improvement Report Details.

RIR No.
Originator:
Project:

Date Entered:
Event Date:
Status:
DateClosed:
Building:
Location:
Description:

IRS Supervisor
immediate
Corrective
Action:

Primary Event
Code:

‘Secondary Event
Codes:
[Apparent Cause:
Facility Mgr:
(DOE
(Categorization:
Occurrence Rpt.
INo.:

Responsible
‘Mor.:

Responsible Dir.:
Target Date:

Corrective
Actions:

PATS No.:
‘Comments:

99-540

771

12/14/1999 12:00:00 AM

42/13/1999 12:00:00 AM

CLOSED

1176/2000 12:00:00 AM

771

179

After placing several packages into an approved waste
container, the employee self monitored using a combo. The|
combo identified the possibility of contamination, the RCT
confirmed 10k dpm total activity on the anti-c gloves. Nasal
and mouth samples were taken because the PIF was
calculated at 6.25. The waste packages were resurveyed
along with Anti-c gloves wom from the previous day and afl
surveys were <500 dpm. The source of the initial 10k dpm
could not be focated.

J. Harris

Stopped work and verified all boundaries. Contacted
intemal Dosimetry.

B13

OTHER/Packaging _
J.J. O'Brien

Not Applicable

G. Bracken

A. Parker

4/12/2000 12:00:00 AM

All actions were taken in accordance with approved
procedures. Work was stopped pending a complete
investigation. No further actions are required.
2000-000124

RMRS PA Screen No. RMRS-99-1060 Letter ARL-007-00
sent to Gary Bracken requesting copy of PIF and surveys
for closure on 5/26/2000. Copy of PIF submitted, but no
survey copies can be produced. Closed without surveys-bjs|

11/6100.

wttp://rfetshp/portal/ Default.aspx?PID=25&MID=335

ee

Rad Protection Site Links

# Radiation Protection

# TBD Log
2 Training
# Video Library

_Database Links

@ Create RIR
2 Radiation Generating Devices

(RGD)
# Sealed Radioactive Sources
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Contact

McGinley, Pam
Webmaster

PHONE: x6818

PAGER: (303) 212-5374

Savitz, Kenneth R
Alternate Webmaster
|. PHONE: x4686_. ___ __
PAGER. (303) 212-4443



Office of Price-Anderson Enforcement

June 5-6, 2004
Kaiser-Hill Company, L.L.C.

{Nuctear] Safety, Authorization Basis, Procurement,
Building 771 Radiation Safety Program, and Quality Improvement Deficiencies

Enforcement Conference List of Attendees

Rocky Flats Field Office

R. Keith Christopher, Director

Sharon Hurley, Enforcement Officer
Peter Rodrik, Enforcement Officer
Anthony Weadock, Enforcement Officer
Steven Zobel, Enforcement Officer
Steven Hosford, Technical Consultant

Office of Environmental Management

Barbara Mazurowski, Manager
Paul Hartmann, Assistant Manager
Lisa Bressler, PAAA Coordinator

Office of Environment, Safety and Health

Henry Himpler, PAAA Coordinator
M. Ellen Chitwood, EM-5

Maria Gavrilas-Guinn, EM-5

Marc Jones, EM-33

W. Alexander Williams, EM-33

Kaiser-Hilt Company

Alan Parker, { ]
Lincoin Hall, [ J
Frank Casella, [ ]
Steve Crowe, | J
Kelly Trice, [ ]

Ken Powers, [ }
Marvin Brailsford, [ ]
David Dei Vecchio, { ]

SCOOOSOHOHHOHOHSOHOSHOHSHOHSHHHHHHHHHHHOOOCOHOOOEOS

Bill Weaver, EH-3



Radiation Protection - Radiological Improvement Reports (RIR)
Monday, July 19, 2004 9-17:52 AM

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Radiological Improvement Report Details

FUR Ni 00-397

Originator:

Project: 77

Date Entered: 10/49/2000 12:00:00 AM

Event Date: 40/16/2000. 12:00:00 AM

Status: CLOSED

DateClosed: 12/18/2000 12:00:00 AM

Building: 774

Location: 186

Description: During a tour/walkdown, a DOE representative found an

out of calibration low volume air sampler connected to an
SSC tent in room 186. Air sampler in question is low vol. #
HO6027, with a cal due of 9/2/00. Therefore, inadequate
alr sampling was performed during this fime.

IRS Supervisor A.C. Vigil

immediate Sampler was tagged out and removed from service, and

Corrective replaced with a valid in cal sampler. 771 rad manager and

‘Action: CCA notified. An investigation as to what work, when it was,
C done, how tong, and who was in the 186 tent at those times]

was initiated.

Primary Event Bt

Code:

Secondary Event

Codes: - -

‘Apparent Cause: PERSONNEL

Facility Mgr: H, CLerum

DOE “Smaps

Categorization: Completed

‘Occurrence Rpt. 2000-0613
No.:

Responsible

Mgr.: D. Boone

Responsible Dir.: K. Trice

Target Date: 11/15/2000 12:00:00 AM

Corrective Interviewed monitors, issued personnel corrective actions,

‘Actions: calibration of air samples required, no adjustments, sample
results were verified for the time in question.

