The PORTS Industrial Hygiene and Health Physics Department considered personnel exposures to low- enriched uranium compounds to constitute a chemical rather than radiological exposure. However, as discussed, site processes involved both soluble and insoluble forms and were designed to enrich uranium to over 97 percent, which complicated the respiratory protection issues at the site. Not only were the constituents of uranium compounds within the enrichment cycle hazardous (e.g., fluoride and acid compounds), but heavy metal poisoning could result from exposures to significant quantities of uranium. Consequently, respiratory protection programs of the time were instituted to minimize personnel exposures to these contaminants. Early in Plant life, the respiratory protection program principally utilized dust masks (paper masks) to minimize exposure to nuisance
particulates (e.g., dusts and filings), and MSA masks with cartridges and the Army assault mask were used to minimize personnel exposures to chemical and radiological contaminants.
Many work activities at the site resulted in high airborne radioactive material concentrations in the work area. Based upon the results of air samples collected in those areas, Industrial Hygiene and Health Physics personnel routinely recommended using engineered controls (ventilation) or respiratory protection devices for specific tasks with identified high airborne radioactive material concentrations. Unfortunately, the Industrial Hygiene and Health Physics recommendations were made after high airborne radioactive material concentrations had been measured, and evidence indicates that although line management knew of those recommendations, they were not always implemented.
During 1973, the Industrial Hygiene and Health Physics group and Plant management took several initiatives to improve the level of respiratory protection for employees, which were driven by a 1972 safety and health appraisal. Industrial Hygiene and Health Physics developed and Plant management authorized a comprehensive program to upgrade respiratory protection practices at the site. Program elements included Plant surveys to identify respirator need and type; respirator procurement; employee training in respirator use, cleaning, and maintenance; fit testing; and procedure-controlled issuance. Plant management also identified and designated a number of Plant areas, particularly those where process gas might be present, as requiring respiratory use. These actions resulted, at least in part, from continuing problems with puffs. During this effort, 350 full-face and 150 half-face air purifying respirators (APRs) and air-supplied hood were purchased and placed into service. Purchased equipment was state-of-the-art for the period. However, deficiencies continued to occur, and it was not until 1982, during an OR assessment, that programmatic corrective actions were initiated for respiratory protection program deficiencies. The OR assessment resulted in a number of corrective actions designed to improve the program and implementation, including establishing a new respiratory fit testing facility in 1985; refitting and retraining all employees; developing a respiratory protection audit program; and reviewing and revising Goodyear Atomic Corporation procedures to include information required by the ANSI standard for respiratory protection.
Puffs, minor releases of UF6 from process gas equipment, were a common occurrence despite efforts
to minimize the amount of material available for release. Frequently, solid UF6 deposits became isolated from the process gas stream in closed-end volumes, such as instrument lines, that developed blockage. Records from the 1960s and 1970s indicate that in some cases, puffs occurred numerous times per week. Evidence indicates that during this period, operators did not typically wear respirators while sampling cascade process gas, despite frequent puffs of UF6. Puffs were also frequently experienced in product feed and withdrawal areas when UF6 cylinder pigtails were disconnected. Although Plant procedures specifically required respirator use during these evolutions, they were not typically worn. This procedural violation repeatedly resulted in the development and issuance of radiological occurrence reports to document the adverse condition, but corrective actions were not effective. Interviews with process operators indicated the belief that the uranium materials at the site were relatively harmless, resulting in unwillingness to use appropriate personal protective equipment.
The Industrial Hygiene and Health Physics group always recommended the use of respiratory protection devices in areas with high potential for airborne and/ or chemical contaminants. Records indicate that the Industrial Hygiene and Health Physics group routinely interacted with operations and maintenance management and workers to advise them on the use of respiratory protection equipment and provide counsel on the types of work that would normally require respiratory protection. However, records also indicate that despite the Industrial Hygiene and Health Physics group’s concern with personnel protection, that group did not have the authority to direct the use of respiratory protection. Consequently, respiratory protection was
not always utilized when high levels of airborne contaminants were present. For example, during 1972, Industrial Hygiene and Health Physics personnel assigned to X-705 reported approximately 300 radiological occurrences related to elevated airborne conditions in the oxide conversion facility. The reports indicate that as few as two and as many as 30 high airborne radioactive samples were identified during each incident, and in one case, a continuous air monitor alarm was ignored. Additionally, the reports indicated that respiratory protection was not used on many jobs for which the use of that equipment was specifically required by procedure, resulting in many special bioassay requests. Former-worker interviews and records indicated that failure to wear appropriate respiratory equipment was pervasive throughout the Plant.
Both Industrial Hygiene and Health Physics and Plant management recognized the hazards associated with contamination from transuranic compounds, and actions were taken to limit receipt of those contaminants. Although records indicate that the oxide conversion facility and some cascade deposits contained significant levels of transuranics, PORTS considered technetium-99 to be more pervasive, and respiratory protection program recommendations were subsequently based upon transferable beta contamination levels in work areas. However, work was routinely conducted without the benefit of respirators on open cascade components in process buildings, maintenance, refurbishment work, and waste handling activities. Extrapolation of analytical data would have indicated that these areas could have contained transuranic compounds. Until the early 1990s, uranium and technetium compounds were the only radiological hazards mentioned in respiratory protection guidance, even though the Plant was aware that some transuranic contaminants existed in the recycled uranium being processed at the site.
Since the beginning of Plant operation, there were significant deficiencies in respiratory program implementation. The early lack of line management support for the program directly impacted the Industrial Hygiene and Health Physics group’s ability to establish controls consistent with the hazards encountered by workers at PORTS. Worker acceptance of the respiratory protection program was hampered by lack of supervisory encouragement/enforcement, inadequate training regarding the hazards, and poor equipment fit, comfort, and visibility. In addition, there was a belief that uranium was relatively harmless and could even be ingested without ill effect. Because of
these issues, unnecessary worker exposures to airborne radioactive materials occurred through PORTS history.