sanegin gts ile iene oe

EGE Se IP ATER eT ape tee a eneein oy

7 ,She Transportation Department at Fernald did not
follow the QA plan for the Preparation and shipment of
radioactive materials in that shipments are released
yithout ala applicable decuments being executed and
turned in.

~ ° NIO TEER Department did not understand their -
responsibilities in mon. toring packages and vehicles for

compliance with DOT regulations.

~ the failures in implementation are of significant
magnitude that even a cursory audit of implementation of
the QAP would have disclosed failures.

~ one of.the recommendations from an earlier DOE report ~
dated February 7, 1985 to implement a dynamic internal
audit system to Systematically evaluate the NLO
environmental protection program was not in place for
the handling of radioactive shipments and plant
operations. The receipt and shipment of radioactive.
materials are essential to the operations and mission of
FMPC. Noting that the recommendation of a previous
board and similar findings in the handling of
radioactive shipments and Plant operations, the Beard
concludes that this is a generic problem within NIO
management system. The internal audit system is
inadequate, and NLO is in violation of DOE orders
5482.1A, 5480.3 and 5480.1A
Unfortunately, there is much more to the report that is
eritical of Fernald. in response to this stinging DOE
indictment, and under orders from DOE, NLO submitted an Action
Plan in September, 1985. Despite the obvious and glaring
inadequacies, T-Hopper shipments continued throughout. this
° period.
: On January 14, 1986, DOE sent the DOE Investigation
Report to Westinghouse management, and instructed them to comply
with the Report's recommendations within a month. on January 28, —
i986, Westinghouse responded to DOE with a letter that guaranteed
that Westinghouse was in compliance with the DOE mandate. f
On January 31, 1986 Me. Grumski approached me and assigned
me the task of evaluating the "Action Plan" developed by NLO in

-22- -

312880:


uranium into the body. Experience shows that skin and clothing contamination
are often the first (and maybe the only) signal of loose contamination in the
work area. .

Recommendation: Appropriate contamination survey equipment should be
installed and maintained in the work place and at selected locations for exit
surveys.

A.3 Observation

Routine contamination surveys are made of the higher potential areas on a
quarterly basis.

Comment: This would seem to be adequate, assuming recommendation A.2 is

implemented.
A.4 Observation

Most of the enriched uranium is handled in Building 1; however, there fs
some movement between the buildings. There were no procedures for keeping
enriched (u . 235y) yranium physically separated from normal or depleted

uranium (<5% .

Recommendation: Enriched uranium should be isolated from normal uranium.
Otherwise 1t is extremely difficult to distinguish which is which using
portable survey instruments.

B. WORKER MONITORING
B.1 Observation

The routine surveillance program to monitor internal exposure of workers
consists of both in-vivo and excreta measurements, The frequency of the
examination depends..on the.job assignment but is generally at Teast once per
year. ~ :

Comment: This combination provides the basis for a good program,
provided their air sampling program is upgraded per recommendation A.1.

8.2 Observation

The detection level for the in-vivo counter which is provided by Oak
Ridge is as follows:

depleted uranium 4mg
normal uranium 47 ug
enriched uranium 110 yg
(>5% 235u) :

The counter is located near the administration building and workers are
instructed to shower before being counted.


Stenderd Operating. procedures and safety Manual

Documentation of the Industriel Hygiene end Radiation
Safety programs was reviewed ana found to pe satisfactory

Standard Operating Procedures prepared for each plant
operation contain sufficient detail relative to safety

Robert W. Foe
Health Paysicist


Lets 2H-201-0000, AAJ-201-0001, LAB-D1-0006 and IGN-21-
COZ nave heen redsvramed anc reccdced to 1k-302 %, This
wew 3208p let contains nine druss and weigns 2 nat

pounds. ihis new scrap lot shouid a lewer sssay suan
product TNT because it centains/¢cls fllp material, sca ssh,

mercondri and vermiculite. The! ope less of tris

matsrial to the storm sewer.

nd ingot pieces were msde into two lots. Somes
ces were originally with the type 207 ma-
x s are available upon request.

1 ter (C8 pouis 3" diag 7 pieces

listed below, ‘The. clad and hollow rods ware
xdth the type 289 asterial.

ps0 Box #258 pousis all diemter rods and
2 LAE lana

B

& 1,382
T,85E pounis .
this natertel is good reset sorep after pickling,

. tubes (not certain of im

‘This lot might be més into renelt material after pickling

type 26s Delete - Tais item wee recoded te, type 207 end 275 material.


SUBJECT
To

FROM
REFERENCE

NATIONAL, LEAD COMPANY
OF OHIO.

P.O, BOX 138, MT. HEALTHY STATION
CINCINNATI 31. OHIO

April 19, 1955

RADIATION FROM THORIUM MATERIALS
J. A. Quigiey, M. D.
R. C, Heatherton

There is no information available on the difference in radfation

leveis from thorium fluoride prepared from nitrate in the

original method used in Plant 9 and that prepared from oxide

which is the method used in the last few months of operation,

However there 1s some information to indicate that there was

no appreciable difference in the levels of radiation.

Thorium fluoride made by the new method geve 15 mr/hr as

measured with an instrument in contact with a 30-gallon drum.

Slightly higher readings have been obtained from thorium

nitrate and thorium oxide. ‘The sump cake obtained by the

old method gave readings of about 3.5 mr/hr at contact with

55~-gallon drums. This indicates that most of the material i
giving the gamma radiation remained with the fluoride. ‘These i
veadings were all taken on freshly prepared material. Con- ‘
siderable information has been accumulated on the radiation

from thorium metal and some information on the build-up

of radiation from a cast ingot. 48.5 mr/hr games was measured

with an instrument at contact with thorium rods stored in

Hebeams, The estimated surface area was 21 x 6 ft., or about

120 sq. ft. It is assumed that ld be about the sane
as & reading obtained from an source, Readings
in contact with a thorium ingot from. 8 wr/hr, 3 days

after: casting,-to 18.5 mr/hr, 12 days after-casting.: The
readings then remained at that level for a period of 75 days.
No readings were taken beyond the 75th day. Slices of ingot
showed the same relationship between time and radiation
build-up with lower readings from the ingot slices. Radiation
levels were approximately 50% of those measured from the
ingot itseif.

Since all readings were actually instrument contact readings
and not surface dose rate measurements. An attempt was made

to compare the radiation from thorium with that or uranium,

in which the surface dose is known. ‘These measurements indicate

that -a radiation level from thorium 1: roximate:
0-20 times tha’ wo Om, 8 oR
from thorium is approxima’ of that from uranium.
Assuming a surface dose of 5 ar, gamma and 240 mreps/hr
beta from uranium metal, I t! that we can say the contact

dose with thorium ia in the neighborhood of 50-100 mar/hr gamma
and 75 mrepa/hr beta.

Attached is a report of information summarized by E. ¥. Barry.

R, C, Heatherton
RCHsmk

2910030 1600385


‘Shallow was no longer sampled for uranium or ether contamination.
Even the pump had been removed from the well. Upon inquiry, =
was told that uranium levels in the well were too high, and
therefore testing on that well was no longer done. I was later
instructed by Mr. Tippenhauer and Mr. Weichold not to put this
information into my audit repers.

Several Problems as noted above were also problems for the
Sewage Treatment Plant, the Ultra violet Treatment Facility, che
Manhole 175 Area, the Check cf Manhole PH Meters and Alarms, and
other areas audited.

Under. "General" observations in my audit, I noted that
several samples (including water and seage sludge samples) were
placed into one carrying rack that did not contain dividea
compartments. As a result, the samples woulda tip over and
intermix with, and leak onto other samples in the carrying. rack.
I also observed that "some samples would be brought into the
Water Plant Laboratory frozen solid." During the audit, 2
observed that sulfuric acid spilled from the acid storage tank
while the acid tank above ‘thé cleat well Was ‘being chargéd with

acid. "The acid was contained in the concrete basin, but quickly

ieaked out through the bottom." Also, the acid tank above the

clear well rested on a severely warped piece of plywood. I
wrote: "If this board warps enough or breaks, the acid tank

could tip and spill acid out. It is recommended that a thorough
{

inspection be made of the structure."
The management response on February 16, 1985 from Mr.

Leist is indicative of the powerlessness of the Quality Assurance

-16-

3128796


Itinerary of Uranium from Time ef Exposure until Tise of
Exeretion in the Urine. :
Bio-Assay Committee, &. C. Heatherton, Chairman

September 8, 1959 Page 3

Gc. Age - As a person ages, elasticity of the iungs decrease.
With this loss cf elasticity compensat. usua, ooeurs
by an increase in respiratory rete with increased oxygen
needa. To the other extent, the inactive or dead air
space volume of the lung increases. ‘Therefore, retention
of airborne contamination between a worker of age 36 and

a worker of age 60 could wary. sonsiderably - Little
investigation his been this 2
5. Particle size

Largest proportion by weight of most airborne sontaminants
4a in the 1 to 3.miaren range. There is wide variation in
the estimate of retention in the lower reapiretory tract
for different perticle sizes. However, there is general
% that only a swell £ of particles over 5 microns
tn diameter reach the alveoli. But of particles reaching
the alveoli, retention 1s favored by the density X éismeter?;
therefore, onee a 12: ele reaches the alveoli it is
tote eetained pee tt is worthy of note that
enitters a

area (@.¢. alpha activi =

YO wieren particle is abeorded in 1/1000 the tissue ares
~ that would absord the alpha activity frow a 1 mieron
particle) ‘The influence of particle size on soludility is
also thought to be significant.

S._ Density

Retention of airborne contaminant varies directly with the
Gensity of the sontaminant. Therefore urenius nds being
of @ very dense nature, are te a greeter extent than
other airborne centaminants of equal particle size.

Z-__Shape

Some investigators report 2 difference in solubility as urenics
salts age.

A sf ire: tract

Inhaled particles pefore they peach the alveoli of the lover
respirstery tract meet resistance te their flow from the

2ReFSS7


THER DSPARIMENC MUALY REPORT - aUGUSr 1 - AUGISr 31, 1957 Page 2

i

i

i

cl

:

i
eee
ue

It

used quite satisfactorily
suitable for this

that rexaco C soluble

This is being

‘tion room of the Laboratory Building.
to F, Jenkins, sapervisor,

tried on this job.
and it was thought that this would be

conducted on the use of Saf-r-Solv for cleaning the cut-off

sample prepara’

Monitor:

on of

However, he wore no respiratory protection even
Air line tespirators showld be

measurements on the pots.
the ventilation is bad, especially when desdiig over the pots

Plant
this
more
, Plant 2
usual thet night as the vextiiation was vot strong

tien was completed on
was exposed to N02 around the

to pall it



P.O, MOK 188, UF. MEALTHY STATION

: CINCINNATI 31. CHIO— Septenber 5, 1957
SUBJECT IRAR DEPSRMGENT MONTHLY REPORT ~ AUGUST 1 ~ AUGUST 31, 1957

TO Fe Ae leery Me CENTRAL FES

FROM. R. H, Starkey for R, C. Seathertcn

Hlant Air Dust Survey sng Rspossce Syatnation
for’ Plants 2, 4, and 6 bave mow been completed and the report

Tom been made on a number of operations and sreas -
diving thie marth A special survey was initiated sed completed in
the Laundry im peeparation for the visit by AKC personnel. A final
seport on this survey is in progress.

A special study is presently underwsy to ascertain the radon cencen-
trations in the metal oxide storage silos. oe ee
been reported by the Analytical Laboratory, but this study will be

i

‘he sheating of F-metal alsbe! in ‘the Maisitesanes Shop is Geing followed
quite closely te makecvertain that the recomendations made cariier
are carried out. As long as these recemendations are followed there
appests to be ne preblem with this operation.

M0-GER-E9B-1 (12-14.853

|
i
|

i
{
i



IH&R Department Monthly Report for May, 1958

c. A. Quigiey, M. D.
18

June 4, Page &

the drum baler in the drum reconditioning building. galy
those men involved in cleaning the baler will be requ:
to make @ complete clothing change. _

The Methyl Chloroform report and an informetion vbulletin on
Fluorine have been reviewed and is currently being revised
and corrected. These reports are expected to be completed
in time for the July safety campaign.

Pume_ and Dermatitis Investigations

During May, two fume inhalations were investigated as well
as five cases of dermatitis. No cause for the dermatitis
conditions have deen determined as yet. Two of these cases
were declared cacupational. A meeting concerning this was
held between the Assistant Director of Personnel, the
Services Departwent Head, the porters' foreman and a
representative from this department. ‘The various compounds

used by the porters were discussed and it was agreed that

a check be made on the dermatological aspects of these

compounds, Our preliminary investigation indicated that
no new waterial has been recently added to the materials
handled by the porters.

Urine Study Progras

The remainder of Plant 6 personnel (Inspection, Transportation,

Acdountabtlity, Production Records) -wili be tentatively .

scheduled for sampling during the second and third weeks of
toh PN

Noise and Lighting Surveys

The noise level of the Swagging machine in the Development
Machine Shop was analysed and it was determined that the presen.
enclosure is not designed to provide the maximum of efficiency
in reducing the noise level to the operator. A fire hazard
also exists because of the present unit, This hazard is caused
by 042 which is deposited on the fiber glass lining and then
ignited by sparks from the machining operation. A new enclosure
4s being designed by Engineering which will reduce the noise
level of the operator and provide him with less limitetiona of
movement than 1s presently possible. The ventilation of this
. machine 1s also in the process of being improved and the oil
controlled by improved splash guards so that the fire hazard
6 will be eliminated,

Pilot Plant personnel requested that a means to reduce the
noise level on the 3620 reactor vibrators be investisgsted.
A new type of fiber piping is currently being tested ty vhis

04063]


. November 11, 1969

THER DEPARTMENT MONTHLY REPORT FOR OCTOBER 1969

J. A. Quigley, M.D.
M. W. Boback

Air ne Studies

Traverse studies of Plant 8 dust collectors G8-2 and G43-27 showed
that these collectors were performing at design capacity.

‘Due to odor complaints a check of the exhaust ventilation for the shower
and drying rooms was made. The exhaust was found to b workin...
However, it was noted that th: exhaust grill in the dryin: roon. was
about 40% covered with lint, thus reatricting the effectiveness of the”

-@ system. ‘This was discussed with :. Peterson and hc is taking action
to have the Lint removed from the grill.

Several operations in th: Pilot Plant’ s production of thoriun. mavtal ar
apparently hizh air dust opcrations, as noted from the amount of visibic
dust. Due to lack of manpower and other pressin, duties, sampizs hav.
mot yet been obtained. Ik is planned to spend a full weex in November
sanipling theseoperations. Rispiratory protection is being worn at:
these operations.

Special Radiation Studies

On Getober &, 1969, the RDA test evacuation drills were conducted for
second and third shift Refincry personnel. These teste were held up
until the new plastic RDA horns were installed. It was reported that th:
horns, lights, and persouncl evacuation drills were satisfactory.

Health physics surveillance was provided ai the Technical Livisior:
radiometric facility upon receipt of a 5 curic cesium:-137 source. Lue
to a misunderstanding, it almost became n=ceasary to build or purcnas-
a storage pig to transfer the source into. It was not clearly uncerstooc
from the beginning that tne shipping piz could be retained by NLO anc
that only the shippine container would have to be returned. This created

REST-PNDv AVAI ARIE


we . :
ay Ff Te
NATIONAL LEAD COMPANY
OF OHIO

@ P20, BOX 158, MT. HEALTHY STATION.
~ CINCINNAT! 31. OHIG December 22, 1952 22277*¢

Weekly Report - Ind. Hygiene & Radiation Dept.
Period - 8 am, December 15 to 8 am, December 22 Incl.

J. A. Quigley, M.D.
R. C, Heatherton

ae

pet

General
1. Plent 2

1. Leakage of beaver lodge feed materials which is
being shipped to MCW is continuing. This condition
~ has been noted in last week's report. Carriers are
being lined-with heavy brown paper to prevent
- contamination.

2, Swok(2)coverexposures tolganmareidiat jation:have been.
_spptedstp personne} “hand e "Q-12/ Mr. J. Coste has
een asked to minimize handling of this material.

e@ 2. Plant 2
1. The digestion area has been operating to the satis-
faction of Mr. Strattman. However, we are aware
of a few sources of dust.