PATS No.: 2000-001496

Comments:

ittp://rfetshp/portal/Default.aspx?PID=25& MID=335

Rad Protection Site Links
@ Radiation Protection
@ Alpha Group
Briefings
# Calc Log
? Databases
@ Documents
@ Final Surveys
2 Forms
@ Mission
@ Procurement
2 TBD Log
@ Training
@ Video Library

Database Links

# Create RIR

@ Radiation Generating Devices
(RGD)

@ Sealed Radioactive Sources
(SRS)

Contact

McGinley, Pam
Webmaster

PHONE: 6818
PAGER: (303) 212-5374

Savitz, Kenneth R
Altemate Webmaster
PHONE. x4686. _
PAGER: (303) 212-4443

a

Es

T9104

_


April 14, 1998 aA

Mr. Robert Card

{1

Kaiser-Hill Company, L.L.C.

Rocky Flats Environmental Technology Site
P.O. Box 464

Golden, CO 80402-0464

EA 98-03

Subject: Consent Order Incorporating Agreement between U.S. Department of Energy
and Kaiser-Hil! Company, L.L.C.

This letter refers to the Departrnent of Energy's (DOE) evaluation of the facts and
circumstances presented to DOE by Kaiser-Hill Company, L.L.C.'s (Kaiser-Hill) internal
investigation reports of three events that occurred at the Rocky Flats Environmental
Technology Site between January 1996 and January 1998.

These events involved (1) an unplanned {radioactive material] uptake by two workers
during a CERCLA Tank Remediation Project conducted by Rocky Mountain
Remediation Service (RMRS), a sub-contractor to Kaiser-Hill; (2) seventeen workers
receiving small radiation exposures as a result of inadequate assessment. of area
dosimetry data for sev. i s containing radioactive materi:
; (3) an RMRS sealed source custodian receiving unnecessary exposure while
performing a radioactive source inventory and leak test. .

While the actual safety significance of these events was low and none of these
incidents resulted in radiation exposures at or near the limits specified in the
Occupationat Radiation Protection Rule (10 CFR 835), DOE is concerned because
these events collectively indicate significant weaknesses in the conirols necessary to
perform work safely.

DOE has evaluated the results of the internal investigations of these events conducted
by the Kaiser-Hill team and has concluded that the findings and conclusions with
respect fo these events have been comprehensive. DOE has concluded that these
investigations disclose all relevant facts and objectively assess the actual, potential, or
programmatic safety significance of these events. DOE's approval of the Kaiser-Hill
team’s aggressive investigation of these events, coupled with similar results in a
number of prior cases, leads’ DOE to conclude that any further investigation into these
matters by DOE is unnecessary and unwarranted.

es



‘Special Exposure Cohort Petition, Form B OMB #0920-0639 Expires 05/31/07
Appendix - Continuation Page

ACRONYMS AND ABBREVIATIONS

AMAD - Activity Median Aerodynamic Diameter

CEDE - Cumulative Effective Dose Equivalent

DAC ~ Derived. Air Concentration

D&D ~ Deactivation and Decommissioning

DNESB - Defense Nuclear Facility Safety Board

DOE - Department of Energy

EEOICPA - Energy Employees Occupational nesses Compensation Program Act
Ge - Geranium.

ICRP ~ International Commission on Radiological Protection
NIOSH - National Institute of Occupational Safety and Health
NDT - Nondestructive Testing

NTA - Nuclear Track Emulsion Type A films

Pa~ Plutonium

FUSPS ~ Plutonium Stabilization and Packaging System.
RadCon ~ Radiation Control Manual

RFETS - Rocky Flats Environmental Technology Site

RV - Reaction vessel

SAAM - Selective Alpha Air Monitor

SEC - Special Expostire Cohort ;

SS&C ~ Sand, slag and crucible

TLD - Thermoluminescent dosimeter

TBD -~ Technical Basis Document

USWA - United Steelworkers of America

The USWA, Local 8031 reserves the right fo provide additional information beyond that which is included in this pefition
30

and in support of our ability to obtain Special Exposure Cohort designation for the Rocky Flats class of workers.



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PRELIMINARY NOTICE OF VIOLATION
and
PROPOSED IMPOSITION OF CIVIL PENALTY

Kaiser-Hill Company, L.L.C.
Rocky Flats Environmental Technology Site

EA-2001-04

During a Department of Energy (DOE} investigation conducted on April 3-5, 2001,
violations of DOE nuclear safety requirements were identified. In accordance with the
“General Statement of Enforcement Policy,” 10 CFR 820, Appendix A, DOE proposes to
impose civil penalties pursuant to section 234a of the Atomic Energy Act of 1954, as
amended, 42 USC 2282a, and 10 CFR 820. The particular violations and associated
civi} penalties are set forth below.

{. [Nuclear] Safety

10 CFR 830.120(c)(2){i) requires that “[wjork shail be performed to established
technical standards and administrative controls using approved instructions,
. procedures, or other appropriate methods.”

