Contamination Control

PORTS had a fairly conservative contamination control policy; however, historical evidence suggests that management expectations for contamination control were often not met in the field. This was particularly true in the buildings with the highest

potential for contamination, such as the main process buildings, the X-344 feed manufacturing plant, and X- 705. Historical health physics records indicate that the control of radioactive contamination was considered a high management priority from the very beginning of Plant operations. A Supervision Safety Letter issued by Goodyear Atomic Corporation in November 1954 describes contamination as a more serious problem than exposure because it involves actual contact with a radioactive substance that can remain on or be deposited internally in the body for long periods of time. Proper contamination control practices for workers were highlighted in the safety letter. Another Supervision

Safety Letter issued in September 1960 points out that

hand counters are provided at strategic places throughout the Plant and are intended for daily use by employees, but health physics reports indicate inconsistent usage.

From the beginning of operations, PORTS had PALs for assessment and control of radioactive contamination. The PALs for contamination were primarily based on fixed and removable alpha contamination levels. There were different limits for floors, hands, clothing, and shoes. Although evidence suggests that contamination control was problematic throughout Plant life, Goodyear Atomic Corporation’s limits were much more conservative than other gaseous diffusion plants, and often an order of magnitude lower than other facilities and regulatory requirements. Thus, areas considered contaminated under the Goodyear Atomic Corporation program might have been considered clean under the Oak Ridge or Paducah radiation protection programs. One reason for the lower contamination thresholds was concern over the higher-assay material at PORTS that would have resulted in higher radioactivity for the same amount of uranium released or spilled. However, the lower limits were frequently exceeded. In the 1950s to the 1970s, personnel “spot checks” indicated many readings above PAL limits.

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

Difficulties in contamination control can likely be attributed to the pervasive nature of uranium discharges from process equipment and lack of sufficient staff and/ or upper management commitment to enforce contamination control guidelines on line management, supervisors, and workers. For example, hand monitoring equipment and radiation detectors were available, but their use was not mandatory or effectively monitored. A number of audits and appraisals conducted over the years highlights the lack of adherence to requirements, procedures, and guidelines such as use of protective clothing, hand monitoring, frisking, and boundary control. Areas of PORTS not believed to have a significant potential for contamination were often overlooked, such as the X- 720 maintenance shops and X-750 garage, which were routinely used to repair potentially contaminated parts and vehicles. Limited health physics survey staffing resulted in low priority and infrequent surveys for these areas.

In the mid-1950s, Goodyear Atomic Corporation evaluated the seriousness of contamination in work areas by calculating a “contamination index” for each surveyed area. The contamination index was a weighted average based on a mathematical formula that considered both the contamination levels encountered and square footage. A three-tiered approach to contamination control was utilized based on the contamination index. Areas were categorized as red, orange, and clean. An index of greater than 75 was designated as a “Red Job Assignment,” calling for company-issued undergarments, coveralls, head covers, and shoe covers or yellow-toe shoes. Showering was also a policy requirement for Red Job Assignments. An index of between 10 and 75 was classified as an “Orange Job Assignment” requiring somewhat less stringent protective clothing (no head covering) and no showering requirement. An index of less than 10 was considered clean for contamination control purposes. Despite these rather formal designations, inspection reports and appraisals indicated that adherence to protective clothing and contamination control requirements was inconsistent and was influenced primarily by the first line supervisor’s philosophies and work ethic.

As early as 1955, permanent Red Job areas included portions of X-705, X-744G, X-342, X-344, and X-746. Classification of other areas was subject to change based on survey results. In some cases, classifications were not performed correctly. In 1980, surveys showed that portions of X-326 met the criteria

for a Red Job area but were not categorized as such. A union grievance was filed and an investigation was performed to review the matter. Other problems with the classification system included the lack of formal restrictions on movement of personnel and equipment in and out of contaminated areas. In 1977, Industrial Hygiene and Health Physics noted that employees wearing contaminated clothing were permitted to enter clean areas such as the cafeteria, and individuals were allowed to eat and smoke in contaminated areas. A change in Goodyear Atomic Corporation standard practice procedure SPP H-8, “Health Protection Measures for Red Orange and Contaminated Job Assignments,” was proposed at that time. In 1979, Goodyear Atomic Corporation established a Contamination Control Steering Committee to review the overall contamination control program at the Plant and make recommendations for implementation of a more effective and uniform policy. Contamination control problems continued to persist into the late 1980s.

Although Goodyear Atomic Corporation management and the Industrial Hygiene and Health Physics Department were concerned about the need to control contamination to levels as low as reasonably achievable (ALARA), contamination control policies and procedures were not fully effective, as evidenced by continuing radiological problem reports and PORTS emphasis on corrective actions that lasted into the 1990s. These deficiencies are likely to have resulted in additional exposures and spread of contamination over the Plant operating history.