3. Plant 3

1. De-nitration - Approximately eight (8) batches of
“* . matertel have been run in‘the pots as part of- the
shakedown phase of equipment. Some dust conditions
have been noted, These could be attributed to
inexperienced operation.

. 2. A dust problem has been noted at the exhaust end of
the gulper, This is due to tne tearing of tags in
the collector. To minimize the dispersal of the
dust a drum or bag will be installed at the discharge
of this collector.

4, Plant 4

2. A meeting with Messrs. Stewart, Bucher, Heatherton,
and Stefanec was held on December 15 concerning the
health problems in Plant 4. One of these problems~
ineluded the pulling of the ribbon conveyor which ‘2s

F witnessed on December 18 by Messrs. Stefanec and
Qt bs Schumann. For this operation the. casket was employed
| 931 and the dusting seemed to be considerably below the

PETWHY c .


nem gee pets Che sear cere re oe neege

“of greensalt that Fernald was facing while the ban on T-Hesper

shipments was in effect. The memo warned that there was only a
@ two week supply of the vital Production material available.

Production thereafter would cease. :

Two days later, Mee Sritten wrote to the DOE, announcing
that Fernald management had completed corzecting the three items
that the DOE team had found wanting. Again, no mention was made
oF ny investigation report. Mr. Britten had failed to raise the
fcliowing information to poz shat my investigation had revealed:

(1) No procedure -existed that included information on
the weighing, receiving and shipping inspection
requirements for T-Hoppers from Paducah;

(2) No environmental, safety and health procedure

existed that included information on how te perform a
radiation check and visual examination on incoming T-

Hoppers;

(3) No ES&H procedure existed that included information
- on how to perform a smear test and radiation check on ‘T-
a @ Hoppers;

(4) No procedure existed that included information on
how to replace the bottom gasket of the T-Hoppers;

(5) No procedure existed that included information on
specifications for bottom gasket of. the -T-Hopper ;-. -
(6) No procedure existed that included information on
how to tack weld the two opposite bolts at bottom
closure of T-Hopper;

(7) A program had not been established for periodic
weight verification of T-Hoppers and T-Hopper dollies;

(8) A program had not been established for five-year
interval leak testing and bottom gasket replacement on

T~Hoppers; I
(9) The following procedures did not include
information on Seale No. 4-44, which is used to weigh*T-
Hoppers;

~26<

3128806


Comment: The detection capability is not state-of-the-art.

Recommendation: An in-vivo counter in a shielded facility should be
installed. This would also improve follow-up capabilities in the event of a
known or suspected intake.

A.3 Observation

Maximum permissible Tung burden (MPLB) yglues of 260 yg 225u for 1.5%
enriched material and 100 ug 2°°U or 50 mg 7°80 for 0.2% enriched material
have been established. Frequency of in-vivo measurement is generally on an

annual basis, however, should an in-vivo count indicate 250% MPLB the
fréquency of examination is increased to twice per year.

Comment: This forms the basis for an adequate program provided air
sampling capabilities are upgraded for Recommendation A.1.

A.4 Observation

Detection level for uranium in a routine urine sample is “10 yg/L. At 40
ug/L, a second sample is collected from the worker.

Comment: These levels are about normal for a uranium facility. However,

- there was no indication that a level has been established (for uranium in

urine) that would trigger investigation of the workers exposure, or that would
restrict a worker from further work with uranium until the excretion level

decreases. .

Recommendation: Levels be established for removal/return of workers from
the work place based on concentration level of uranium in urine.

B.5 Observation
Involvement -of -a worker in an-incident triggers special urine sampling.
However, their understanding of what constitutes an incident is rather vague

and does not seem to be well understood, especially by the field monitoring
technicians.

Recommendation: “Incident” criteria should be documented.
C. MISCELLANEOUS
C.1 Observation
Good records were available for both bioassay and in-vivo examination.

Comments: Though records of measurements are recorded and retained there
was little evidence to suggest anything such as dose assessment was being done
with the data.


Itinerary of Urenius from Time of Exposure until Time of

Bxcretion in the Urine.

Bio-Assay Committee, R. C. Heatherton, Chairman

September 8, 1959 : Page 2.

in this event.

It is also worthy of comment to note that absorption studies
from the 3I tract ere besed on animal experimentation for
the most part. In the human, to be considered is the high
acidity of the stemach with the possibility of chemical
reactions or increased solubility of uranium compounds that
normally sre insoluble in weter or at neutral p's. Any
urgnium passing from the stomach to the small intestine
capable of chemical reaction would be met with the alkaline
pH and high bicartonate content of the small intestine,. it
is Shought that bicarbonate compounds of urenium are readily
soluble. .

Little 1s known ef the process by which the absorbed urenium
crosses the gut barrier; whether body deficiencies in other
metallic el 8 Gs calcium, potassium, etc. would
enhance uranium absorption is subject for thought, It has
been reported, however, in sowe of the older literature
that orally administered doses of ag high as 3.0 grams of
uranyl nitrate per day were tolerated without albuminuvis

or glycosuria,

4, Breathing Habits

@. Rats - Inhalation of centazinant is naturally proportional
to sespiretory rate, however § retention diminishes with
Snereased respiratory rate due to the repid inward and
outward movement: of air; therefore, while there is 2 linear
relationship between breathing rate and inbalation of
contaminant, there ia not # linear increase in the retention
of contamaunt with increased breathing retes.

b, Volume - The tidal volume equals the volume of inspired
air per breath. Minute volume equais the tidal volume times
the respiratery rate per minute. Body needs determine the
minute volume which can be increased by increasing the tidal
volume, the rate, or both.

e.g. Tidal Volume X Rate = Rinute Volume
“Worker A" 500 ml X 30 = 15000 ml or 15 l/minute
“yorker B* 1000 mi X 128 = 15000 wl or 25 i/minute

In this example, both workers have identical minute volumes

and thes have inhaled identicsi eoncentrations of centaminsnt,

however, "Werker eisetnet slower and deeper respiretions.
oe

would retain more ¢



zaboratory frozen solid, “anagement, in its response te the

audit, disclaimed this finding, and flatly stated, "We doubt that
Samples are brought in frozen solid." I had personally witnessed
this cccurrence, but I was Powerless to press my point - -
Management had made up its mind that there was no problem,

therefore no corrective action was required. This uncaring,

" unprofessional attitude and practice of management continued.

Massive health and safety problems uncevered uring the ccurse of

an audit went unresolved.

Finally, follow-up audits revealed that several, sometimes
none, of the corrective actions promised had been implemented.
This problem was so pervasive that I wondered why I was wasting
my time doing the audits at all. In one instance, in an audit on
“Derby Breakouts", dated November 11, 1984, I identified many
significant violations of the procedure. For ene, the procedures
were not current, did not reflect the operations as performed,
were not even available in the work areas, and left out important
health and safety requirements, such as the requirements for
wespirators -tn- high: vadioaétive dist ateas.* ven though i

management agreed with the problems identified in the audit, and
promised corrective action in a March 23, 1985 response (three
months late), a follow-up audit performed by myself
eight months later found that none of the promised corrective
actions had been implemented.

Another problem that I noted was that many of the aivisiords

and departments at Fernald were only self audited, in violation

of the whole concept of Quality Assurance/Control, as well as

DOE Orders. This was the case in the Health and Sazety

-7-

3128787


“NLCO-895

te

4 CONTINUED PROGRAM OF ANALYSIS FOR URANIUM
IN HUMAN AND ANIMAL TISSUES

at
Richard C. Heatherton a
Michael W. Boback
Joseph A. Quigley, M. D.

National Lead Company of Ohio
Cincinnati, Ohio

September 20, 1963

\s

Prepared for presentation at the Ninth Annual
Bioassay and Analytical Chemistry Conference
San Diego, California
October 10-11, 1963

work reported herein was perfo ed
for U. S Atomic Tgy Commission ~

‘under Contract No. ATTS0-1)-1156



oY)

Itinerary of Uranius from Time of Exposure until Time of
Exeretion ia the

Bio-Assay Committee, R. C. Heatherton, Chairsen
September 8, 1959 Page 4

mucous-like epithelial lining of the trachea and bronchi.
Also growing from this epithelium are hair-like projections
called ¢ilie which by wave motion sweep particles back up the
respiratory tubes. For this reason, only @ smell percentage
of larger sized particles reach the slvecli. It may ve noted
that individuals with ehronde bronehitis (e.g. many cigarette
amokers) after a period of tine become denuded of this normal
respiratory epithelium and cilia. Avess denuded of this normal
epithelium become possible foci for permanent Gepoaition of
conteminant. It would be individuals such as this tha: would
run increased risk to ether pathologieal conditions such as
bronchogenic carcincaa.

20, Lungs

Ae particles move down the respiratory tubes enatomical structure
may favor certain areas for retention. ‘The main respiratory tube,
the trachea, is in almost @ vertical position, however, ite two
terminal branches, one to the left lung and one to the right
lung, are at angles. The angle of the branch to the left lung

%
It must be remembered however, with humans we have a standing
deposition ef contaminant. aeseoe with this taken into
account would be ef interest, af 4% would show that
contamination concentrations are pet uniform throughout the lung

and certain areas do have inereansed deposition.

JAB iajs

eo: J. A. Quigley, M. DB.
=. G. Byrne, HM. D.
3. F. Ziegler, M. B.

R. 5. 3
mt nan A 7

aeaceRo


@

om

KADLEC MEDICAL — DENTAL BUILOING

» HANFORD ENVIRONMENTAL
HEALTH FOUNDATION

Re tha

duly 11, 1979 yee

pe
Mr. Herschel Hickman, Director ny
Manufacturing Division : ©
Qak Ridge Operations Office
-0. x
Oak Ridge, Tennessee 37830 Pky
Dear Mr. Hickman: : 4
The letter will inform you of a dialogue that has been taking (or.
Dlace almost a year now.
In May 1978, Hanford Environmental Health Foundation (HEHF) of 3 A
Richland, Washington, given a contract DOE to develop an Oc- 5
pational Health Study of Uranium works is being assisted 4
by Pacific Northwest Laboratories Battelle) in carrying out this A
study. ig
National Lead Of Ohio (NLO) represents a unique group

of Uranium workers for possible autopsy study. As the work force - <———
has contracted over the years, workers have been retained, as you - ss
kriow, on a seniority baSis. Thus the 600-workers -presently employed

have for the most part been there since Manhattan Project Days.

National Lead of Ohio during this time has been involved in all phases

of Uranium work.

As you know Mr. Richard C. Heatherton and Mr. Michael Boback at

Nationat Lead Of Ohio (NLO), have long been interested in the ultimate 7d
disposition of Uranium in the human body, and both of them have written i$
and given papers on this subject. Since October 1978, Mr. Heatherton and ir

¢ 20.80% 100, RICHLAND.


F.

G.

Irradiation Facilities

A 252c¢ source has been added to the neutron activation
facility. The 153 microgram source is currently in
storage; use is plenned in 4.5 months. ‘The procedures,
interlocks, etc., in use for the Cockroft-Walton machine
will also apply to the *52cf source. No radiation bazard
exists at present, as verified by surveys performed by
the IH&R Department.

Treining

The professional staff of the IH&R Department participates
in periodic seminars end technical sessions offered by
universities end professional societies.

Plant employees attend monthly safety meetings. Health
physics and industrial hygiene topics are occasionally
presented at these monthly meetings. Sudjects covered
recently include noise end respirators. The IG&R Depsrt-
nent distributes appropriste phampliets and booklets per-
taining to safety and also informs supervision by letter
of selected hazardous materials or operetions. This
training program is considered to be satisfactory.

Hoise_

Major noise areas. within the MLO plant have been identified.
hose areas which exceed the Ocoupétional Safety and: Health
Standard have been evaluated in terms of providing engineer=
ing solutions to correct the problen. Several of these
engineering changes have been incorporated while others re~
quire further evaluation. Protective equipment is utilized
where necessery. During this review only one operator was
noted as not wearing the required ear protection. HLO shouid
continue to stress the importance of wearing ear protection
when it is required. Hone of the areas which have been de-
termined to require ear protection was posted as such. tt is
recommended that these areas be posted. NLO should continue

te resolve noise problems through the application of engineering

design solutions. Where these are not feasible, exposure
should be reduced through the use of administrative control
and the use of protective equipment.



response to the DOE report, as well as the Transportation
Department's Compliance with the Plan. The Action Plan
guaranteed to DOE that corrections had been made and that a
recurrence of shipping contaminated and leaking T~hoppers would
not happen again.

On February 7, 1986, I personally submitted my investigation
report to Nr. Grumski. He was impressed enough with the report
that he came ints ay office that sane day and said, "This is the
best thing I have seen come out of here yet. Damn good job." My
investigation revealed fourteen areas that were deficient,
including: °

- No program had yet been established by the Materials

Control and Accountability Department for periodic
weight verification of T-hoppers.

- No tamper-proof seals on bottom closure of T-hopper.

- No- leak testing maintenance procedures and bottom
gasket replacement. : .

- Leak testing is not performed on T-hoppers from Paducah
by FMPC -- instead it is performed by Paducah.

- An Environment, Safety & Health procedure had not yet
been written on radiation checking and visual
_ dnspection for all_incoming T-hoppers. .. -

- There were discrepancies in washer sizes.

- No operating procedure for 5-year leak testing and
bottom gasket replacement, @espite commitment
to contrary.

- ES&H procedure which includes information on the
maximum radiation level acceptable was still in the
Process of being written.

- Many areas requiring development cf SOP and
audit procedures, including: .

- Need for revision in procedure to include
information on scale preparation and use by
production personnel.

- 23 -

"3128803


~ It could not be establisied

DOE_ftormaliy knew_o: 1S A

> About 368 metric 3S: Lutenium~Dde:
mater: curr ty remains at FMPC in the form of
uranium trioxide. Spe al precautions will need to
be taken

to.process this material. .

~ (The Task Force concluded that “insufficient effort
and attention was given ‘to worker safety and radiation
exposure control. For example, during routine opera-
tions the decision on whether an_ ingestion of radio-
active material has taken or could take place rests with
the worker. It did not’ appear to the Task Force that :
workers have had enough training and/or knowledge to
intelligently make such decisions."

- Deficiencies in the Fernald's Health Physics and
Environmental Programs were noted by the Task Force.
Against this background, Westinghouse was planning to pro-
cess more of this material in response to pressure from Hanford,
and in order to alleviate a shortage of greensalt that was about
te develop. The pians calied for processing appoximately 168

metric tons of uranium oxide containing an unknown -level of

pluténiun contamination, as well as some raffinate containing,

according to a November 1985 report, up to 3,500 ppb..
On February 7, 1986, I was assigned to develop procedures

for the plutonium-out-of-specitication Processing.(P0OS}. ‘The --

assignment was to upgrade procedures for the Poos program. A
meeting on February 10, 1986, attended by Mr. Macaulay, Mr.
Bonfer, Mr. Dunaway, Mr. Neyer, Mr. Weichold, Mr. Walker, Mr.
Herman, Mr. Christianson and myself, was held to discuss the
program. Mr. Weichold and I were tole to write two new
procedures and revise six others. The Environmental, Health ana
Safety Department was given the responsibility of writing a ‘
special procedure that would include information on all health

-29-

3128809



also clear that DOE had failed to uncover my investigation
report. Presumably, all they would have to do was to ask fer ali
Westinghouse reviews in order te receive my investigation reperz.

Westinghouse's failure to bring up my investigation, ana
management's "advice to me te not bring it up unless asked, was
worrisome. I had expected different behavior from the company
that "Was Sure."

To DOE's eredit, the three items that the Appraisal Team
found lacking were enough to ban Fernald ‘ron Shipping
TeHeppers, two days later, on February 14, 1986. However, this
was not in time to prevent yet another contaminated T-Hopper
shipment from Fernald to Hanford on February 18, 1986. Within a
year, despite the hoopla and criticisms, despite the promises and
commitments from Fernald management, Fernald had repeated its
mistake.