Contrary to the above, work was not performed to established technical standards
and administrative controls using approved instructions, procedures, or other
appropriate methods in that work activities associated with the size reduction of
fradioactive material} items, the loading of nuclear materials into transuranic (TRU)
waste containers, and the handling and storage of TRU waste containers, were not
performed in accordance with approved procedures and [nuclear] safety operating
limits. Specifically:

A. [Radioactive Material] Size Reduction Activities: The [radioactive material] sizing
procedure, PRO-556-FO-1025, and the corresponding [nuclear] safety
evaluation, JCG-21, required operators to (1) re-secure sized [radioactive
material] pieces in part carriers prior to initiating can-loading activities, and (2)
empty, and verify empty, any partially filled can used for packaging newly-sized
{radioactive material] pieces. However, on June 22, 2000, Kaiser-Hill Company
(KH) identified that operators were placing a partially filled [radioactive material]
can in the work area and loading the can as [radioactive material] pieces were re-

0OOOOOOOOOHOHCOOHOOCOEHOOOOOOOCOCOOOOCOEOOEO®S


| Radiation Protection - Radiological Improvement Reports (RIR) Page 1 of 1
Wil Monday, July 19, 2004 9:16:47 AM Portal Directory Portal Search Portal Sitemap.

Reperis RR} Steve Trujito

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ise
Ey

Home > Databases > Radiological Improvement Reports (RIR)

| Radiological Improvement Report Details Rad Protection Site Links
: ean NN @ Radiation Protection
fur Ne. 00-332 2 Alpha Group

Originator: : cael
j Project: TM @ Databases
. [Date Entered: 8/23/2000 12:00:00 AM 2 Documents
Event Date: 8/21/2000 12:00:00 AM 2 raat Surveys
Status: CLOSED # Mission
DateClosed: 10/12/2000 12:00:00 AM ® Procurement
@ TBD Log
Building: 771 2 Training
Location: 480K ” Video Library
Description: While moving a 4” hose from the one INOEX airmover to
another one, a CAM alarmed. RCT found 100,000 dpm | _, Database Links
removable on fop of the airmover 1 square foot. Also 3, # Create RIR ;
000 dpm removable on flat surfaces in the room 100 @ Radiation Generating Devices
square feet. 1 RCT had 1,500 dom on left shoulder and (RSD) 4 Radioactive S
back area of the anti-cs. They also found 2,520 dpm under iss) led Radioactive Sources
chin 16 square inches. 600 dpm on the chest on the skin
20 square inches. Also 2,160 dpm on the back of his head Contact
and 1,800 dom left side of his head by the ear in his hair. =
CAM had 4,516 dpm on the filter paper. McGinley, Pam
@ RS Supervisor D. Sinner ~ PHONE: x6818
immediate All personnel left the area responding RCT surveyed PAGER: (303) 212-6374 |
Corrective personnel. Contained the contamination on the one person Savitz, Kenneth R |
Action: and exited to the decon room with employee. No Savitz Webmaster |
contamination on another personnel. Contacted CCA and |. | PHONE: x4686 |
RCTTS. RCT deconned in the Bidg with mild soap and PAGER: (303) 212-4443,
water. PIF completed on all personnel. Level | nasals were |
taken. |
wo. . +> [Primary Event 5 |
Code: Ba |
Secondary Event |
Codes: BS, B7, B11, B13 |
Apparent Cause:
Facility Mgr: T. R. Hergert
DOE fi
Categorization: Not Applicable

ocurrence Rpt. 2002-0002
lo.

Responsible T. Dieter

Mgr.
Responsible Dir.: K. Trice
Target Date: 9/20/2000 12:00:00 AM.
Corrective Completed immediate actions, performed bioassay
Actions: analysis and conducted project wide training on “scope
@ creep” seminars. Price Anderson materials completed for
investigation.” .
PATS No.: 2000-001269
‘Comments: Cross reference RIR# 00-412.-bjs
a

|
|
uttp://rfetshp/portal/Default.aspx?PID=25&MID=335 T1904
|
|
|



technicai specification requirements (TSRs). Specifically:

A. Building 440 Specific AB Issues: . The Building 440 Basis for Operation (BFO),

Revision 7, required the following controls:

1. Ridged Liners for Drums stacked higher than the second tier.
2. AB Surveillances within specified time freauencies.

3. Minimum aisle spacing limits.

4. Protection of electrical panels with concrete barriers.

However, KH identified in July and August 2000 that Building 440 routine waste
handling and storage operations were not being conducted in accordance with
the above AB requirements for an undetermined period of time.

. Building 664 Specific AB Issues: The Building 664 AB contains a TSR limit and

corresponding Limiting Condition for Operation (LCO) action statements on the
amount of nuclear material in radioactive waste containers.

However, KH identified in February 2000 that the facility was storing 19 waste
drums that exceeded the TSR limits. A second AB violation occurred upon
discovery of the drums when the facility management failed to curtail all facility
operations in accordance with the above LCO action statements. These drums
were stored in Building 664 since August 1997 when the new AB for the facility
established requirements prohibiting storage of these drums. Laboratory
analysis of assay information, although available, was not used to determine
compliance during a 1997 AB implementation inventory.

. Container Re-assay Work Control Issues: KH did not develop an effective work

control process for timely notification to facility management of changes in waste
container assay values. The container assay value affects the facility compliance
with the AB TSR8. TSR LCO actions require the facility operations to be
terminated and the facility returned to a compliant state within [specified] days.
Specifically:

1. In Building 440, the re-assay of two drums in January 2001 identified higher
nuclear material contents in excess of the TSR limits. However, the facility
continued to store the drums unti! February 22, 2001, when the LCO action
statements were entered.

2. In Building 664, one drum was re-assayed in January 2001 with new material
values in excess of the TSR limit. LCO action statements were not entered
until February 22, 2001.

3. In Building 991, the re-assay of three drums in December 2000 identified
nuclear material contents in excess of the TSR limits. LCO action statements
were not entered until February 26, 2001.

This violation constitutes a Severity Level {§ problem.



coatings used in molds may also be involved. IR revealed little about the nature of
the duct residues, the only conclusion being that some of the samples may contain
hydrocarbon oils.

Discussions with members of the Stabilization Technical Review Group revealed
that they have not yet decided what additional testing, if any, will be done to
define how to safely stabilize the duct residues. Their opinion was that the duct
materials could probably be safely stabilized either by limiting the batch size or
by heating to a relatively low temperature (perhaps 200°C), holding there to
allow gases to evolve at a manageable rate, then heating up to the stabilization
temperature, possibly above 500°C. Additional TGA testing, using reduced
heating rates and hold times at different temperatures, will be needed to define
this modified process. The members of the Stabilization Technical Review
Group did not envision performing other laboratory analyses to more precisely
determine the constituents of the residues. From a safety perspective, this is
acceptable, but it does not address the potential for RCRA-regulated constituents
in the residues.

5. Conclusions:

a. As expected, characterization of plutonium oxide feed materials indicates that they can
be safely stabilized in the Building 707 calciners.

b. Characterization results for the plutonium-bearing duct residues indicate that procedural
or process changes will be needed before they can be safely stabilized in the Building
707 calciners. Continued DNFSB staff attention is warranted to ensure DOE-RFO and --
EG&G adequately resolve this problem. ~

a

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A VUUALG LLUGUULE oA VURAL LOVE LAP USULY UY OULSEULUL ANGUIUMULLUUED ~ LRAUIULU AICI dee, LBL LU UL LD

Unresolved Issues Concerning Hanford's Hot Particles

During the preparation of this report, the technical reviewers raised several important points that
should be incinded.

Karl Z. Morgan, Ph.D., expressed great skepticism with the estimate for the amount of plutonium
released from Hanford. The current estimate from the Hanford Environmental Dose Reconstruction
Project is 1.78 curies of plutonium released to the air. Based upon his experience at the Oak Ridge
(Tennessee) nuclear weapons facility and his knowledge of Hanford processes, Morgan believes that
the current estimate is "a gross underestimate.” Morgan is regarded by many as the father of health
physics and was chief of radiation protection at Oak Ridge. He was chairman of the Intemal Dose
Commnittees of both the International Commission on Radiological Protection (ICRP) and the National
Committee for Radiation Protection (NCRP) from 1949 to 1971. These committees set the maximum
permissible radiation exposure limits on the international and national level, respectively.

Professor Ronald L. Kathren felt it was important to state that, given the current low radiation dose
estimates from the selected radionuclides, it is "extremely unlikely” that there will be any measurable
health problems among those exposed to Hanford's radiation releases. "Measurable health problem”
means an effect that could be determined by an epidemiological study as being related to exposure from
Hanford's radiation. Kathren is the director of the United States Transuranium and Uranium Registries
and a professor at Washington State University.

Tim Connor stated that the assumption by the Hanford Environmental Dose Reconstruction Project
that all of the plutonium released by Hanford to the air was in a soluble form is tenuous at best. Connor
is concerned that even if the plutonium separated at Hanford was initially dissolved by nitric acid,
further steps in the separation process would have resulted in transforming at least some of the soluble
plutonium to an insoluble form. Thus, a considerable fraction of plutonium escaping to the atmosphere
may have been in an insoluble form. Connor is a researcher with the Energy Research Foundation in
South Carolina and was a staff member of the Hanford Education Action League (HEAL) for several
years.

Summary

While comparisons to specific individuals are often uncertain, the information in this report may help
identify potential health problems from exposure to Hanford's releases of plutonium, cerium, strontium
and ruthenium. An important point to recall is that the estimates of the amounts released and the doses
received are not yet complete.

The Technical Steering Panel completed its role in 1995. The federal Centers for Disease Control and
Prevention (CDC) is now working with the HEDR Task Completion Working Group to continue public
participation and to assure completion of the remaining HEDR activities.

References for the History of Hanford's Hot Particles

Stohr, Joe. Memo to the Technical Steering Panel and the Centers for Disease Control: "Preliminary
Review of Documents Describing Hanford Particulate Releases, 1944-1954." December 26, 1990.

Thomas, Jim. Hanford Education Action League (HEAL) Memo to the Technical Steering Panel:

http:/Avww.dob.wa.gov/hanford/publications/overview/radionuclides html 01/07/2005



actions to date as a basis for enforcement mitigation. Mr. Hall further indicated the
procurement deficiencies were not as troublesome to KH as they appeared to be to the
DOE. Mr. Parker then gave the closing remarks for the KH presentation.