Westinghouse Claimed that the T-Hopper was sent out-on
January 30, 1986. This is of small reassurance, since
Westinghouse had sent a letter to DOE on January 28 guaranteeing
that radiation surveys were being conducted. In fact, the
‘surveys were performed; but without benefit of 4 written
procedure. Westinghouse attempted to escape blame by
Claiming that they implemented the corrective actions promised to
DOE. Westinghouse had performed a radiation survey on the T-
Hopper - = three weeks prior to shipment. They had followed a
flawed and vague procedure, exactly the danger that I tried to,
point out in my investigation report. But it gets worse.

On February 25, 1986, a Westinghouse internal memo to
WHCO Vice President Britten, outlined in grim terms the shortage

- 25 -

3128805


rN

Respirator Program

The Occupational Sefety and Heaith Standards, 1910 Subpart I,
Paragraph 13%, contain specific standards for the documen—
tation and content of a respirator ‘protection program. The
“W00respiretor program does not now comply with this standard.
It ig recommended that NLO review the standard and modify

its respirator program to achieve compliance. It is further
recommended that areas within the pliant where respiratory
protection is required be posted.

Ventilation

Laboratory hoods, a vapor degresser, and ventilation systems
for severe] drumming and dumping ststions were evaluated

to determine air flow rates. The basic standard used was
100 fpm, except for’ systems specifically covered by the

OSHS, such as the vapor degreaser. With only few exceptions,
the ventilation systems appeared to be adequate. LO in-
tends to perform a detailed review of all ventilation systems
prior to November 1, 1972. Results of this review will be
supplied to ORO. Subsequent to that review, it is suggested
that NLO initiate e program of ventilation evaluation to
assure that systems continue to function properly. Each
ventilation system should be checked at least annually.

Heat Stress

Several arees within the plant appear +o be capable of causing
heat stress in employees. It is suggested that NLO evaluate
these areas using the method of evaluation outlined by the
American Conference of Governmental Hygienists. This eval-
uation should properly be performed during the hottest season
of the year.

Control of Toxic chemicals

No formal program for control ef toxic chemicais, with the
exception of solvents, currently exists at NLO. Chemicals

cam be obtained by operating personnel from at least three
sources, including direct purchase, with division approval,
from a vendor, Industrial hygiene epproval is required pricr
to the purchase of solvents. It is suggested that in order
to assure that users of chemicals are aware of the toxicity,
a method of inventory, labeling, and toxicity information dis-
semination be established. Similarly, chemical users should
be encouraged to dispose of chemicals no longer needed, and
storage areas should be checked to assure compatibility of the
chemicais with the storese enviromment. .


maintaining and distributing DOE/OR orders. Mr. Weichold made
the decision that the Company Library should be responsible for
the Orders. When Weichold contacted Librarian Ms. Gardewing and
her immediate supervisor, Mr. Elikan, manager of Technical
Services for Westinghouse, an agreement. could not be reached. As
of the date of my departure, nothing had been established as to
who was to -be responsible for maintaining the orders. Given my
past experiences with the DOE order maintenance under NLO, = was
dismayed that Westinghouse management was still dragging their
feet on this seemingly important task. However, my first actual
insight inte how things were to be under Westinghouse came with
my first assignment - - investigation of transportation shipment
vessels, called "T-Hoppers", that carry radioactive materials.

A T-hopper is a transportation vessel used to transport
uranium oxide from Hanford te Fernald and to transport greensalt
from Paducah to Fernald. The Hanford to Fernald shipment is
performed by rail service; Paducah to Fernald shipment is
performed by truck. I was to investigate the overall operation

of transporting Trhopper vessels. ds.

It is important to explain the background behind this
incident. A shipment of an externally contaminated T-hopper from
Fernald to the DOE's Hanford facility on 7/23/85, sparked a DOE
investigation (released 11/25/85) which heavily criticized
Fernald for lack of procedures, training, quality assurance and
more. The DOE report found, inter alia: . f

. > operating procedures used at both Fernald and Hanford
to inspect the shipping container and to prepare it for

shipment were not sufficiently detailed to assure that
the package closure was sealed and contamination-free.

- 20 -

3128800


Page 5

Procram for Obtaingns Me: rements

Thorium.

After the chemical crocess is studied, sap collected

of the various thorium comvounds br radio-
activity measurements. These samy? ces of
thorium and a thorium slug. , cane ni film measure~
ments will be made so that act may be Dictted.

Comparisons will also be made,
badge resulta. The informatzon
into a report.

wnt readings with film
& will then be written

Urenium.

A similar sampling and mé 12 be undertaken with

uranium.

E. V. Barry

&

1600390


The porpone ofthis sper is to repart the current stfus and findings of
tha tissue analysis stay which Wis bogun at the Nationdi Load Company of Chio
in 1986. At that time the plant work force numbered about 2400 persons including
about 1600 proseas workers who had been engaged for 2 to 4 years in some phase
of the uranium fuel production work, This work was a source of some exposure
to airborne uranium dusts and fumes.

As might be expected, whenever a desth occurred in this group, the
question of causal relationship between exposure and death was generally raised.
The program began as an attempt to settle the question of causal relationship
through the analysis of tissues obtained whenever an autopsy was ordered for
former employees. Because of mutual interests, a cooperative program was
worked out with the county coroners and the pathologists at local hospitals. We

. abtaihed portions of body organs of interest whenever postmortem. examinations

were made. ‘Then, acting as agents for the coroner or pathologist, we analyzed
the tiasues for urantum and submitted results to him, ‘Through this arrangement,
we were also provided with some tissues from autopsies of persons without
known history of occupational exposure to uranium.

Related case history information and tissue results from our first six
autopsy cases were reported in 1958.1 The analytical investigations made in
conjunction with the start of the program were reported the same year. 2

New Cases : .
_. We have since obtained information from two autopsies of former employees,

three biopsies of employees, and nine autopsies of unexposed subjects. Analysis
of human stomach tissue obtained from surgery, a finger severed in an accident,

at.



IH&R Department Monthly Report for May, 1958

J. Ae Quigley, HM. D. -
June 4%, 1958 Page ®

eight persons were exposed to 600 mreps or more of beta
radiation, and two were exposed to 150 mr or more of samma.
The highest beta exposure was S30 mreps and the highest gamma
exposure was 165 ur.

File badges worn during the o4 4/30 to 5/14 indicate chat
six persons were exposed. to mreps or more of beta vadiavion,
and one was exposed to 150 mr or more of gamma. The highest
beta exposure was 760 preps and the gamma exposure was 165 pr.

Of the 17 exposures noted above, 13 were in Plant 5, one in
Plant 8, one in Plant 1, one in Plant 2, and one in the
Laboratory,

Ground Contamination Surveys

No special surveys were taken curing this period. A few qmail
spills were noted and cleaned up by Zesponsible persons. A

drum of grinder sludge at the Plant 6 pad ited
in jected area was cleane
up by hos: mto drain system. tions did not exceed

15 mrep/hr

Plant Effluent

Analyses of effluent samples for the period from April 24 chrouz:
May 22 show no contamination above MAC. The following sable

shows. Maximus concentrations of contaminants in the river and

two main effluent streams for this period:
Maximum Concentration

Contaminant MAC River ole
Uranism (ppm) 0.35 0.0028 9.80
Fluoride (ppm) 1.20 0.0065 72.0
Nitrate (ppm) 4kLO 2.359 3656.6
Apne ;) 12:8 0.008 o4.0
3. 0. 1251.0
BSS (ppm) --@ oraee Tia to

Fise
Permission’ was given to the Refinery to rolease daily. amounia ut
evaporator product, not to exceed 2,000 gallons/day, to <ne
General Suwp until further notice is received oy them from tiv
Health & Safety Division.

040633


Fernald in January, 1986.

Mr. Grumski, head of Westinghouse’s Quality Assurance,
directed me in January 1986 to get the DOE Orders out, as the
Orders would be needed: in performing investigations: I searched
for hours but.could not locate the Orders. I finally reached mr.
Spencely, the former President of NLO (still on site at the
time), and was told to check the library. I knew that that was
wrong, since DOE Orders were never maintained in the library. =
then called Mr. Spencely's former secretary, Ms. 3rewn, whe
stated that the DOE/OR Orders were kept in the Legal Department,
but that the Orders hadn't been kept updated for two years
because she wasn't given time to do so. I then went to the Legal
Department accompanied by Ms. Murphy, secretary, and President
Boswell's secretary, Ms. Kinnett, and located the orders -- they
were literally heaped on a shelf, in total disarray. The binders
that held the Orders were not in any order, and many labels that
titled the binders were on the floor. Many Orders were missing,
some were not filed, and some were also on the fleor. I
discovered that the Legal Department had net kept up the files
for-over five years. “I reported ‘the problem to Mr. Grumski of

Westinghouse, but as of my departure, nothing had yet been done.

GENERIC OBSERVATION ON AUDITS
During my two year stay at Fernald, I conducted 23 audits -
and one investigation. I have kept a copy of not only my audits,
but of management's responses to the audits, as well as the f
follow-up audits that were performed. Audits are highlighted as

an addenda to this affidavit.

-12-

3128792


c

Whole Body Exposure

Whole body external radiation exposure continues to
remain vell within the AEC guides. ‘The maximum whole
body penetrating radiation exposure for the first

half of 1972 was approximately one (1) Rem. ‘Two
employees received close to quarterly whole body skin
exposures, approximately 9.5 Rem in the first quarter
1972. The employees were moved to lower exposure jobs
to assure that quarterly limits would not be exceeded.
Operational changes were aiso made to reduce the exposure
potential. .

Changes in job assignments necessitated by radiation ex-
posure are not consistently requested in & formal manner,
as is done for other medical job restrictions. It is
suggested that the WLO Industrial Hygiene and Radiation
Department formally notify supervision of the necessity
to preclude further exposure for & specific time period.

In Vivo Monitoring.

In vivo lung counting continues to be used vy WLO as the -
primary means of assessing internal exposure to radio-
active materials. At the present time, approximately
eight chemical operstors from the Refinery end four from
other plants have lung burdens greater than 50% of the

‘recommended, maximum permissible lung burden (mprB). EQ

has determined that the

of. ‘oyees that require annual lung monitoring.
This group ey be counted at least annually » ‘end more
frequently if the previous in vivo count, or the tvo~year

average, is ebove 50% of the MPLB. Qther employees. with
tential sure will be counted as time mits, but at

Teast 50% # ‘Shese will be counted each year. The in vivo
lung count: ‘program is sétisfactory.
Urinalysis

Urine samples are collected at least quarterly from those
employees who have potential internal exposure. Except

for the Refinery chemical operator group, urinsiysis indi-
cates no exposure problem. Several very bigh urine samples
have been detected among the Refinery chemical operators.
These data appear to indicate that the exposure is to rels-

tively soluble uranium The data have’ been used primarily es 2



12. on occasion, the employees were exposed needlessly to airborne
were

radioacti' supervisors
ib: at a rate in excess of the ction rates set forth in
qperating at gesting procedures ee rises when” ventilation

Fe SS blocked. production supetvicors told the employees to go
ghead and dump uranium anyway causing the radioa ve dust and
fumes to billow out into the plant.

13. In the 1950s no industrial hygienists worked on the second
shift, third shift or on weekends. It is my understanding that
many gperations that would not be condoned OY ht gu otife and of
Divis: Gone on the second shift, third.shift and on

be
ai eon than no industrial hygienists were present.

14. There was no fit testing for respirators used at Fernald during
the years that I was employed there. Respirators were not used by
the production plant employees as frequently as recommended by
Health & Safety Division. Often the respirators were left in the
production areas uncovered where the respirators became dirty and
covered with radioactive dust. fhe enployees would then pick up

smoking in the production plants.

ees would carry the cigarettes in their coveralls where the
‘would become contaminated with radioactive dust and then

the employees would smoke the cigarettes.

People that were. injured in the production plants were assigned

16.
" aduty®. Light duty could be anything ~ such-as sitting ina

18. Many times during my employment plants 2 and 3 had to be
evacuated because of nitric acid funes. No samples were taken at
the time of evacuation, however samples were taken before the
employees were allowed to return to the buildings.

19. Supervisory personnel were aware that employees were being
3


JUL I.1 1968.

2154437

Mr. C. L, Karl, Area Manager
U. S. Atomic Energy Commission
Pp. O. Box 39188

Cincinnati, Ohio 45239

Subject: Proposed Employer-State~Federal Records and Reports System for
Radiation Workers:

Dear Mr. Karl:

Although we have not been officially asked to comment on the subject proposal,

I would like to provide comments regarding the proposed record keeping system.
It is-not clear from the proposal what leeway may be afforded the individual
émployer in-his record keeping. .We are opposed to uniformity in record keeping
if uniformity means sameness. Different situations encountered in different
operations should require some difference in the type of records which will be

kept. I_believe that each employer should be left free to decide to some extent
how he wilt keep his records and what information will be recorded.

In our opinion the record keeping ag outlined in the proposal is far too detailed
for the individual worker. We would propose insteed thet the records be mein-
tained in'two parts.” First, the’ company records pertaining to the processes,
methods of making radiation surveys, and levels of radiation encountered would
be kept. The individual employee record would contain only his external radiation
exposure as measured by film badge, urinalyses and body counting data if avail-
able, and perhaps a broad description of his duties.

While we believe that externally received industrial radiation can be and is
measured accurately, the state of the art for accurate estimates of radiation
from internal emitters is not sufficiently advanced to make good estimates.
We are opposed to using either airborne concentration or urine data to derive

a@ rem dose to a particular organ.

It does not make much sense to us to keep very accurate records of the industrial
exposure when exposures are low and at the same time not have information

01889683 -



one

September 8, 1959

ITINERARY OF URANIUM PROM TIME OF EXPOSURE UWEIL TIME OF
EXCRETION IN THE URINE. .
Bio-Assay Committee, R. C. Heatherton, Chairman

J. A. Huesing

Listed are some randon thoughts on the itinerary of uraniuo’
from g Of exposure un’ [3 or excretion bs
lL. Exposure

Procedures exist which enable us to determine with a fair .

degree of accuracy airborne exposure concentrations. However,
little 1s known about actual intake end retention. The use 0°
respiratory protection further complicates the exposure-intake

yatio.
2. Sype of Materia?

_ALyborne uranium contamination is usually measured in alpha
-eounts per minute per cubic meter of air. While the siphe

emission of uranium remains unchenged in the different chemical
compounds of urenius, the physical and chesieal properties of
Therefore, the physiological

a tobe gunds. But just sa st. rences
occur bere , etriki fferences ceeur in the me tal
of the @ifferent insoluble eompounds. Jor example Woes UOs:
3308s igs ete. each have their specific physical end cal

P whi

urenium compounds do differ.

ch influence their retention and metabolim.

3.__Soludility of Material

a@. Inbalation - the more readily soluble the material, the higher
the percentage of retention in the lung. Sandbook tigures
indteate 25% of soluble contaminant resains in the lung while
only 12-1/2% of insoluble contaminant is fixed in the lung.
The soluble waterial is cleareé frem the lung in 8 matter of
hours while the insoluble aterial is eleareé mueh sore

slowly. .

oe Ingestion - It is estimated that 60 <0 DS of tue
is moved vy ac pespire tract lus
baer vowrd the pbaryer ent is in tare senliewsd. re is
further estina that only from .0¢ to .C7® oF scluble

uranium is absorbed from the gut. Any &
the _gut would-fer the wost pert, enter the

- anasres


eo mc

2280484

HEALTH PROTECTION APPRAISAL
RATIONAL LEAD COMPANY OF OBTO

AUGUST 1972

by

THOMAS M, JELINEK

ROBERT W. POE



“we NLO, Inc.

Be

Use

le

4.

e. Test dosimeters were not routinely evalusted.

£~ Special care was always taken in the method used
to store films, te carefully control film process-
ing conditions, and in preparing calibration films.
Calibration films were always from the same lot and
. processed along with the workers’ films. See aiso
* attached Report On Examination “Audit of Controls
Over Radiation Badges” dated June 6, 1978.

G. There were no specific training requirements for
the film badge technicians when this program be-
gan in 1951. The technicians received on-the-job
training. The technician now performing all film
badge processing began this work in 1952 and has
been only technician doing this task since 1959.