Mr. Christopher stated that KH’s presentation and other information would be taken into
consideration for the DOE’s enforcement deliberations. Mr. Christopher also asked that
the procurement issues discussed the day before be concluded within ten days. The
conference was then adjourned.



and concluded that it adequately addressed potential calcination safety issues. (documented
ina trip report forwarded by the Board to DOE-DP on March 19, 1993)

4, Discussion: EG&G has completed characterization of the brushings and other ordinary
plutonium oxide materials currently identified as feed for thermal stabilization, and has
characterized some of the duct residues planned to be stabilized. Twelve containers of duct
residues have been sampled and analyzed, and another 16 containers are scheduled to be
sampled once thermal stabilization begins. EG&G does not pian to sample the remaining
59 containers of duct residues in FY 1994 because they are not scheduled to be stabilized
in FY 1994. Test methods and results to date are described below:

a. Test Methods: EG&G uses thermogravimetric analysis (TGA) and infrared
spectroscopy (IR) to characterize two samples from each can of feed material. In
‘FGA, a 15-30 milligram sample is heated in air to about 900°C, and weight changes
are monitored as a function of temperature. Weight losses can be caused by
evaporation of absorbed water or other volatile materials or by chemical reactions
evolving gaseous products. Weight gains are typically due to oxidation of plutonium
metal. This test can be used to estimate how much plutonium metal is in a sample, and
whether significant chemical reactions occur when it is heated.

In IR, a two milligram sample is mixed with 300 milligrams of an infrared-inert
material, formed into a one millimeter thick pellet, and iduminated with an infrared
source. Absorption is measured as a function of infrared wavelength. Organic species
and some inorganic materials can often be identified using this process.

b. Test Results:

(1) Oxides: Oxide materials showed a small (1-2% ) change in weight in TGA, and
contained essentially no IR-active constituents. These materials should be safe to
calcine. EG&G is also using the TGA results to estimate the plutonium metal fines
content of the samples. EG&G is considering removing containers with sufficiently
low plutonium metal fines content from heat detectors, to make room for storing
uncharacterized scrapings that will be generated in the upcoming plutonium metal
repackaging effort.

(2) Duct residues: Duct residues experienced up to 80 percent weight loss in TGA,
indicating they are vastly different from the oxide materials. Most of the weight
loss occurs below 500°C, but some samples showed noticeable weight losses up to
about 800°C. EG&G plutonium experts consider it likely that the weight loss is
due to organic material in the residues burning in the test, but suspect that inorganic

2



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Radiological Improvement Report Details
7 # Radiation Protection
99-490 @ Alpha Group
@ Briefings
@ Calc Lor
RMRS 2 Databases
11/4/1989 12:00:00 AM a Documents
904 z sveys
14/2/1999 12:00:00 AM 2 Forms
CLOSED . 2 Mission
DateClosed: 11/18/1999 12:00:00 AM ® Procurement
@ TBD Log
Building: 771 2 Training
Location: 187 * Video Library
Description: Employee was reaching into B-80x187E and contaminated aa
- his left glove and elbow of coveralls. Contamination levels Database Links
were at 100,000 dpm on glove and coveralls, # Create RIR . .
RS Supervisor M, Fitzpatrick” *Raation Generating Devices
immediate Contained and removed contaminated clothing and 2 Sealed Radioactive Sources
Corrective escorted employee to west SOP. No other contamination (SRS)
Action: was found after full body frisk and survey of area in room
187. Contact
Primary Event McGinley, Pam
e Code: B13 Webmaster
PHONE: x6818
eeuetay Event PAGER: (303) 212-5374
a Savitz, Kenneth R
Apparent Gause: PROCEDURE/TRAINING ‘Atternate Webs :
Facility Mgr: K. D. Stovat PHONE: x4686
DOE PAGER. (303) 212-4443
Categorization Completed
Occurrence Rpt.
_ No.: ~- - 98-0786
Responsible
Mgr: L. Rosenbrock
Responsible Dir.: A Crawford
Target Date: 12/1/1999 12:00:00 AM
Corrective Nasal smears taken. Fecal samples submitted. Body count.
Actions: Fact finding meeting determined B-Box was incorrectly
posted. RIR 99-493 generated to address B-Box posting.
PATS No.:
|Comments: RMRS PA Screen No. RMRS-99-1000
s
uttp://rfetshp/portal/Default.aspx?PID=25&MID=335 TN9N4

re


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PLUTONIUM: 5
4 oe o
Leukemia 7 Ww owe mon
fe tf
There are conflicting opinions in two studies regarding plutonium exposure and the risk of. leukemia. wv sy a

FOULCUUAL DEAL FLOVICLLS LOU DAPOSULE LO OCLEGEG KACLODUCHGES - MANIOTG Peale ML. Page o OL 12

When plutonium isi i i ¢ form, most of it that is retained in the body remains in

the respifatory tract. In this kind of exposure, cancers of the lung are possible. Plutonium workers are
CaN apoced tt the insoluble forms of plutonium. Studies of these workers have not found an
increased risk for lung cancer that is related specifically to plutonium exposure.‘ In animal studies,
nearly ali animals that were exposed to high doses of insoluble plutonium died either of extensive lung
damage or fang cancer.

Most insoluble plutonium particles that are inhaled are removed from the body within a few days.
Some particles are veroved va the lymph ESS Some of these pariicles may remain in the lymph
nodes for years. In animal studies, exposure caused the lymph nodes to stop functioning properly.
Dr. H. Metivier with the Experimental Toxicology Laboratory in Montrouge, France, has suggested that
plutonium could weaken the immune system in humans and lead to the development of cancers ouside

ae

of the lymph nodes!
———

(
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In 1987, a study of Rocky Flats workers by Dr. Gregg S. Wilkinson (then at the Los Alamos National |
Laboratory) and others concluded that workers who had plutonium inside their bodies had an increased |
risk of lymphopoietic neoplasms (tumors affecting a kind of white blood cells).? A report by the (
Cornmittee on the Biological Effects of Ionizing Radiations of the National Research Council (BEIR |
IV) was skeptical about this finding because the Rocky Flats study did not show any increases in lung, |
done or liver cancers.£ |

|

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Plutonium in a soluble form acts differently in the body than the insoluble form. Instead of
remaining in the lungs and the iymph-nodes-as the soluble form does, soluble plutonium enters the
blood relatively quickly and deposits on bone surfaces and in the liver. About 40 percent of the

lutonium that enters the biood goes to bone surfaces, 40 percent to the liver and the remaining 20
percent fo Guscle? Ira paso is exposed to soluble phitonium, cancers of the bone and liver are
possible, with the likelihood dependent on the dose.

Some scientists stress the need for additional studies on humans because of the long time lapse between
exposure and when cancers are diagnosed. This period 1s called the latency period. For plutonium, thé

latency od is estimated to be more than 30 years, but may vary depending on the dose received 2
ot du scahaens enaranatD EE

Leukemia is 2 cancer of the blood and begins in the blood cells formed within the bone. Metivier stated © .
at a symposium presented by the French Society of Biophysics and Nuclear Medicine in 1982 that there ¢* ou
is a possibility of leukemia if the bone marrow is exposed to plutonium. 4! However, the 1988 BEIRIV x >
report stated there is no evidence that plutonium can cause leukemia” In humans, relatively little we
plutonium is found in the bone marrow, and the dose to this tissue is quite small compared to the dose“ -
to the bone surfaces. The risk of leukemia from exposure to plutonium is likely to be far less than the ie pou?
tisk of bone cancer. qh eye

ys rx
PLUTONIUM: ore
o
Chromosome Aberrations ve ws

E. Janet Tawn and her colieagues in the Medical Department at British Nuclear Fuels, Sellafield, oe ot in

eee

hittp://www.doh.wa.gov/hanford/publications/overview/radionuctides.htnl 01/07/2005 y



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Attachment 2
MTS-193-94
Page 1 of 2

SYNOPSIS OF NEUTRON BOSE ISSUE

In August of 1992, the Health Effects Department of EG&G Rocky Flats, Inc.,
received funding from the Department of Energy to medically monitor the health
of former radiation workers and to re-evaluate doses to workers from plutonium
and other ionizing radiation exposures at the Rocky Flats Plant primarily in
building 771. The re-evaluation of doses in former workers is presently
underway and a status report on this project was given on May 18, 1994. The
status report included the following preliminary conclusions:

- The radiation workers most exposed to neutrons in the early 1950's
{until July 1958) were not monitored for neutron doses.

- Neutron doses were poorly evaluated from neutron film until 1967.

These conclusions also indicate that the accuracy and completeness of
historical neutron data prior to 1968 is in question. This could have the
effect of underestimating the neutron doses reported for workers during this
time period. Several neutron film from the late 1950s to the early 1960s have
been re-read and many doses reported as zero (0} actually should have been
reported higher than zero. Other film which were evaluated that had indicated
a non zero exposure actually read zero.

Since only a small portion of the film was reviewed there is little indication
of the magnitude of the problem until the previous personnel neutron dose for
these individuals can be re-evaluated. However, it must be noted that the
risk received by these employees from this radiation exposure has already been
incurred by these employees and through administrative controls, further
occupational radiation risk can be limited. - . -

An initial personnel record search was performed to identify present active
employees who had worked at Rocky Flats prior to 1968. The search indicated
that there are approximately 138 individuals who meet this criteria. A
preliminary review of the individual work locations and exposure history was
also performed. Of the 138 employees 80 have been identified as workers who
had worked in building 771 prior to 1968.

For the 138 individuals identified who worked at Rocky Flats prior to 1968 a
neutron dose was estimated using a neutron to gamma ratio. A neutron to gamma
ratio was determined by reviewing the neutron and gamma doses for the
different processes in building 771. From the neutron and gamma doses a 2 to 1
neutron to gamma ratio was determined. Using the neutron to gamma ratio,
neutron doses were estimated using each individuals gamma dose for each year
of employment prior to 1968. The estimated neutron doses were then added to
the individuals lifetime dose and an estimated total lifetime dose was
created. Until dose reconstructions can be completed, this estimated lifetime
dose will be used to determine N rem work limitations.



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7

Euvdronmental Health Programs
Hanford Health Information. Network

You are here: DOH Home » EH Home » HHIN » Potential Health Problems from Exposure to

Selected Radionuclides

Search |
Employees

Lmportant Notice: The Hanford Health Information Network (HHIN) closed in May, 2000. HHIN
Web pages are provided as archived information only, and are noi currently maintained. Information

contained on the HHIN Web pages may be out-of-date.