Personnel who make use of the dosimetry results are
convinced that the dosimetry procedures provide a
reliable weasurement of radiation doses. Knowledge of
the calibration, development and read-out processes
leads them to conclude that the precision would be
better than £252.

of Badges 7

Since badges were always a combination security-dosimeter

badge and also contained nuclear accident dosimetry
materials, all employees have always worn badges. How-
ever, exposures were not always determined for all
Saployees. During certain periods female employees.
were not routinely monitored. Periods when male and
female employees were monitored were:

1951 - 1960: male employees only

1961 - 1968: male and female employees

1969 ~ 1978: male employees only

1979 - present: male and female employees
AEC (ERDA, DOE) Manual Chapter 0524. Female employees
were not monitored during certain periods because the
potential did not exist for them to exceed 10 percent
of the quarterly standards. - a ~
Yes.

Because of the dual nature of the badge, the time
employees did not wear badges was minimal.

-3-

-- 3455937


piece of radiation monitoring equipment for general personnel.
it was never standard procedure to require such monitoring as
well. I saw only one hand-held radiation monitor in use at

the plant, and two broken monitors that were never used. It was
not standard to screen personnel either coming or going at
Fernald. New monitering equipment was installed in the summer ef
1985, in my opinion, thirty-three years too late.

Another glaring precedural deficiency that I aiscovered in
By audits was the lack of a filing system for Maintenance
Procedures. File cabinets were simply stuffed full of documents -
in no particular order, and it would often take hours to find the
Procedure being audited. I also found that Standard Operating
Procedures (SOP's) and Manufacturing Specifications (MS's) that
had been "reissued", i.e. supposedly updated and improved, were
actually unchanged from the old versions.

Increasing my frustration was the Quality Assurance/Control
Department's total powerlessness. I did not have the authority
to put a hold on non-complying equipment or work.’ The auditor's
job was simply an advisory role. I was used to a stronger ;
Quality Assurance. function + + » in order for a quality assurance
department to be effective, it must be independent from
production.

2/ My opinion of the state of Fernald's environment is n
shared by many others. In July or August of 1985, Northwest
Pacific Laboratories was contracted to assess Fernald's enviren-
ment. I overheard one technician who came from the

Health and Safety Building exclaim, "The building is as hot as a
firecracker." The same technician commented about the Lab build-
ing where I worked, "The Laboratory is a pigsty."

3128789


Department, Laboratory Department; Procurement Department,
Engineering Division, Nuclear Materials Control and
Accountability Department, Transportation Department, Maintenance
Department, Production Control Department, and ironically enough,
the Quality Assurance/Control Department.

The implications of this disarray became immediately evident .
in the very building that I worked. The uranium dust in the
Laboratory Building was unusually thick, and I inquired abect why
such conditions were tolerated in February, 1985. I was informed
by Mr. Tippenhauer that there was only one dust collector and it
was in the basement. I went to the basement and took a look at
the dust collector, and then asked who was responsible for
changing the bag on this particular collector. Nobody knew. So
I asked where the procedures were for changing the collector's

bag. I discovered that there were no procedures. The bag, as

far as I could determine, had never, in the life of the

Plant, been replaced. Months went by, and finally, in June 1985,
I insisted that the bag be replaced, which it was. Mr. Graver,

Mr. ‘Fallings and ‘t ‘witnessed the removal of the old bag which had
disintegrated. Uranium dust had not only been building up in the
Lab Building for years, but dust was bypassing the bag and going
straight up the stack. Upon further inquiry, I discovered that ~—
many of the dust collectors in the production plants lacked
procedures, notably the portable dust collectors. {

In tandem with this problem was the lack of radiation .
monitoring equipment at Fernald. To ny knowledge, until about

nine months ago (mid-1985) there was not one state-of-the-art

3128788


~ monitoring for contamination was net performed on T-
Hopper 651 prior to package, closure and release tor
offsite shipment from Fernald and was not required by
any operation or safety procedures in effect at

e@ Fernald.

~ the release of contaminated T-Hopper 651 at the
Fernald site was attributed to inadequate managenent
control systems, primarily in the areas ef radiological
safety and- quality assurance audits, and ineffective
overview of the radioactive material packaging, safety,
and transportation activities at the FMPC site by the
DOE-OR field office.

7. the NLO Quality Assurance Audit committee conducted
its biennial audit of the NLO QAP en March i2, 1985.
The audit did not esncern any assessment of the inrlen-
entation of the Quality Assurance Plan,

- T-Hopper 651 was inappropriately labeled as an
"empty" shipping container because it contained uraniun
that exceeded the allowable internal contamination
limits as prescribed in 49 C.F.R. 173.427 (sc).

~ NO does not check for removable contamination on T=
hoppers prior to release of the shipment. DOT 49 C.F.R.
173.443(a) requires that sufficient measurements shall
be taken to assess the nonfixed contamination levels.

~ NLO procedures do not address the quality control
 ) requirements for 49.C.F.R. 173.475. This regulatory
section covers the condition of the closure devices in
three subsection. The closure devices must be properly
installed, free of defects, properly closed and sealed.
T-hopper closures were found that had rust, deformed
and contaminated gaskets, improper nuts on the
eyebolts, warped lids, and foreign materials on the
. flanges,lids. and. gaskets... - = 0. vo ctor

~ procedures at Fernald were less than adequate or
nonexistent.

= operating procedures for weighing the T-hoppers

were cut of date and incomplete. Consequently,

erroneous weights are being taken by the operating -
personnel. These errors create weight differences and
material accountability problems between Hanford and

NLO.

~ because the Transportation Dep't (at NEO) did not J
understand the applicable federal regulations, they did
not properly train NLO employees, especially the IHER
technicians.

- 21

3128801


to follow an MS is that a nuclear criticality aceident could
occur. Manufacturing Specifications dictate what a particular
machine's or instrument's capacity is'or is not: how mich
material a machine can withstand, at what rate, and under what
conditions. Manufacturing Specifications are important in most
industries for efficient and safe operations . . . in a nuclear
materials plant, they are the cornerstone of safe operation that
protect against one of the most deadly of:accidents.

The reviewing and compliance of Manufaacturing
Specifications are important enough that DOE requires strict
compliance. Yet the MS system at Fernald was in total disarray.
The blatant violation at Fernald would lead te civil penalties in
private industry; at the government-owned Fernald plant,
violations were simply routine oversights. As far as I could
determine, the plant was essentially self-regulated - - DOE had

abdicated its role as overseer by failing to check up_on whether

the contractor was obeying the rules. ‘The DOE preferred to rely

on the contractor's. flawed and inadequate quality assurance

program: -

Recordkeeping in the area of DOE Orders was also literally a
joke. DOE “regulates” its plants through directives in the form
of Orders. A DOE Order is supposed to set the requirements for
the total cperation and maintenance in the areas of worker
‘protection, envircrmental, health and safety, reporting of
accidents, and in almost every area of operation. I discovered
just how seriously Fernald management viewed the DOE Order

system when Westinghouse took over operations at

-ill-

3128791


SP -Yo08e 47 -

- 30,2 f62
Tete as of 102/62

the past three years all 6f
thi m scoducts were inspected \ se!
recceed oy the Project Labor /roqt.

item and at times the ¥6

catching on fire or causing
calcium metal was
thorium residus.

were od or rs
Plant 6 thorium furnace. I:
mes. sere in a worse condition than
this wes a mejor cause of the thos
The thoriun stterials are now

remelt
the residues are on the
thorium residues
ry 1,500 drums (240,000

Ye sad. Api
Giscarded at some off s:
- net weight) have b



~~
oNKO, Inc.

6. Records are complete.
7. This has not been necessary.

8. Most of the monitoring data is computerized. Data
is not computerized for workers who terminated before
computerization of records. Computer records also do
not contain monthly or yearly breakdown of exposures
for workers prier to 1961.

The format of the computer records has not always been
the same. For 1958 through 1960, exposures for each
badge period and yearly totals are listed. From 1961
to present, exposures for each month, quarter, year and
employment total are Listed.

9. One week, two week and month (four or five weeks) long
monitoring periods have been used. Since 1959, only
monthly monitoring periods have been used.

10. The only summaries available are those reported annually
sincé 1961 on AEC Form 190. There are yearly summaries
of whole body (gamma) penetrating radiation. There are
no summaries available for skin or extremity exposures.

TIi. Internal Monitoring Data

A.

Bioassay Program .

Uranium “in urine analyses have been performed on a tegular
basis to monitor employees for exposure to airborne
uranium. However, we have not used these results to make
estimates of internal exposure.

Whole-Body Counting

i. Whole-body counting has been.used since 1968.

2. Groups of employees doing the same jobs are scheduled
for counting on the basis of their potential for ex-
posure to airborne uranium. Additional counts are
obtained on individuals whose count results are above ~
50% of a permissible lung burden.

3. Whole-body counting was done "in house.”

4, We use the DOE's mobile body counter which was designed
and is maintained by Union Carbide's Y-12 personnel.
Initially, Y-12 personnel operated the counter at our

site. Since about 1970 we have been operating the
counter ourselves.

* Ses
~5-

3455939


TRELIUINARY SEPOMT - =XTFRHAL “ADIATICN + LEVELS FROW URANICY
aBD THORIUU

mergies of the cthoriun gammes §
cranium gaemas. ‘Thia ceans 42

ures to beta radiation
Ping of uranium. A
ad UX, and UXx2.

have cocurred. one
separation cocurs }

vye molten metal thereby con-
flation coming from the top
400 mreva/hr. - The crucible lids

have read az nigh for burning

out the orucibhes and 3 dust sollectors have been
high in beta ra ton py necessitating time limits for
work in

e@ high exposures are possible (and have occurred )
g or aged uranium materials, such a@ scrap

we ocourred during the handling of uranium
dge oxide, green selt, hex gas, ammonium
‘calt, rods, siugs, or derbies.

ures to gamma rediation have oocurred during the nandling
pling of thorium nitrate, during the inspection of
lugs, and during the start up phase of the thorium olant.
as imposed by this devartment have reduced the over-
xppeures to essentially sere. (The use of shielding has been
igoussed with several of the supervisors and in many cases it
decided that x time limit was much more practicei than

E. YY. tarry
EVB/bg

1600387


With all of these deficiencies unaddressed - - and
unannounced - - by Westinghouse, I could only wonder how
Westinghouse was really different from its predecessor, NLO.
Once again, it seemed that environmental, health and safety
concerns were taking a back seat to production goals. contrary

to Westinghouse's bold assertions and reassurances to the

community and to the public, it was business as usual at Fernald.

In conclusion, from my viewpoint Westinghouse and NLO both

were slow to correct the deficiencies identified by DOE. =

estimate that two weeks of hard work could have accomplished the

up-grading of all procedures necessary. Westinghouse
affirmatively misled the DOE by failing to bring to their

attention information from their audit files of relevance to the

DOE's investigation. Production concerns obviously played a
heavy role in Westinghouse management's failure to do so.
Finally, Westinghouse failed to respond and Follow-up on
my investigation report.

For DOE's part, DOE overlooked many important problems
identified by my audit. A team of four investigators failed to

identity 12 major’ items ‘uncovered by ny investigation in the sane

amount of time. To its discredit, DOE even failed to unearth ny

investigation report.
Inumediately following this incident, I was assigned what

turned cut to be my last project at Fernald. For me, it was the

final straw which led to my resignation and convinced me that y
had to come forward to expose the intolerable situation at ‘

Fernald.

- 27 =

3128807


computer systems, and supervised five personnel. 1 had been
promoted from Production Supervisor, where I supervised 31 per-
sonnel, planned manpower requirements, wrote weekly ‘and monthly
status reports, and conducted training and communication ses-"
sions. In May of 1984, I began my duties as Methods Analysts
Lead Auditer for National Lead of Ohie (NLO, Inc.) at the

Feed Materials Processing Center in Fernaid, Ohio.

es while at Fernald inelu:

My job ressensibi

coordinating, Fericrming and reviewing compliance audits cn
Standard Operating Procedures, Manufacturing Specifications,
Procurement Specifications, and Maintenance Procedures. I also
executed special projects and developed Quality Assurance
Decumentation. I maintained a security clearance (Level L, or
limited) and attended several training sessions and seninars, as
well as myself training other quality assurance/audit personnel.
In January, 1986, NLO, Inc. was veplaced as Contractor at Fernald
by Westinghouse Materials Company of Ohio (WMCO). My job
responsibilities at Fernald remained essentially unchanged until
my departure on March 24, 1986; ‘ appitiinatély 32 months ageér
starting there. :

CONDITIONS AT FERNALD
When I first reported to work at Fernald, I observed several
serious problems. My first impression was that the facility was
antiquated and in poor condition. I immediately noticed that the
building where I worked, the Laboratory Building, was
contaminated with uranium dust from personnel wearing process
shoes ang clothing into and throughout the building. Process

-3-

3128783


Page 3

Surface Measurements

Ingots:

Age
30 minutes

oS hours
2 days
he
5°
7"
127
uy, *
15°
20 *
21°

35°
uy?
56*
mh
216"
229°"

18.5

18.5
18.0

7.0
7.0
7.0
TS
75
75
8.0
8.0
8.0
8.0
7.0

765
7.0

Se

al
2
3


UNITED STATES
ATOMIC ENERGY COMMISSION
WASHINGTON 25.9. C.

326- AG Cmte

gg er Damon g 8 hele (024)
190 Constitution Avene | .
washington 25, De Co 7

Dear Er. Deans

me advisory Committee for Biology and Hedicine was partionlsrty,

Tae Aavio°Ty being able te hola their twenty-ninth meeting ot She
fos Vegas test site on October 2 and 29, 1951. For most of us

Tas Tega ev hiest opportunity to witness an atomic detonation, 24
toads WAS thi cstebami the radislogical safety operations in which
the Committee has been vitally interested since its inception, and
te which we hope we may bave made sone contribution We are grateful
$S hee tyler and Dr. Graves for making this possible; and to Drs.

to brs Miigher add Shipman for an interesting and instructive Progréne

Waile most of our time was devoted to field trips and briefing
sessions, we arranged to meet formally on Honday to consicer two items
of pressing importance: the effects of the Yatdenal Science Founda~
tion's training plans on the 450 fellowship progrsn3 and the AEC'S
responsibility im cancer research and therapye

he Committee reviewed.the carrent. status of fellowships in light

of the plars-of the NSF and supported the plans of the Division of
SSolosy and hedicine to continue the specil fellowships 20 a
medicine and in health physics, ‘and such renewals in the fields of
Tiology and medicine as constitute a soral obligation. They were in
Biology a0 he decision to give no new fellowships, predsetorss &



was “nothing to audit on a QA basis." 1 could certainly agree
with that, but I wondered what ur. Grumski intended to do until
Westinghouse had finished installing its 9a replacement program.
The Quality Assurance overview ef procedure audits that was
submitted to management consisted of Andit Indexes. These
indexes catalogued the number of audits, audit follow-ups
actually performed (with corresponding dates), and the number of
audits that were never performed. The numbers, provided below,

speax for themseives.

AUDITS PERFORMED IN LIFETIME oF FERNALD

Standard Overating Procedure Compliance Audit Index, 1/1/86

Audits performed: 83
Audits required, but
never performed: 296

Manufacturing Specifications Compliance Audit Index, 1/1/86

Audits performed: 7
Audits required,
but never performed: 95

Maintenance Procedure Compliance Audit Index, 1/1/86

“

Audits.performed: -- - - --3-
Audits required,
but never performed: 218

Quality Assurance Compliance Audit index, 1/1/86

Audits performed: 93
Audits required,
but never performed: 60S /
Audits with followups: is .
Audits with no followups: 77

- 14+

3128794


= audited was deficient in some

Very single cperaticn that
way as far as having up-to-date, comprehensive and workable
procedures. Massive noncompliances with written procedures were
observed in areas of. critical safety. = had to rewrite
procedures myself in some cases, even though that is generally
not the responsibility of an auditor. Z_only was able or

permitted to audit a very Small portion of the overall plant

procedures . . . I was warned not to touch the chemical cr waste

areas; X-65 areas; Gust collecticn systens in the production

areas; and many other areas of critical Plant safety.

Another observation was that Management had the power to

accept or reject audit findings and recommendations at they saw

fit. There were many instances where management chose to
institutionalize a dangerous practice that I had discovered, or
to ignore the problems altogether. I was often instructed not to
pursue certain audit follow-ups, especially beyond a certain
stage.