All HHIN publications are available.

A PUBLICATION OF THE
Hanford Health
Information Network

hae

Plutonium, Strontium, Cerium and Ruthenium

For more than 40 years, the U. S. government produced plutonium
for nuclear weapons at the Hanford Site in south central
Washington State. In 1986, responding to citizen pressure, the U.S.
Department of Energy made public hundreds of previously __
restricted: documents. Since then, mich attention has focused on
the very large releases of iodine-131 as a possible cause of thyroid
disease. However, Hanford also released other forms of radiation
into the air and the Columbia Rivet.

This report examines the releases of four radionuclides to the air
and the potential health effects which might result from people
being exposed to these materials. The four radionuclides are:
plutonium, strontium, cerium and ruthenium. Other radionuclides
were released to the Columbia River. A separate HHIN publication
addresses the possible health effects of these radionuclides.

According fo the Technical Steering Panel of the Hanford
Environmental Dose Reconstruction Project, the largest
contributors to dose from the air pathway were first, iodine-131,
then cerium-144, plntonium-239, ruthenium-103, ruthenium-106,
and strontium-90. Dose is the amount of radiation absorbed by a
person's body. There were many other radioactive materials
released into the air, as weil, but these contributed less to dose,

http://Awww.doh.wa.gov/hanford/publications/overview/radionuclides. html

[ERE YOULL FIND...

History of Hanford's Hot
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Downwinder Perspective

U ved Issues Concernin:

Summary

01/07/2005



procurement as a recurring issue. Further, deficiencies in the Procurement program
have been Jong-standing and the subject of repeated DOE Enforcement Actions and
penalties, including the issuance of civil. penalties in calendar years 1999 and 2000, and
an Enforcement Letter in 2000. This dernonstrates the general ineffectiveness of
corrective actions taken to date. As a further specific example, subsequent to the June
enforcement conference KH identified an additional procurement-related noncompliance
associated with the inadequate control of suspect/counterfeit electrical circuit breakers.
Although not specifically cited as part of this PNOV, this later event emphasizes the
recurrent nature of deficiencies in this area. Therefore, the DOE believes itis
appropriate to escalate the procurement-related civil penalties by 50 percent to
emphasize the need for management to achieve effective and long-term resolution in
this area.

With respect fo the Building 771 Radiation Safety deficiencies, no mitigation for
identification was awarded due to the self-disclosing nature of the events. Fifty percent
mitigation for corrective actions, however, was awarded in recognition of the depth of
the contractor's investigation into the air sampler calibration event and the scope of the
corrective actions.

No mitigation for either identification or effectiveness of corrective actions was deemed
appropriate for the Quality Improvement violation. In keeping with the subject of this
violation, the DOE intends to closely monitor the effectiveness of corrective actions
undertaken in response to this PNOV, as well as your progress in improving the
timeliness and adequacy of your assessment programs,

You are required to respond to this jetter and follow the instructions specified in the
enclosed PNOV when preparing your response. Your response should document any
additional specific actions taken to date. Corrective actions will be tracked in the
Noncompliance Tracking System (NTS). You should enter into the NTS (1) any actions
that have been or will be taken to prevent recurrence and (2).the-target-and completion
dates of such actiéns. “After reviewing your response to the PNOY, including your
corrective actions entered info the NTS as well as the results of any other assessment
or inspection, DOE will determine whether further enforcement action is necessary to
ensure compliance with DOE nuclear safety requirements.

Yau are further required to pravide a summary briefing to the RFFO on the status of
corrective actions completed and planned concerning the Procurement program’s
programmatic deficiencies within 60 days of your receipt of this letter.

Sincerely,

R. Keith Christopher
Director

Office of Price-Anderson Enforcement



Radiation Protection - Radiological Improvement Reports (RIR)
(BBA vonday, July 19, 2004 9-05:08 AM

Page 1 of 1
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Welcome,
Steve Trujillo
>
Home > Databases > Radiological Improvement Reports {RIR) oo.
Radiological Improvement Report Details Rad Protection Site Links
@ Radiation Protection
RIR No. 99-534 # Alpha Group
Originator: @ Briefings
Project: RMRS Bate
Date Entered: 12/6/1999 12:00:00 AM @ Documents
Event Date: 12/2/1999 12:00:00 AM z Final Surveys
Status: CLOSED @ Mission
|DateClosed: 1/4/2000 12:00:00 AM @ Procurement
stati 2 TBD Log
Building: 7741 @ Training
Location: 158 # Video Library
Description: During routine glove box work, an employee self monitored .
and discovered 10,000 on his left hand. Contamination eens
# Create RIR

surveys of the glove found 10,000 on the thumb area of the
anti-cs. Surrounding area surveys were <500 dpmv/100em2
and no other contamination was detected on the employee.
PIF calculations were 6.25 and nasal and mouth samptes

were taken.

RS Supervisor = J. Harris

immediate Removed the employees glove and surveyed the inner
r Corrective liner Contained the glove box glove.

Action:

Primary Event

Code: B13

Secondary Event BS

Codes: -

Apparent Cause: EQUIPMENT
Facility Mgr: J.J. O'Brien

{DOE 1 iCable
Categorization: Not Applicable
Occurrence Rpt.
INo.:
Responsible
Mgr.: R. Caulfield
Responsible Dir.; A. Crawford
Target Date: 4/1/2000 12:00:00 AM
Corrective Changed GB glove. Crew continues to inspect and survey
\Actions: GB gloves and continue to wear Jeather gloves over GB
gloves.
PATS No.:
|Comments: RMRS PA Screen No. RMRS-99-1055

ittp://rfetsbp/portal/ Default. aspx?PID=25&MID=335

@ Radiation Generating Devices
(RGD)

@ Sealed Radioactive Sources
(SRS)

Contact

McGinley, Pam
Webmaster

PHONE: x6818
PAGER: (303) 212-5374

Savitz, Kenneth R
Aitemate Webmaster
PHONE: x4686
PAGER: (303) 212-4443

eal

7/9/04

es



°adiation Protection - Radiological Improvement Reports (RIR) Page lof 1
(G89 Monday, July 19, 2004 9:08:01 AM Portal Directory Portal Search Portal Sitemap
Wailiation Pratectian ‘Welcome,

Reports (RRS Steve Trujillo

>

Home > Databases > Radiological Improvement Reports (RIR) .
Rad Protection Site Links

Radiological improvement Report Details ; ee
# Radiation Protection
00-250 * Alpha Group
# Briefings
Project: al 7 Catcteg
Date Entered: 6/27/2000 12:00:00 AM @ Documents
Event Date: 6/21/2000 12:00:00 AM 2 Final Surveys
Status: CLOSED @ Mission
DateClosed: 8/25/2000 12:00:00 AM : procurement
Building: TM 3 Training
Location: 114 ® Video Library
Description: While doing glove box clean out of tine 2 room 114,
operator pulled out of the gloves. Surveyed his hand. and Databese Links
found 20,000 dpm on the right palm of the anti-c glove. @ Create RIR - .
Contained the glove on the operator. Surveyed glovebox @ see Generating Devices
side and on the floor < MDA of 12-1A. PIF completed, level + Seated Radioactive Sources
IRS Supervisor _D. Sinner
immediate Contain anti-c glove . Remove operator from the area, Contact
Corrective completed survey of the area. Glove port contained. McGinley, Pam
@ Action: Notified RCTTS, CCA, internal Dosimetry. ‘Webrnaster
Primary Event 4 : : PHONE: 16818
Code: 813 PAGER: (303) 212-5374
Secondary Event Savitz, Kenneth R
Codes: Alternate Webmaster
Apparent Cause: EQUIPMENT - byyscin pn A483

Facility Mgr: A. B, Adams

. NotApplicable

Responsible

Mgr: M. Brown

Responsible Dir.: K Trice

\Target Date: 7/21/2000 12:00:00 AM

Corrective All immedaite actions were appropriate and complete.

Actions: Changing the glove removed the source of contamination.

No further actions required.
PATS No.:
(Comments: No intake
&

uttp://rfetshp/portal/Default.aspx? PID=25&MID=335 TA9/04

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sized without (1) re-securing all of the newly sized [radioactive material] pieces,
and (2) emptying and verifying empty the partially filled can.

B. TRU Waste Container Loading Activities: {Nuclear} Safety Operating Limit ([
JSOL) RMS-19, revision 12, requires the [radioactive material] content of each
package be limited to [specified quantity] when two packages are placed in a
single 10-galion drum. However, on December 21, 2000, KH identified in
Building 707 that workers loaded three 10-gallon drums with TRU waste that
exceeded this flimit] per package [ JSOL limit.

[ ] MVM-015-3 requires the (radioactive material] content of certain 55-galion
drums not to exceed {specified quantity]. However, on December 29, 2000, KH
identified in Building 707 that workers loaded a 55-galion drum with several
packages having assay values, when totaled that exceeded the [ ] limit. The
worker and a second verifier signed a data form listing the assay values of the
individual packages but failed to ensure the loaded drum complied with the limit.
Subsequent to the event, a re-assay of the loaded drum established a new assay
value below the [ }Jimit.

C. TRU Waste Storage and Handling Activities: [Nuclear Safety] Analyses for
Building 440 (JP-410) and for Building 991 (BSM-883) require that only certain
nuclear material assay methods be used to verify [radioactive] material content of
containers prior to their storage in Buildirigs 440 and 991, respectively. However,
on August 28, 2000, KH identified that 40 containers in Building 440 and eight
containers in Building 991 were being stored without having the [radioactive]
material content verified, using one of the required methods.

Subsequent to the above problems, KH issued. Standing Order-71 and
Operations Order OO-MSWO-001 prohibiting the further shipment and receipt,
respectively, of drums without the required assay method. However, KH
identified on January 24, 2001, Building 569 shipped a noncompliant drum to
Building 664 which accepted it for storage.

This violation constitutes a Severity Levet {f problem.
Civil Penalty - $41,250

i]. TRU Waste Facility Work Controls

10 CFR 830.120(c)(2)() requires that “[wjork shall be performed to established
technical standards and administrative controls using approved instructions,
procedures, or other appropriate methods.”

Contrary fo the above, work was not performed to established technical standards
and administrative controls using approved instructions, procedures, or other
appropriate methods in that facility operations in Buildings 440 and 664 were not
performed in accordance with approved authorization basis (AB) documents and