Out ef 23 audits = performed, management disagreed in whole
or part, with the suggested corrective actions; failed to respond
altogether, or failed to provide the requested corrective action
as promised.

Finally, it should be noted that Westinghouse ended my
audits altogether. on January 6, 1986, after I submitted to
management a Quality Assurance overview of all Procedure audits
performed over the lifetime of the Fernald site, I was instructed
by the head of @A/scc of Westinghouse, Mr. Grumski, net to perfem
any further audits. ‘In this respect, I was muzzled from
performing my standard duties. His explanaticn was that there

-i13-

3128793


040632

IH&R Departwent Monthly Report for May, 1956
J. A. Quigley, M. D. -
dune 4, 1958 Page 5

department to determine if it will be of any aid in this regard.
The feasibility of this will be determined within the next few
days.

Nighttime lighting surveys were completed in the Health &
Safety Building, Technical Laboratory Building and the Service
Building.

Reports were completed and distributed during May on lighting
surveys which were taken in the Administration Building,
Employment Building and the Service Building.

Ventilation Projects

A complete evaluation was wade of the Plant 4 packaging

stations! ventilation. ‘This was done in conjunction with

Production Engineering in order to determine what improvements

were necessary for adequate ventilation. It was concluded

that a new dust collector would be necessary and redesign of

sont, of the existing ventilating facilities was also deemed
sirable.

At the request of this department, the dust collector pags
in 043-27 dust collector in Plant 8 were wade with an over-
lapping seam instead of the usual butted seas. It was felt
that thia type of seam would be stronger and have a better
colecting efficiency providing that the blow rings didn‘t
exert too-much.wear on the.seam. -A month and a haif has
elapsed since installation and these vags show no signs of
abnormal wear. If they continue to work satisfactorily, shis
type of bag will replace Purchase Order #GS-1670.

Stack Sampling

Stack losses during May were epproximately 856 lbs. of uraniun
as o red to 428 ips. for april. A loss of 451 lbs. originated
from G4-7 in Plant 4 while 83 lbs. originated from G43-27 in
Plant 8, 70 los, from G1-754 in Plant 2, and 6i lbs. are reportec
as lost froe G42-615 in Plant 9. The cause of the losses has
deen investigated and it has deen established that the broken
bags undoubtedly were the cause. These bags have been replaced.
The total loss for Plant 5 during May was lbs. of uranius,

the second loweat ever reported in their history.

External Radiation
Film badgea worn during the period 4/16 to 4/35 indicate inat


SUBJECT
TO

FROM
REFERENCE

priya

NATIONAL LEAD COMPANY OF OHIO

A Buetorame OF WE HOUSTRIES, IMEs
CINCINNATI, OHIO 45239

November 24, 1980
COMMENTS OR DRAFT REPORT OF HEALTH PHYSICS APPRAISAL, OCTOBER 7-10, £980
B. J, Davis and K. Shank °

R. C, Heatherces

As I commented to K. Shank over the phone on 11/21/80, ve do take
exception to some things which are said in the report. The exceptions
represent a difference in opinion regarding the seriousness of some of
the deficiencies found at the time of the appraisal. Our primary
concern was how the report might be interpreted by opposition eritics
who wight obtain the report under the Freedom of Information act and
quote from it for proof of our poor management and fRarard to employees
and the public in continued operation of the plant. Tf the report and
our response do not convey the impression of undue hazard ve are not
greacly concerned.

We do take exception to the use of the word poor vith reference to

exposure cootrol in the sumary and conclusions on page one. Consider

the plant has been operating for more than 25 years and most of our

work force has been here that long, ‘These people received their radistion

exposure control dndoctrination and dnitial job training vhen less stringe

standards were in effect. We have emphasized the need to meet standards

but also attempted to avoid cresting fesr of radiation of harmful effects
exposure at these levels. Additionally, allowable exposures have bees

~ of. st
periodically lowered. In°view of the circumstances, it. does Dot s¢oo

thar one case of exceeding the current asximm pernissible ‘exposure to
the skin can be called poor control.

We must admit to some failure in the commitment tO the ALAP or ALARA
why it is feult

principle. The foregoing comments, in part, explain
to get our people to change some practices. While efforts vere wader we
realize now the effort and achievement were not what is expected.

Many of us at the wanagement level pelieved our objective vas tO operate
thig pliant to turn out & quality product safely, efficiently, and econon
ideally. In order to achieve this objective, judgments vere nade regardis
cose of exposure control and expected benefit. Perhaps our judguent vas
poor, especially considering whet is generally expected with ALARA



—
+ "BLO, Inc.

5. The mobile body counter was programmed to provide
radionuclide content of the workers. Consequently,
we-were not required to caiculate this from the raw

r ) counting data.

6. The amount of 073° in one lung burden or uranium at
various U enrichments has been caiculated on the
basis that 0.017 pCi of uranium produces a dose to the
lung of 15 Rem/year. The enrichment of the uranium
in the lung is calculated from the total uranium and
u?35 values provided by the body counter. The amount
of u7°5 representing one lung burden for that enrich-

, ment is then divided into the amount of U7*° in the
lung to obtain the percent of a lung burden.

C. Other Internal Monitoring Techniques

1. Air monitoring results were never used to estimate
internal deposition.

2. No other monitoring methods were used to estimate
internal deposition other than whole-body counting.

D. Administration and Recordkeeping

1. Internal monitoring reports are not computerized. -

2. Unusual values are validated by additional counts
obtained on the individual. If a medicaliy adminis- .
tered -radioisotope is suspected, confirmation is obtained
e . from the individual's doctor or the hospital. aa

3. If artifacts are discovered, a notation that the count
results are unreliable is made in the worker's record.
The reason for judging the count to be unreliable is
also included in-the notation.

4. Prior to 1979, there was no formal procedure for merging
. internal and: external’ dosimetry data although this
was done for the higher exposures. Since 1979 a list-
ing has been prepared of those employees with either
internal or external exposures above certain levels.

Attachments: Radiation Records Survey Questionnaire .
Report on Examination, "Audit of Controls Over
Radiation Badges"

+6-

3455940


NU

3. ‘Immediately clean up the contamination in the re-
finery and recovery plants; that safety devices
and operating equipment be kept in proper repair;
end that increased attention be given to reducing
contemination that results from abnormal operating
conditions.

kh, Post those areas vhere ear protection has been de~
termined to be necessary.

5. Review and achieve compliance with the Occupational
Safety and Health Standard concerning respiratory
protection; further, those plant areas where respira-
tory protection is required should be posted.

Iv. Findings

Ae

ony
er

Extremity Exposure

Several areas of the plant present extremity exposure
-potentiais which exceed 10% of the AEC guide of 75 Rem/yr.
The operators in these areas have been monitored in the
past on a periodic basis, and annual extremity exposures
have been extrapolated from this data. Contamination of
wrist badges has, however, resulted in large uncertainties
tn the results. NLO nas recently acquired a@ new wrist

‘badge which precludes much of the contamination, These
new badges vere used for 8 two-week period to monitor ex-
tremity exposure in Plant’5. Kesults indicate ‘that ‘ex:
trapolated quarterly exposures range from 3-17 Rem/quarter.
On the basis of these results, it is recomnended that NLO
continue the periodic monitoring of all potential extremity
exposures; that those operations identified which result

in greater than 10% of the annual limit be monitored at
least tvo weeks each quarter; and that those operations
identified vhich result in greater than 50% of the annual
limit be monitored continuously. Should monitoring indicate
@ high exposure (greater than 50% of the annual limit) for
certain operations, NLO should consider engineering or opers~
tional changes to reduce the exposure potential. (Specific
reference is made to crucible loading in remelt area of
Plant 5).



Zergon 20am

Er. Soré=

next meeting for January 11 and 12, 1952, at the
gaiversity of California at serkeley, California.

g Sincerely yours,
oes Solon Lee he tees

E. We Goodpasture, HeDe
Vice Chairman
Advisory Committee for ology and Medicine


Il.

rit.

Purpose_and Scope

‘he annual health protection appraisal of NLO was conducted
py members of the Health Protection Branch, Safety and
Environmental Control Division, ORO, on August 22-25, 1972.
Emphasis was pisced op compliance with AEC Manual Chapters
and the Department of Labor Occupetional Safety and Health
Standards in the areas of health physics and industriel
hygiene.

Summary

The overall health protection program continues to be satis-
factory. Several ereas within the program require modifica~
tion end/or increased attention to comply with the Occupational

Safety end Heaith Standards. Several plant areas, visited were
judged to be presenting hazardous vorking en’ ronments for

employees end recommendations were made for immediate correc—
tive action.

At the conclusion of this appraisal, detailed comments and
recommendations were presented to NLO management and to the AEC
Site Representative.

Recommendations.

bh

A. Recommendations of 1973 Appraisal

There were no recommendations made as @ result of the 1971
appraisal.

Be

Current Recommendations

Qurent 3

it ds recommended thet NLO:

1. Continue periodic monitoring of extremity exposure
for those operations which are identified as
potentially exceeding 10% of the annual extremity
exposure guide, and provide continuous extremity
exposure monitoring for those operations identified
as exceeding 50% of the annual extremity exposure
guide. (See Section IV.A.)

2. Urine samples collected from the chemical operator
group be spread out to cover the entire quarter,
rather than one month es at present. (See Section
Ty.D.)



example, if I stood on one side, the reading might be zero while on
side, might be 50 times Maximum Allowable

the other , the
Concentration ("MAC").
6. In order to obtain an accurate result of what the employee is
» it dust survey be done as
close as possible to the production plant employee’s breathing

zone. should be taken in the direction that the dust is
blow: _if the sf is jacted to the dust.

7. on several occasions during the term of my employment, when I
got air dust survey t ba

Fesults that vere above the MAC,
that the results were_in’ and I was told to go
- « one spec: eccasion when I was
sampling jo: in plant 5 where ventilation modifications had
just been made and I was sent out there to sample the air. The

production plant employee was working over the jolter and the dust
was_coming up into his face. I obtained results that were ahove

the MAC. I think that my results were correct the first time that
I sampled because they were similar to the results that I had
obtained before the modifications and the modifications were not
effective. Nevertheless, my supervisors told me to go. back and

8. In air dust surveying there were many other variables that could
change the results. For example,

(a) the results were lower in the summer because the windows
in the plants were open; ..

(b) if there was dust laying on the ground or on equipment,
this dust could be resuspended and become airborne; .

(c) feEk truck traffic would “increase the airborne activity;

(a) if the ventilation ducts were partially or completely
plugged, the air dust would be higher in the work areas;

{e) production rates would affect air dust results; and

(£} whether the standard operating procedures were followed
would affect the results.

9. When there were fires in the buildings, the windows and doors
were opened to get the smoke out and sometimes the air dust surveys
were not taken until after the smoke had cleared.

10. when there were fires outsi the buildings, generally on a
storage pad, the air dust surveys were taken were randon as to
location and tine.

11. In the annual air dust survey reports I wrote recommendations
for reducing air dust levels in the plants. Some of these

2


Logger fos

Deficiencies that were identified were net recorded in a
‘ e systematic manner, and therefore no "trend analyses" could be
performed. Trend analysis is like institutional memory.

* Incidents and mistakes that are recorded systematically can be
evaluated to help prevent repeat mistakes. At Fernald, they kept
commiting the same mistakes over and over again. In effect,
Fernald was not learning from its past mistakes.

Tne extent of the problem and its implications are further
revealed by an audit I performed in the first few months of my -
tenure at Fernald. I performed the first audit ever of
Maintenance Procedures at Fernald. I found that these procedures
were out of order, and were not kept up to date. I found it
incredible that maintenance operation at a nuclear maaterials
facility was allowed to go unchecked and unverified for over 30

[ ) years. Maintenance of sensitive equipment was” simply left to the
memory of supervisors and workers. By the time of my departure,
I had finally put the Maintenance Procedures in order, but had
not succeeded in convincing management that a system for Updating

“es ‘ and revising maintenance procedures should be established.

As far as the audit program itself, there were terrible
inadequacies. For instance, there were Re procedure audits
performed at all until the mid-1970's. Half of the audits -
performed in the late 1970's are missing, presumably
irretrievably gone. In the area of auditing Manufacturing {
Specifications (MS's), I found that NLO had only performed ‘six.

audits in the entire lifetime of the Plant. It is extremely

important that MS's are followed. A possible resnit of failing

e 38:

3128790


- Need for maintenance standards for --

* scale calibration revision :
* calibrating NLO-fabricated checkweisht
(revision needed.)
On February 11, 1986 a DOE Transportation Safety
Apptaisal team visited the site and spent the whole day reviewing
Fernaid's procedures. Four DOE personnel, including Mr. Pryor,
Mr. Hansen, Mr. Fouck and Mr. Slatterly conducted the review. on .
February 12, 1986, they held a close-ouz neeting to disezss thei:
findings. I was told to attend the meeting by Mr. Weichold. on
the way to the meeting, I was told by Mr. Weicheld that, "r¢ you -
are asked any questions, be careful what you say. Say as little
as possible.“ I knew what he was vefetring to, because =r
realized that the true state of affairs in the Transportation
Department in relation to T-Hoppers was such that Fernald was in
jeopardy of being suspended from being able to transport the T-
Hoppers at all. Conceivably, production could grind to a halt if
that happened.
The meeting cccurred, and sure enough, nothing at all
was mentioned about ny investigation. At the meeting was Mr.
‘Grumski, ‘ur. Weichold, Mr. Block of the Transportation
Department, myself and the DOE representatives. Ineredibly, the
DOE team only uncovered three items that they felt were of
concern. Two of these items were problems I identified in ny -
investigation. DOE, with a four man investigation team, had
totally overlooked twelve major problems that one single auditdr
had found in twenty hours. It was clear that Westinghouse .

management was not about to volunteer this information. was

~- 24 - .

3128804


@ NATIONAL LEAD COMPANY
SF OHIO

> ©. BOX 158
AT. HEALTHY STATION
> CINCINNATI 31. OHIO

- : way 3, 29595

TIN +

“D R. C. Heatherton

=. ¥. Zarry

Introduction

In comparing the tyo eieme
sranium and its cauenters
and its daughters insorar
are coneerned, anile (Ss

Yhen uranium is separated selore and processed into

3 80 radically sroken that
@ some of its daupgte!
= TR = 1600 years

the two da vers UX
between 0255 and
equilibrium val

not pogaees any long lived
itey@ - the longest being BenaL28} Yefich has a nalf

After pros ing into metal the dauchters |
In approximat: 20 days the first period
oni. . Thistperiod lasts for avproximate-
high +: actiri ecreases by 25 to 30%.
Lats unt§l 3 years after separation. From
y/o the sorivity increapes till at the end of 60 years the
and 1 period of/equilibrium is achieved. The

secon@-veriod is twice that of the first veriod.

the long half lives of

h te = 30,000 years and S8Ra226
equilibrium that is achieved 13 among
Th23.) and UX2 (91PaZ34 ) which lie
approximately 2h¥fdays 99.9% of she
seytwo daughtengiarg formed.

Rad

ae.
areMiue ENS surface beta dose rate is 2h0 areps/hr, while
therium the surface dose rate at the end of the third yeer
K3 mrepsshr. The dose rate during the first period of

gatitbrium (writer's ovinion) is approximately 60 mrevs/nr.

© dose rate during the second vericd of squilibrium is

115 mreps/nr.

Because no sevaration is 100% complete equilibrium is achieved
sooner. This iz not too important in the case of uranium but
it £3 se in the case cf thorium because of the more intense
gamma radiation emitted by the thorium daughters.

2910031 1600386


040630

IH4&Q Department Monthly Report for May, 1958
Te he Quigley: Me De :

Jane 4, Page 3

Approximately 25 tons of K-65 drums have been baled preparatory
to a test melt at Knoxville, Tennessee. Contact readings of tne
cales range from 1 <tc 5 ur/hr, Estimates of the radium content
indicate there will be 25 to 50 mg Ra in the 50 tona necessary
for the melt. This indicates that there will be little, if any,
radiation hazard associated with the metal recovery operation
at Knoxv. .

Monitoring service is currently being provided the Residue
Comaittee Chairman in the preparation for disposal of thoriun-
contaminated wastes at FHPC.

A wrist fils badge, inadvertently left near some radium-
containing samples in the Radio Chemical Laboratory, showed
480 mr gamma, This occasioned a radiation survey of the
laboratory and special film badges were placed stout the ares
for confirmatory data. Instrument readings indicated a gamma
exposure of 1 to 10 mr/hr at working distance Selcw the waist,
due to materials on cabinet shelves below bench tops. Film
data will ta reported later,

Laundry studies of dust collector bags are currently in progress.
Bags reading up to 30 mrep/hr before cleaning show readings of
0.5 to 5.0 ursp, after cleaning. The wool type 24 usually
under 1.C mrep, after cleaning, while the canvas material
veads higher, Purther repozt will follow upon completion of

study.
Misceliencous Special Stucies
Investigations were continued this month in an effort to
ascertain the cause of the chlorine releases in Plant 8.
These particular releases ocour when the caustic scrubber is
dropped into a digestion tank and hydrochloric acid is added.
A wore frequent cropping of the scrubber «as recomended aa
desiradle in allevisting the problem. Adding the acid more
slowly and the use of a digestion tank closa ta the scrubber
for better ventilation was also suggested. Plant § personnel
are investigating the possibility of removing the scrubber
iiquer directly to the sump, as uTanium analyses are usually
OW.

A rough draft of Health and Safety specifications for solvents
is nearly completed. This will be reviewed by Dr. Birminoghan
of the USPHS before being submitted to the division director
for final approval, This same degree of completio: is
applicable to the specifications for powdered huid soaps.

Au investigation was made concerning the clothing change
requirements for subcontractor personnel involved in relocating


NLU sy

anc.

5. Initially, heat damage from leaving badges in cars
during hot weather was a problem. However, this has
not been a real problem for many years. Leaving badges
in desks, cars, etc., did not heave a significant impact
on the overall external dosimetry program.

6. Temporary badges were provided if a worker left his
badge at home*or lost his badge. If the dose registered
on the temporary badge was considered to be of no
consequence, no adjustment was made to the individuals
dose record.

7. Workers normally wore their badges on the upper part of
the body (on shirt collars or shirt pockets}.

Other External Monitoring Techniques

Only film badges or TLD's have been used for determining
actual personnel exposures. Neutron monitoring is not
required at this site.

Administration and Recordkeeping

1. Initially, external radiation doses were reported in
mrads and later in units of mrem. ao
For our gamma (whole body) exposures, the units of
roentgen, rad and rem were assumed to be equivalent
and no conversion factors were used to convert from
one to the other. For beta and gamma (skin) exposures
no Conversion factors were used to convert from rads to
rems. The published value for the absorbed dose rate
produced by natural uranium metal expressed in mrad/hr
was assumed to be equal to the same dose expressed in
mren/hr.

2. No quality factors or modifying factors were used to
evaluate dose equivaient.

3. Anytime a reading was considered questionable, an in-
vestigation was conducted. A decision as to whether
or not the reading was legitimate was based on the find~
ings of the investigation. ~

4&. A dose is assigned to a worker if his dosimeter is
lost or damaged. The amount of dose assigned is based
on which jobs the worker performed during the unmonitored
‘period.

5. Several films (blanks) are taken from the supply of
films which are stored in a refrigerator and developed
with the calibration and personnel films. The blank
films are used to zero the film densitometer. This
automatically compensates for background radiation. <

- -he

3455938


Page

Derbies (Urenium)

Age

15 minutes

20 minutes

5 hours

1 day

2 days

Derdies (Thorium)
1 day
2 day

5 days

Slugs (Uranium
—~ days LP

U9 days
Ud; days

30 to 100 days
casting dates unknown

15
16
17
27
22 - 26

10

So

ol

ol

8
9

15.5 - 20

1600329



THER DEPARTMENT MONTHLY REPORT FOR OCTOBER 1969 Page 3

3. & Quigley, M.D.
November 11, 1969

exposures of 2550 and 3250 mrem. There were ten badges that exceeded
one-half the MPD or APD. 4 breakdown of these exposures is as follows:
PlakS - 6 - Remelt Area Operators
Pilot Plant -3 - Thorium Processing
Plat9 - 1 - Remelt Area Operator
Ground Contamination
‘The amount of uranium lost via the Storm Sewer System for October was
2$4 pounds. No unusual spills of contaminating materials or losees to
the Storm Sewer were found to have occurred.
Stack Losses

The estimated uranium loss from dust collectors during October totaled
62 pounds. No thorium loss was estimated.

Environmental Sampling -

No NCG values were exceeded during October in the Miami River or
Paddy's Run. ‘The total suspended solids concentration in Manhole 175
effluent continues to average well below the NCG of 100 mz/1.

Our off-site sampling results for nitrogen dioxide and fluoride durin:
October were all below NCG values.

Work Statiaties

Samples Collected - 155 Equipment Material Passes - 29
Air Dust - 1l¢ Nuclear Safety Change-Over Inspections - 16
Stack - 4 Receipts Monitored - ¢
Water - Hn Radiation Work Permits - 8
Fluoride - & Drawings Reviewed - 3
Nitrate - &

MWB/fb

ce: J. A. Quigley, Mi. D. - 3x

BEST COPY AVAILABLE


SUMMARY

PORTSMOUTR~GASEOUS DIFFUSION PLANT

Monitoring B-the work place was generally good, with one possible
exception. The move of air in the process facilities apparently has never

been checked to determine 4{ “dead-air® pockets exist or if their air samplers
are properly located.

ible internal exposure appeared to be

ermanent, better shielded in-vivo
ion level could be Tower and the
-up measurements if an

Monitoring of the worker for po’
adequate, however, the installation of
counter would be of benefit in that the de
counter would be available at a71 times for fo
intake has or probably has occurred.

NLO FEED MATERIAL PRODUCT IN CENTER

Both the monitoring of the work place and of the workers appeared to be
less than adequate in my opinion. Air sanoting was almost non-existent,
personnel contamination survey equipment both in the work place and at exits
from the work place were not ‘apparent, and though both direct and indirect

bioassay measurements are made, no efforts were visible in trying to use these
data to estimate internal exposure.

MISCELLANEOUS

The scope of this review did not include consideration of chemical
toxicity vs. radiotoxicity of uranium. Recently there has been some
speculation that the radiotoxicity limit is controlling but to my knowledge
this question has never been completely resolved. I have discussed my concern
on this matter with Ed Vallario. Perhaps a DOE Ad-Hoc Committee could be
formed to investigate and resolve this matter.


P Nr. Boback, and representatives of the U. S. Uranium Registry have

T been in conversation about a potential project. . It would seem that

“— NLO has a unique population for study, and that the U. S. Uranium
Registry can offer NLO a mechanism by which autopsies may be obtain-
ed and tissue analysis accomplished.

The purpose 9 ris tet is to make you aware of these con-
versations. ~ there develops-a basis for an active relationship
between NLO afd the U. S. Uraniud Registry. we hope you would react
favorably to Mr. Samuel F. Audia ggarding such an effort.

TI would be pleas d
any questions you may have abou’

y\additional information, or answer
his potential effort.

_ Sincerely, pb?
Ne EN: UL. w”
R, H. Moore, M.D.
ja ;
File/1b

cC: C. C. Lushbaugh, M.D.

Vin, Aadew 2 Manage
of Yatra’ Fol of he .


SITE VISIT

February 21-22, 1985
Feed Material Production Center.
National Lead of Ohio
Fernaid, Ohio

Contacts: M. W. Boback, Director Health and Safety; R. B. Weidmer, Chief,
Tadustrial Hygiene and Radiation; S. L. Hinnefeld, Technologist; T. A. Dugan,
Supervisor, Bioassay Lab; W. A. Hayes, Technologist

OVERVIEW
The internal dosimetry program provided for the workers at the Fernald FMPC

was reviewed in depth. The primary contacts were R. A. Weidmer and
W. A. Hayes. The following elements of their program were reviewed in depth:

© Work place monitoring
e@ Worker monitoring
e Miscellaneous

Overall their program and practices appeared to be lacking in many aspects.
These are discussed in the body of the report.

A. WORK PLACE MONITORING
A.1 Observation

There are no fixed area air samplers installed in the process facilities.

* Some lapel ‘samplers are assigned to workers performing jobs with higher

release potential.

. Comment: Area.air sampling is an essential element of an effective work
place monitoring program. Criteria for placement of Samplers, the ~ ~~~
installation of samplers, and a study to assure that samplers are not located
in a dead-air pocket are essentia} for a good program since the airborne

contamination is not uniformally distributed throughout the entire work area.

Recommendation: A study should be performed to chart air movement.
Criteria for the placement of area air samplers should be documented and air
samplers should be installed.

A.2 Observation: There are no contamination survey instruments kept at the
work Site for use in checking for skin and clothing contamination. Neither
are there any hand and shoe counters available for use either before or after
showering.

Comment: This practice is totally unacceptable. Workers are forced to
accept that the shower at the end of the day is completely effective in
removing any skin contamination. Also, this practice does not provide any
"triggers" for follow-up action to ascertain if the workers have’ taken any

.

6 =


@ TEM DEPARIMERY MONUILY REPOR: - AUGOSE 1 ~ AUGUSY 31, 19ST Page 2
Jo Ae Quighey, KeD.
September 5, 1957

from the pumber or persons receiving 2 siniiar exposure in the
preceeding four-week .period. Only one badge exceeded MPD.

One badge also exceeded MPD for gamma exposure. ihis was 3 badge worn
by 2 man while working om the thorinn redrumcing operation. Time
Limits have been established to prevent this from reoccurring.

Liquid Effinents

‘this month the river flow hes been lower then usnsl because of the
lack of rain, ‘the lowest flow of the month was 475 cfs on August 26,
‘this combined with large amounts of contaminants in the effluent
stream has given the highest results since March. Relatively high
amounts of contaminants in the effluent were resulted from Plant 3
Deing partly shut down for repairs from August 12 to August 14,

‘the high flnoride liquor from Plant 4 is being precipitated with
lime and the solids and CaF settled and pumped to the fluoride pit
because of the low river flow. .

‘the liquid effiuent from the Laundry bas been sampled and a report is

being written.
‘ ‘the Refinery requested and was given permission to dump raffisate fron
. two columms to the Generai Sump for three days. this solution was to

be settied prior to pumping to the river and the settleable solids
distributed to the clay pit for storage. A procedure was written for
this approval in the future and agreed upon by both Production end
Heaith & Safety.

Eallout Sempling

_ AIL guipéper sexples are being changed approximately once ‘each week
in an effort to determine the reliability of gumpeper results. Pre-
liminary results indicate that one month is too long for reliable
results.

Results of gumpaper semples taken this sonth show that in the month of
July the amount offaliout on the site incressed to above five tines.
at of

e radiation exposure figures, whe report on this survey is now in
progress. and should be ready for distribution in September.

S PE 743s


- +i\<and safety aspects of the operations. I stated at the time that

other procedures were involved. Iwas told by mr. Macaulay,
Westinghouse Operations Training Manager, to stick with the
eight. Two days later, February 12, at another meeting
management decided to add four mere procedures.

“Management gave eight calendar days to complete the
procedures, and added six calendar days to complete development
and implementation of training, roping off areas, procurement of
disposable clothing, cleaning, etc. That was far too little
time. I felt that at least two months were required. due to the
magnitude of the Project, and I said as mich. Despite this, Mr.
Weichold and I were the only ones assigned to write/revise
procedures,

On February 11, Mr. Weichold informed me that he would not
be working on the Project, and gave ne the full responsibility
for completing the assignment. This change definitely made it
impossible to meet the deadline for the project. I had already
pointed out in the February 10 meeting that I believed that
everyone was “unduly overly optimistic" concerning the
-preparation-time: giver’ to procéss the plutoniun. The unanimous
response at that time was "No, we can do it." As mr, Macaulay
said, "I think you guys can get the job done."

The next meeting was held on February 14, 1986. Mr.
Macaulay, Mr. Gardner, Mr. Hinnefeld, Mr. Neyer, Mr. Walker, Mr.
Weichold and I were present. At this meeting mr. Macaulay wanted
the procedures signed off. I stated that the procedures were
inadequate, especially the Health and Safety Precedure. I then
told Macaulay that all procedures would have to be sent around

-30-

3128810


é

—

THAR Departuent Monthly Report for May, 1958

J. As Quigley, KN. D. .
June’, 1958 Page 2

Re-evaluation of Cleaning the Sperry Filter Presa, Plant 9 ~
The report hag been written and distributed. Air dust levels
have decreased over previous surveys, However, the woaring

of dast-type respirators was still recommended dus to the
Seriagion of air dust levels normally encountered in operations
2: type.

Evaluation of Baling Q-11 Drums, K-65 Area - The report has
been written and distributed, Breathing zone air dust levels
were found to be as mich as 30 times the MAC downwind of the
operation, The use of dust-type respirators was recommended
at al) times when the baler is in operation.

Evaluation of UF_-Hg Blend Briquetting Press, Pilot Plant -
The report has been written and distributed. Some breathing

zone samples were found to be as much es 81 times the MAC.

Due te the expected short term of this operation, only 8
temporary type of ventilation wag attached. The use of dust-
type respirators was recommended at all times while the briquetc: *
is in operation.

Processing Berylitum-Contaminated Material, Plant 8 - A letter
with specific recommendations for parsonnel protection
immediately prior to and during the initial prosessing of
Beryllium—-contaminated materisi was prepared and distributed.
These recommendations included respiratery and glove protection
and are intended to cover not only the campaign of accumulated |
waterigl tentatively. scheduled. to begin Wednesday,. June. 4, 1956,.
out to apply as well to any future operations of this type.

Special Radiation studies

During the shut-down of digestor tank 104 in Plant 8 for repairs,
special test film badges were exposed for varying periods of
time. These badges are now being processed and, upon reading,
will provide a comparison between cur monitoring instrument
readings and fils badge exposure data. Aliso, survey readings
were taken in tank 101 before starting a campaign of specisi
material. Readings will be taken again soon (approximately

one month efter first readings) to determine whether or not

auch material ig contributing to the high radiation readings
currently found in the digestor tanks.

Radiation surveys are being made in connection with the K-65
drum baling operation currently in progress. Average instrumen.
reedings in working areas are 1 to 5 mr/hr. Special film vadsez
have been placed at locations representative of working areas,
and these and regular film badges will, upon processing, give

a clearer picture of personnel exposure at that particular jot.

040629



State of Ohio: _
County of Hamilton: ss

x, being duly cautioned and sworn, state as
follows:

1. I live at-

2. I worked at the Feed Materials. Production Center ("Fernald") at
Fernald, Ohio from _ 4953 until 1971. For
the entire time that I worked at Fernald I worked in the Industrial
Hygiene Section of the Health & Safety Division. My supervisors
were Richard Heatherton, Robert Starkey and Michael Boback. Dr.
Joseph Quigley was the Director of Health & Safety during ny
employment at Fernald.

3. I was an industrial hygienist for the entire time that I worked
at Fernald. My job responsibilities consisted of conducting
surveys in the various plant areas and on
such items as dest . , and yentilal
surveys; sur’: aust collector exhaust and estab:
gampling rate for particulate oa
for material to the vii

dust "aot rectars, as well as pant effluent to the river; river?
investigating fume releases, dermititis cases as to possible cause,

@, and higher than normal urinalysis

4. I aid air dust surveys in all the plants at Fernald. f used a

ler which consisted of a small vacuum with a Whatman
filter where was drawn through at a given flow rate. The
samples were all collected open face which means that the filter
paper was not protected on the front of the sampler so, for
example, that it was possible to lose some of the dust. if you were
pumped. You could also lose dust when transferring the filter
paper inte an envelope.

5. When I did air dust surveys, I could get a higher reading if I
stood in the direction that the dust was blowing from the employee
that I was sampling. Conversely, I would get a lower reading if I
stood in the opposite direction from the way that the dust was
blowing. Where I stood could make 100% @ifference in the results
that I recorded depending on how dirty the operation was. For

1



office became the storage area for desks, chairs, and filing
cabinets, making my office crowded and inadequate. This action
was accompanied by warnings and threats about my job security
from Mr. Tippenhauer and "through the grapevine." After I
complained about my office space, I was told by Mr. Tippenhkaver
that if I didn't like it, "You know where the door is." 1
stopped complaining.

The bulk ef ny respensibit in the first year
involved audits of three areas: Standard Operating Procedures
(SOP), Manufacturing Specifications (MS) and Maintenance .
Procedures (HP). An audit involves comparing the written current

procedure against the actual performance of an operation.

Adherence to the procedures is required in order to promote

efficiency and prevent accidents, as well as to avoid
radiological occurrences such as an accidental nuclear
criticality.

Despite the importance of the procedures, I consistently
found that the procedure being audited was often non-existent '
out-of-date, inadequate, ignored, or inaccurate. Complicating
the situation was the fact that management was slow to respond;
the submittal of an audit report requires a response from
management within thirty days, yet management often failed to
respond for as leng as four months.

Management also ignored key items for correction, and faifed
to implement corrective action when promised. In an audit of the

water testing procedures at Fernald in late November, i985, I

discovered that many of the water samples were brought to the

-6<

3128786


ZLOLLEG

ah

7 . 2236847
NATIONAL LEAD COMPANY OF OHIO
AT AT mammal
——————
P.O. BOX 39158 CINCINNATE 39, OHIO

AUG 1 7 1965

Mr. C L. Karl, Area Manager
WU. S, Atomic Energy Commission
P, OQ. Box 39188

Cincinnati, Ohio 45239

SUBJECT: STANDARD FOR THORIUM-230

Dear Mr. Karl:

We would like to
given in Annex 1, AEC Appendix 0524,
This exception is. requested because of
the Middlesex thorium nitrate whi:

need should we process
5 ppm of thorium-230.

The value for thorium-230 in‘Tsble 1, Column 1, of Appendix 0524

is 2 x 107!2 yo/ml for air. values for thorium-232 and thorium (netural)
are 3x1071] yc/mL Considering the total energy per disintegration, thorium-
230-is a far.:less: health problem.than is-natural thorium or thorium-232. For.
this resson the provisional statement given in the ICRP and NCRP publications,
from which the numbers in the Manual Chapters were taken, should have included
thorium-230. We request that for the purpose of our operations we be permitted
to use the 3 x 10°!2 .c/ml for ali thorium isotopes. ;
We would expect to measure the airborne concentration of thorium from any of
our thorium cperations in the usual manner. That is, air dust samples would
be collected and counted for alpha activity, and weighted exposure evaluations
would be made from the results. Our National Lead Company of Ohio Concen-
tration Guide (NCG) of 100 d/m/m3 would spply. :

Sincerely yours,
Origins! Signed By
d. BR. NOYES 7
Maseger
. J. HK. Noyes
RCH/mb Manager ==

cc: C. L. Karl
c R. Chapman
S. Marshall
a A. Quiglew, BLD.

—-


* COMMENTS ON DRAFT REPORT OF HEALTH PHYSICS APPRAISAL, OCTOBER 7-10, :98¢
. 3. J. Davis end K. Shank
November 24, 1980

Some of the things observed, such ss failure to use protective equipment,
are not in any vay excusable. There is now and will be « concerted
effort to change these things. I would like to point out that smoking
in areas exposed to radioactive material has been allowed. Perhaps

most plants would prohibit this as poor practice. In our case it was

2 considered judgeent that it caused very little exposure and improved
the efficienty of the work force. Similerly, it was our judgment that
routine monitoring of work clothing after laundering produced lictle
penefit for the required expenditure.

Regarding recommendation 80-6 pertaining to film badge calibration, che

impact of scacter vas investigated many years £60. The error introduced
ion is y susil, much less than

ic was done

is not an oversight or failure.
This generally covers the exceptions ve might take to the report. I -
realize it msy make 00 difference in the report as you put ic in final
form. We realize ve have quite a bit to do to get the progres uP to
expected standards. We are uaking progress and expect te continue
progressing at & faster rate over the next several months.

Thanks for the opportunity to comment.

te 4
a et OT
weece itive

R. C, Reatherton

RCE/fb |

ce: N. R. Leist

O1teazs


to radioactive dust and fumes and also

Further Affiant Sayeth Naught.

State of Ohio }
County of Hamilton) SS

sworn to me and subscribed in my presence this second day of

February 1993.

JANE A, WALKER
Notary Pass. oF Otis.
By Conmranssisn Exrtes angest 4, 2885



Department. Mr. Leist was the Director of the Technical

Services Group, which controlled the Quality Assurance/Control
Department under NLO, Inc. Even though Mr. Leist agreed with the
bulk of the ny recommendations, he chose to reject the corrective
action suggested for the problem of water samples intermixing,
and he "doubted" that any samples were brought in frozen.
Extensive follow-up on this audit was not performed.

The second audit I would like to focus on was performed from
December 26, 1984 through April 9, 1985, and involved the water
plant laboratory Procedures, which included all the tests -
performed on water from different sources throughout the Fernald
site. The report is dated April 30, 1985 and it is numbered
Quality Assurance Report No. 4.03.

Some of the water sources that are tested include production
wells, drinking fountains, storm sewer, general sump, sewage
treatment plant, chemical waste pits, test wells throughout the
site, Great Miami River water, Paddy's Run Creek water and other
sources. The objective of the audit was to evaluate the
operation of the Water Plant Laboratory and verify that current.
operations are “in compliance with autherized operating
procedures,

During the audit I found several non-compliances. The
measurements of chemicals used for testing samples were -
inconsistent with the measurements listed in the operating
procedure. Several tests listed in the Procedure were not 1
performed at all, and several tests that were performed were not
listed in the procedure. information on what chemicals were to
be mixed together to perform many of the tests were also not,

-17-

3128797


a

040628

CENTRAL FILES

- June 4, 195d
ZHAR DEPARTMENT MONTHLY REPORT FOR MAY, 1958
Ts As Quigiey, M. D. ~
3. W. NoKelvey for R. H. Sterkey 2118215

Air Hygiene Studi.

The routine complete air dust evaluation for Plant 5
production personnel in being prepared in finel form.
The routine complete air dust evaluation for Plant 6
production personnel has been started. Preparations
have been made to begin the routine couplete sir dust
evaluation for Plant 8 production personnei. This
survey will be conducted simultaneously with the Plant 6
survey.

Individual air dust evaluations of operations and equipment
in Plant 9 were begun during this period. The collection

of samples is approximately SOs cowpiete. As the gampling

of individual areas or complete operations is completed,

a report covering that portion will be written and
distributed... A: complete routine.air dust evaluation. of

Plant 9 is planned to be undertaken in approximately

six months, Suggestions for respiratory protection for
personnel inveived in some operations in Plant 9 were

made to Plant 9 supervisory personnel. These suggestions
were based on visual observations snd sample resuits obtained
at similar operations. It was recommended that wherever
possible these suggestions be incorporated iato the

temporary ‘operating procedures until such time as these
individual evaluations are completed or indicate it to te
unnecessary. These major areas include the UF, reduction
area, derby reduction area and operations associated with
this area, machining area, sump area, chip crusher, and
degreasing operations. .

Re-evaluation of UAP Furnace Drumming Station, Plant & -
he report has been written and distributed. The breathing
zone air dust levels were found to be 16 times the Mac. It
was recommended that good drums and rings te used and that
the sccop sampling be done inside the existing ventilated
enclosure.



040520

BER DEPARTNENT NONINLY REPORT RR RE, 1959 tess
J. 4. Quighey, 3.5. .
July 2, 1959 °

2. APD, whole-body (zarmm) - $17 aren/no.
a, Persons receiving APD or greater - 1
&. Distritution: Yhoriun +

warehouse = 1,

3. **PD, Skin (beta pivs gammz) - 2,500 nren/mo.
a, Persons receiving MPD oz qreater ~ 14
tb. Distritution: Plant 5 + 12, Plant 6-1, biant 9~ 1.
c. Highest sxin dost - $,690 aren ~ Plant 5

_&
<Mole-body (gamma) - 1,250-czem/no.
zsons receiving Nyy - 0
Highest whole-body dose - 450 ntem - Thorium ‘azei

4. MPD.

zouse

*9ED - Average Fermissitle Zose ~ Monthly fraction of aversr
lifetine occupational (A3C Manual Chapter 0524)
artinun Fernissitle bose - Monthly fraction of nasi
(aG0 Manual Chapter 6324)

PD -

Ground Contamination Survey

fhe weoustion Miata fi is continuing,

‘ne line supervisors are all cooperative to the extent of correctint
tnesixatle conditions as they are brought te their attention. “here e=-
still 2 number of undesirable conditions existing, such as the mejor
tacklog of turnings in the east side of Pant 6 and a number of
drums on the storage pad. Uowever, definite progress is be.
-considering. the. entire plant, and it is thought that this inr
will start reflecting in the lower sfflant contanination, 4 fc
nore serious spills Guring the month ace as follow: trails:
betneen Plant © and the waste pit continue, overloading of +!

tesults in occasional spills of trailer cake along the roadway.
these spills are cleaned up immediately upon notification Lyn
this departnent, definite steps should te taken to prevent t-t5
the first place.

able quantity (approximately; 50 lbs) of
ibe SEeSOTt in a netal container sent from the Filot viant
Shop for alterations before installing in Plant 6. ‘rhis material
flushed onto the floor and pad at the jeldirs Shop anc some
before revealed the maturc of tee
inder wes then shoveled up and delivezce to ‘dant $
tot Plant supervision was consulted end agreed that th
pave been cleaned first, then sent to the Decontaninst on

A major release of liquid UNI occurred at Plent 3 on Ju
S00 galions Blaeins | ont onto the pad and ground te

See paren steis coveraa wal eins ccenurre
the night of June 22 and the day of June 23. On June 24, © senple cf

: . PETY5 39



WESTINGHOUSE

When Westinghouse took over operations at Fernald on January
1, 1986, organizational changes occurred site-wide. - The line
was, "Forget what has gone on in the past. It's a whole new bal2
game." I first realized the meaning of this when on
January 6 I was told by Mr. Grumski, the Westinghouse Quality
Assurance/quality Control Manager not to yverforn any mere audits,
because there was “nothing to audit en a CA basis.” What was
meant was that there was no QA program onsite to date. However,
I felt that they should at least follow up on Previous
audit responses. Mr. Grumski and Mr. Weicheld (my immediate
supervisor) told me and mr. Weissenberg to write an audit evalua-
tion of each previous audit over the last ‘year (1985) and
identify the deficiencies, especially those outstanding. I
was told that these evaluations would be presented at the
January monthly QA meeting. ‘This was not done. Nor were they
presented in February or March. yet there were many outstanding
deficiencies.

-I. expected better communications and attitudes to improve
throughout the site with Westinghouse, and to some
extent it was better. Westinghouse promised that Quality Assur-
ance would be a high Priority. But, when it came to specific
projects, Production had total control. I concluded that
Westinghouse was adept at saying the right things, but when ity
counted, it was "business as usual." .

Mr. Grumski gave Mr. Weicholid the assignment, in February
1986, of deciding who should be responsible on Fernald site fer

-1ig9-

31287993


2: zeduction Buildings. On some of the audits that I Performed, =

was not allowed to undertake follow-ups, or I was restricted to
leoking at a limited area of plant operations. for -instance, in

my audit of the scales used at Fernald, which are important for
Smart of the scaies

measuring materials and discovering discrepancies; I was

restricted to auditing Plant 5 scales only, where I found a

yidespread breakdown in compliance with procedures.

. Another example is in my audit of hoists and cranes used a+

Fez.

mg widespread discrezancies in

@, where, after £2:

compliance with procedures in Plant S, I was restricted from

performing other hoists and cranes audits throughout the

facility. (Summary of audit findings will be discussed later.)
My department was the only department that audited

procedures at Fernald. My immediate supervisor was Mr. Weichold,

whose job title was Chief Methods Analyst, and our

department head was Mr. Tippenhaver, who was the Quality
Assurance/Quality Control Head under NLO, Inc.. With me was Ms.
Tilney, a Technical Assistant. Operations told Mr. Tippenhauer

what to audit and when..
Physically, there was very little to work with in our
department. There were not enough desks, no bulletin boards, no

filing racks, no Procedure filing system, and no basic listing of

current procedures, among other problems.

I stated that from the beginning I was uncomfortable with

the audit arrangement. Occasionally, I would perform an audit on

ay own which resulted in complaints from productien, and in turn
pressure from Mr. Tippenhauer, the head of the department, to

alter, or even step the audit en:

izely. After nine months, ay

-5-

3128785


by Shy”
pads m
€Battelle

Pace Northwest Laburatones
PO Boag — KRH 012-85

Richland Washington 1 SA 99352

February 28, 1985 Telephone 30% 375-2819
Telex 15-2074

Robert W. Barber :

Acting Director

Office of Nuclear Safety (PE-22)
U.S. Department of Energy
Washington, B.C. 20545

Dear Mr. Barber:

Attached are findings, observations and recommendations covering recent site
visits to the Portsmouth Geseous Diffusion Plant in Piketon, Ohio and NLO Feed
Material Production Center in Fernald, Ohio. On these visits I was requested
to accompany Joe Fitzgerald to provide technical support and consultation,
especially focusing on the internal dosimetry aspects.

As an aside I feel I should relay one other comment even though it was outside
the scope of my assignment. In discussion with the NLO staff at the Fernald
Plant it was suggested that they had been receiving mixed signals from DOE in
their recent appraisals. The fact that they had received several “Tow”
appraisais in the area of Health and Safety while at the same time receiving
relatively “high” marks in their overall appraisal suggested that the DOE
emphasis may be on production rather than additional refinements of radiation
protection for the worker. .

Should you have any comments or questions on the attached report feel free to
call me on (509) 375-2819.

Very mele .
ee A

K. Heid

Staff Scientist

Health Physics Technology Section
RADIOLOGICAL SCIENCES DEPARTMENT

KRH:mae

Enclosure

cc: JE Fitzgerald .
BL Murphy

JM Selby
EJ Vallario =

tee

PESO7T


an .
f September 11, 1981
@ NLO, ING.

RESPONSE TO
DOSIMETRY ASSESSMENT FACT SHEET

I. History of “Hazards” to Assess Overail Monitoring Program

A. The primary radiation hazards at the FMPC have always been
from uranium. Uranium of various U content, ranging
from depleted to slightly enriched, has been processed
with the average content being close to normal. Periodi-
cally, small amounts of natural thorium have been processed.

B. There have been no significant radiation hazards that have
not been monitored.

C. External Radiation Monitoring: film badge dosimeters have
always been used to measure whole body penetrating and
skin doses. From 1951 through 1960 the film packet was
Sealed in plastic and placed in a metal case which attached
to the worker's security badge. A portion of the film was
not covered by the metal case and served as a means of
monitoring skin dose. Beginning January, 1961, the ORNL

Badge Meter, Model II was put into service at this site.
@ This dosimeter is described in detail in the report -
ORNL-3126. .

Extremity exposures were monitored with wrist film badges
from 1969 until 1977. From 1977 through the present, TLD's
have been used for this purpose. The TLD's are the
Telydyne teflon impregnated with calcium sulfate type.

‘Internal Radiation Monitoring: ali measurements of internal
(lung) depositions have been made with DOE's mobile body

-~ counter which is operated and maintained by Union Carbide's
Y-12 personnel. The counter has been used at this site from
1968 until the present time.

D. Additional information on our present film badge dosimetry
system is contained in the two attachments.
Il. External Monitoring Data
A. Personnel Monitoring Badges
1. Types of badges used:
Film for whole-body and skin exposure

Filw for extremity exposure (limited program) >
TLD for extremity exposures

2707904 _ 3455935,


7 FRR RRR a vinpeniegp rent o renter arnetied on tenets 8 apd font

:

PLUTONIUM OUT OF SPECIFICATION
The assignment was to develop procedures for processing:
eo "piutonium-out-of-specification" or Poos. The assignment was_

initiated because Fernald had received a shipment of plutoniun-
contaminated ash in 1980, and had processed @ portion of that
plutonium-bearing material in a manner which had jeopardized the

workers' health and safety. A September, 1985 DOE investigation

report of Fernald's handling of plutonium-bearing material in the

Past was highly critical, and serves as background informati
for this incident.
Plutonium-bearing materials containing more than 10 parts

per billion (PPB) require special handling, including the use of
protective equipment, respirators, constant air monitoring,
routine worker exposure analysis and strict adherence to Quality
Assurance/Control procedures. ‘These requirements were

. e@ established by a DOE directive of April 4, 1985, and adopted
internally by NLO in March of 1985. Apparently, previous to this
commitment, NLO had considered that materials containing 20 parts
per billion or more of plutonium required special procedures. In 1982

Fernald haa processed piutonium-pearing materials of up to 7,757

parts per billion (ithout observance to any of these safeguards.
According to the September 1985 DOE investigation entitled, "The

Report of the Joint Task Force on Uranium Recycle Materials
Processing", the Fernald facility:

- Did not keep accountability records of transuranic
and fission products elements it worked with. As such,
"the Task Force could not determine, with confidence, .
the quantity of contaminants that may have been
received and processed at the FMPC. Only best
estimates were available for the reveiw.”

@ on

3128808


shoes and Clothing were strung throughout the corziders
(particularly the west corridor) and even placed on benches that
were used for coffee breaks. A layer of dust also covered the 4
cabinets, shelves, and horizontal surfaces throughout the
building.

in the operation buildings, I found layers of uranium dust;
magnesium fluoride, green salt, orange oxide and uranium saw

cnips covered the floors to a level cf cne-quarter inch thick,

At times, the air was so full of uranium dust I had trouble
breathing, and afterwards, acquired a sore throat. This was
especially true in Production Plants i, 4, 5, and 9. Respirators
and masks were not being worn by personnel.

But the main problem I encountered from Day One was in the
Quality Assurance Department itself. I discovered that there was
no comprehensive audit program in Place. I found that the
department was understaffed; only three audit department
personnel had responsibility for perfcrming literally hundreds of
audits, updating» and revising Procedures, keeping. current with -

“ DOE Orders and performing a variety of other functions. The
audit department had no independence from, and in fact took
orders from, production; under NLO, in particular, the Quality
Assurance Department was at the botton of the organizational
chart, reporting to the Technical Division. I was not allowed to

pursue audits in certain critical areas of plant operations; for

example, I was warned not to undertake any audits of the chemical
a

pits, the K-65 silo area, the dust collector systens in the
Se

Rroducticn areas, and the mechanical Shops located shroughout the

-~g-

3i

28784



e

eo

oS
Ss
2132269 , SS
_ . ’ RS
vr $$
January 22, 1957
Mr. John E, Batley
Sefety Engineer
National Lead Company, Ino.
Konticelio. Utah
ntice’
, Ref Your ltr., 1/17/57
Dear John:
The impression which you hays thet-s urine ® epllected 7
oon ater espocure should give « higher resul than -one- -
colleated after a period susy. from exposure is basically
correct. Many factors however i influense the rate of ,excre= a

tion. Among at important of these are fluid balance
and the diet of the individual. Also involved is the rate

of absorption info the body. _—
The relatively _nonesoluble uranium unda which you deal
with are absorbed rather slowly. TS Eatertal, to a large

goon be renaporteg wp She
lowed: where 1G wit)

Water balance will also be involved, especially wheres an
individual is exposed ta relatively. high temperatures which
will cause perspiration and a rednoed volume of liquid passing
Hera Senate, ts, tae, eee ret

es wiich enhance the release of the uranium
ion from the blood stream,

Commonly, iumediate post~-exposure wrinss ‘ore higher. ‘“e do
mot become concerned, however, when relatively few do-not.
follow this pattern, since it is our practice to reecheck all
high samples -before becoming overly concerned. When repeat
samples ere high, we always have the Industrisi Hygiens group



indication of operating conditions within the Refinery-
Tne chemical cperator group is routinely sampled on @
quarterly basis, with the samples of the group veing
collected over a one-month period. It is recommended
that the samples be collected over the entire quarter,
thereby reducing the possibility thet bigh exposure
situations go unnoticed. Further, NLO stould attempt

to determine the significance of the lerge voidings of
uranium noted in several of the chemical operators. In
this connection, it would be desirable to obtain urine
data on one or more individuals in that group after they
have been removed from further exposure. The practice
of obtaining special urine samples from chemical operators
following operational difficulties or indication of high
uranium content in the urine, should be continued.

Refinery and Recovery Plants

The refinery and recovery plants were toured extensively
to observe opersting conditions. In general, housekeeping

was vi 7, and some operating equipment was in a state
of disr ~" Extensive radioactive materiel contamina

tion was noted in the work aress, presenting hazardous
working environments to the employees. Safety equipment,
such as eye washers, were not, in proper working order. At
least one employee respirator was. found to be contaminated.
Iniet air filters were missing and/or extensively damaged
on st least two air supply wits. Water from eye vashers
vas dusty oY othervise contaminated. Uranium. concentratss.
were puffing out of & screw conveyor systen, creating eir-
orne and surface contamination. Inspection ports and
vessel 1ia9 were not properly secured. The needle of a
scrubber water pressure indicator was broken. off.

These, and other conditions, necessitated a recommendation
that prompt cleamp of the areas be initiated, that safety
devices and operating equipment be kept in proper repair,
and that increased attention be given continued cleanup of
the sreas, especially following abnormal operational eccur=
rences, such as blockage of the screw conveyor system.



sees

Recommendation: The bioassay measurement data collected {both urine and
in-vivo) should be used to estimate intake, dose or in some manner estimate
the severity of the intake and resulting deposition and systemic uptake.

€.2 Observation

A sign on what appeared to be a. shipping container indicated plutonium
bearing material had been processed at the NLO plan probably in the 1980-1982
period.

Finding: In discussion with NLO staff it seems that some special
precautions had been taken (such as workers wearing respiratory protective air
being sampled) during the work. Exposure of the workers to plutonium was
probably minimal; however, there was 10 evidence of clean-up or of subsequent
control to isolate the plutonium.

Comment: Plutonium is e: ly difficult to distinguish from uranium
using portable field survey instruments. About the only way to distinguish
the plutonium is to take smears and count them.

Recommendation: Remove or decontaminate the plutonium contaminated
equipment. Take whatever steps are necessary to ensure all the plutonium
contamination is removed from the work site. If similar material is processed
in the future it should be totally isolated and handled in a manner more
appropriate for plutonium.


SAT 8

again for review. They reluctantly agreed to one more review. =
also pointed out that maintenance personnel would have to be
trained. No one had thought of that. I was amazed that mr.
Macaulay, Operating Training Manager and head of the plutonium
program had not thought about trining maintenance personne2.
Finally, a meeting was held on February 20, 1986. At the
beginning of this meeting, Mr. Macaulay asked, "What does ‘Ms!
stand for?" = was astonished that the head of Westinghcuse
Operations did net know what "MS" stood for when he was in charge
of the project. MS", for the record, stands for Manufacturing
Specification. it is an important term in the realm of Quality
Assurance, because it establishes the criteria for (1) nuclear
safety requirements, (2) nuclear materials control and record
requirements, and (3) raw material, process, and product
specifications. This industry-wide standard is critical. for safe
and efficient operation of instrumentation and equipment. Mr.
Macaulay wanted the procedures signed off the next day. Again I
stated that the HES Procedure would be inadequate to cover all

- operations in-a safe manner that: would ‘protect worker health and

safety. This statement received no reply. I then statea that I
coula not go along with the project, and walked out of the
meeting.

I waited for Mr. Weichold at the exit door after this
meeting, and while we walked back to ‘Laboratory Building, I told
Mz. Weichold that I would do anything he wanted with the '

procedures, but I wasn't geing to sign off on then. Someone else

would have to sign off on the then. There was no reply from Mr.

-31-

3128811


To give the reader an idea of the kind of problems that I
was finding during my audits, it is worthwhile to focus on just
two of my audits briefly. The first audit I would like to focus
on was performed from November 13 to November 30, 1984, and the
subject of the audit. was the operation of the water Plant, which
included water treatment and site-wide responsibilities. The
report is dated January 31, 1985 and it is numbered Quality
Control Audit Report No. 4.02.

The treatment of water at Fernald includes sampling ane
testing, preventing uranium losses to the environment via water
channels, ‘the treatment of water for plant personnel consumption,
sanitary sewage disposal, testing fire pumps, water sampling and
testing from the chemical pits and more. The objective of the
audit was to "evaluate the operation of the Water Plant and
verify that current operations and inspection practices are in
compliance with authorized procedures."

During my audit, I found massive noncompliances. I
identified 14 procedures that should have been referenced in the
Standard Operating ‘Procedure (hereinafter, "SOP") that were not
referenced.’ I’ also foutid incon@istenciés with what the Sop |”

walled for and the actual practice. Several operations listed in

the SOP, which called for routine daily checks by operating
personnel, were not performed either "routinely" or "daily."

The steps for operations in the Chemical Pits failed to
mention how often the prescribed operations are to he perforned,
how often the flow charts are to be changed, and that samples of
the effluent are taken for analysis.

I observed that, contrary to the SOP, Test Well No. 1

-i5-

3128795


JHLR DEPARTMENT MONTHLY REPORT FOR OCTOBER 1969 Page 2
J. A. Quigley, M.D.
November 11, 1969

additional worx and some slight, but umnecessary, radiation exposure
which could have been avoided by thorough communication. More explicit
information on the purchase order would have helped.

Some preliminary investigation of the radiation exposure to the hands of
various operators is being made. Wrist film dosimeters have been worn
by the burnout and mold reconditioning operators in Plant 5. These
dosimeters have not been processed yet.

Measurements of the gloves worn by the burnout operator for 2 full day
showed inside radiation levels of 60 to 100 mr/hr. When the operator
changed gloves after every third crucible the levels were iess than

20 mr/hr. The mold reconditioning operator normally used three pairs
of gloves per shift. Radiation ievels in these gloves were 10 to 25 rar/hr.

Miscellaneous

A lighting survey was performed in the General Purpose Warehouse. As
noted in an earlier survey, the illumination was legs than the recommended
levels for seeing tasks. A follow-up survey will be made to determine
lighting improvement after the existing 200 watt light bulbs are replaced
with 300 watt bulbs in cach ceiling fixture.

This department witnessed a demonstration of an air powered drill in
Plant 5 and found its performance favorable in not creating a dust probler.
An air diffuser is used to control dusting that some other air powered tools
as not have. wee .

We observed a preliminary test to determine if precipitated thorium
fluoride could be dewatered in 2 centrifuge. Thx Plant 9 chip centrifuge
was lined with 2 filter cloth and used in this test. No industrial hygiene
problems were seen if the filtrate, which contains hydrofluoric acid,
can be removed to a vented tans. In the test it leaked to the floor and
caused some eye irritation to the people present.

External Radiation
Durinz September two film. badges received beta and gemma radiation in

excess of the MPD (2500 mrem per month for whole poy skin). The
badges were worn in Plant § by charging operators and had received

_— PETYS eee


2. Dates each type dosimeter used:
Film (whole-body monitoring): since plant start~up

_ - (1951) to date
|) Film (extremity monitoring): 1969 to 1977
TLD (extremity monitoring): 1977 to present

3. Types of measurement:

. Gamma whole-body dose
Beta and gamma skin dose
Bete and gamma extremity (hands and forearm) dose

4. All dosimeter evaluations were “in house" except for
t approximately the first 12 months of operation when
film badges were processed by DOE's Health and Safety
Laboratory, New York, NY (presently called -EML).

5. Wo procedure manual is available.

a. Calibration procedure and frequency. Film badges:
Gamae calibration are performed by exposing hadges
to a radium source at various distances. Beta and
Gamma calibration are obtained by exposing films to
a uranium metal slab for various lengths of time.
Six to eight sets of calibration films are prepared .
at atime. One set is processed each month along- wo
with the films from the personnel dosimeters.

{LD extremity dosimeter: calibration exposures are
made in essentially the same manner as with film
badges by exposing the TLD's to 2 siab of uranium
. e metal. Calibration checks of the entire TLD

system are made each month. The individual TLD's .
are calibrated after every two or three uses.

pb. The radium source used for gamma calibrations was
calibrated at NBS. The uranium metal slabs used for
beta and gamma calibrations have not been calibrated.
The published surface dose rate for aged natural
uranium metal is‘assumed for the ‘metal slabs.

c. For film dosimeters, a calibration curve of film
density versus exposure is prepared from the cali-
bration films. The density of the personnel films
is converted to dose using the calibration curve.
This was done manually at first but is now per-
formed by computer.

d. "Test" dosineters are not routinely processed.
However, five or ten gamma and six or eleven beta
and gamma calibration fiims were processed along
with each batch of personnel films. Also, as
mentioned previously, TLD's are exposed for cali-
bration purposes after every two or three uses.

- an

- 22+

3455936


®)

E. Bailey Page 2
Hational Lead Company, Ins.

investigate. the man's working environment and particularly his
work me’ » since careless operators may recoive high exposures
doing exactly the same work that careful operstors may do without
harm to themaclves. This enables us to educate supervision so
that they may be able to exercise the proper control over their

employees. - .
I am enclosing a report on semples submitted in tho Zatter part
of December. Many of these again ere quite high, and I wo
recommend that diacuss results with your plant manager,
Mr. Brower Del: <y
Sincerely yours, es
ORIGINAL SIGNED BY

_ J.A.QUIGLEY.MD.

. J &. Quigley, M.D. oe
Director of Health & Safaty

gAQ/ab . _

cos Be Dellinger
Dre A. Steyvart
G. W. Wunder
Central Piles —

Encl. .


@

Page 2

leyela noted when conveyors were pulled with inadequate
- We are still not satisfied with this oneration

altBrugh if proper caution is used we feel that the

duét concentration can be lowered to within a safe

permissible level.

2. The blending of magnesium with green salt at Plant &
is being tried. If successfully done this wili
eliminate many operations in Plant 5,

Ove have been
- 9. Lor. week of
his is quite an accomplishment
shave received on the average of
@ -who-have had en overexposure. to

2. On December 16 a flood occurred in Plant 5 due to
the incapacity of the pumps to pump to the cooling
tower, No damage other than inconvenience resulted

from this.

3. A survey is being made to develop means of increasing
the heat in Plant 5. ‘This can possibly be done through
the reduction of outgoing air,

6. Plant 6
i. Plans are in the making to exhaust the oi] fumes from
the ingot pre-heat furnace. This should also lower
the dust concentration to a level below the MAC.

2. The work to improve the lighting in the inspection area
has begun. tes . : :

7. Plant 8
1. The meffle furnace which is used to oxidize green salt
is developing inte a dust problem, It seems the drum
dumper was designed for a 30-galion drum and much of
the scrap green salt is stored in 5-gallion drums.
This- overstion will have to be studied to determine .
ways and means of eliminating the dust.
8. Pilot Plant
1, The 3620 area has been operating satisfactorily.
2. The 3013 personnel are assiting in Plant 2 start-up. ~

3. The 3037 area has been operating satisfactorily.

gzigibbe |


listed in the procedure. No records were kept for the length of
time chemicals were stored to evaluate the stability of the
chemicals.

During the audit 1 observed that samples of sewage treatment
waste were placed in a small, unventilated furnace set -at 600
@egrees Fahrenheit for over an hour. ‘The object of the test was
to determine total dissolved solids. Due to the dense smoke and
strong, offensive cdor that was created, ali Personnel had to
evacuate the laboratory rocm. Later with the coor epen to let
out the smoke, I entered the laboratory room and found smoke

residue on. supposedly sterile equipment. When I informed Mr.

Tippenhauer of my experience, I was told not to include
information in the audit about finding the smoke residue on the
sterile lab equipment.

I was amazed at the widespread ‘deficiencies and "no common
sense" approach during these audits. Since 1952, thé public and
the government has relied upon Fernald's self-regulation of its ©

water sampling and testing for uranium and other contaminants,
but this audit reveals that, at ieast up to he time that
corrective action was taken in "response to my “audit, that such
testing is inherently unreliable. I have also observed that
Westinghouse, in its latest Environmental Monitoring Report,
showcased the water plant laboratories as an example of Fernald's

excellent quality assurance. I had to laugh.

-18 =

3128798