ML20150E157
| ML20150E157 | |
| Person / Time | |
|---|---|
| Issue date: | 02/29/1988 |
| From: | Steven Baggett, Costello F, Friedman L, John Pelchat NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150E150 | List: |
| References | |
| REF-QA-99990001-880310 99990001-88-01, 99990001-88-1, SE397, NUDOCS 8803300021 | |
| Download: ML20150E157 (14) | |
Text
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e U.S. NUCLEAR REGULATORY COMMISSION REGION I AUGMENTED INSPECTION TEAM REPORT Report No. 88-01 Docket No.
99990001 General Licensee:
Ashland Chemical Company Easton, Pennsylvania Inspection At:
Easton, Pennsylvania Inspection Conducted: January 23, 19S8 - February 1, 1988 Augmented Inspection Team (AIT) Members:
hl Nt1M9 F. tostello,,4enior Realth, Physicist dat
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/ dat'e Additional inspection assistance was provjded.by NRC inspectors J. Miller, T. Thompson,D.LangeandC.Sispo, j(
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dite Nucleir Materials Safety Section C (AIT Leader) sso33 coo 21 880310 REG 1 QA999 EMVASHCC 999900001 DCD
Table of Contents A.
EXECUTIVE
SUMMARY
B.
INSPECTION DETAILS 1.
Persons Contacted 2.
Notification of Event 3.
Augmented Inspection Team Assignment 4.
Description of Plant Operations 5.
Background on 3M Model 908 Ionizing Air Nozzles 6.
Chronology of Events 7.
Surveys by Augmented Inspection Team 8.
Bioassays 9.
Ashland Chemical Company's Decontamination Plan and Activities 10.
Exit Interview C.
APPENDICES 1.
Preliminary Natifications Regarding Contamination at Ashland Chemical Company's Easton, Pennsylvania Facility 2.
Confirmatory Action Letters to Ashland Chemical Company and Associated Correspondence 3.
Charter of the Augmented Inspection Team 4.
Ashland Chemical Company Easton, Pennsylvania Plant Layout 5.
Processes arid Products at Ashland Chemical Company Easton, Pennsylvania Facility 6.
Evaluation of Compressed Air Systems 7.
Organization of Ashland Chemical Company 8.
3M Static Elimination Registration Sheet for 783 Series 9.
Cross-Sectional Views of 3M Model 908 Ionizing Air Nozzle and Design of Polonium Microspheres 10.
3M Brand Nuclear Static Eliminators General Instruction Sheet 11.
Chronology Details 12.
IBM Survey of Ashland Chemical Company Easton, Pennsylvania Facility 13.
Initial AIT Survey Results at Ashland Chemical Company 14.
Ashland Chemical Company's Decontamination Plan 15.
Ashland Chemical Company's Urinalysis Results and Idaho Data from Idaho National Engineering Laboratory i
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A.
Executive Summary Ashland Chemical Company (Ashland) operates a chemical packaging facility in Easton, Pennsylvania.
The facility leases several (about 20) static eliminating devices, i.e., Model 908 ionizing air nozzles, from Minnesota Mining and Manufacturing Company (3M).
The Model 908 device uses 10 millicuries of Po-210 per unit.
The Po-210, a radioactive alpha emitter, produces ionization of the compressed air that flows through the device, and consequently reduces static electrical buildup in processes at which the compressed air is directed. Ashland's receipt, possession, and use of such devices was in accord with the general licensing specification of 10 CFR 31.5, "Certain measuring, gauging or controlling devices."
On January 22, 1988, NRC Region I received notification from representatives of Ashland that significant alpha contamination, as high as 600,000 dpm per 2
100 cm, had been detected in the company's Easton facility; and that the expected source was one or more of the 3M Model 908 ionizing air nozzles.used in the chemical packaging process.
In response, NRC Region I dispatched two inspectors to characterize the extent of contamination that same date.
From these inspectors, it was learned that (1) the facility was extensively contaminated with Po-210, (2) there was a potential that workers had been exposed to the contamination, (3) the licensee had terminated all operations due to this event, (4) a health physics contractor had been obtained to characterize the extent of contamination and effect decontamination, and (5) the licensee was taking action to contain and prevent further release of the contamination.
Consequently on January 22, 1937, the Regional Administrator, NRC Region I directed a five-member Augmented Inspection Team ( AIT) to conduct a timely, thorough and systematic inspection of the event to assess the licensee's actions; assess the safety significance; collect, analyze, and document all relevant data; and determine, to the extent possible, the cause or causes of this event.
The following summarizes the findings of the AIT:
1.
Radioactive contamination due to Po-210 had been spread extensively throughout Ashland's Easton facility.
The contamination levels 2 to 560,000 dpm/100 cm2 in general creas ranged f rom 1000 dpm/100 c n of the facility.
The highest contamination levels were found by the licensee's health physics consultant in the vicinity of the Cozzoli 2
bottle washer, i.e., ~1,000,000 - 10,000,000 dpm/100 cm,
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2.
The contamination appeared to have the characteristics of particulate matter.
While contamination was extensive, it was discreetly located as opposed to being generally spread.
It appeared evident from the surveys that the contamination was spread by personnel traffic from areas of high concentration, such as the Cozzoli bottle washer and other locations where the Model 908 ionizing air nozzles were used.
While some parts of the Cozzoli washer required the application of specialized decontamination techniques, in most cases observed the contamination was easily removec by normal cleaning methods.
Such characteristics tend to indicate that the contamination was princi-pally caused by ejected microspheres or fragments of microspheres used in the construction of the nuclear source.
3.
The removable contamination found on individual nozzles ranged from about 600 to 5,000 dpm, an activity range less than the reporting level specified in 10 CFR 31.5, i.e., 11,000 dpm (0.005 microcuries).
This finding tends to indicate that, while the nozzles were the source of the radioactivity, nozzle contamination may not be a reliable singular indicator of the significance of leakage or loss of source integrity.
4.
The licensee took immediate actions to contain the contamination, prevent further personnel exposure, and initiate comprehensive surveys of the f acility to characterize the extent of contamination and effect decontamination.
5.
Ashland employees who were potentially exposed to the contamination were subjected to bioassay sampling, i.e.,
urine and fecal analysis for Po-210.
Polonium-210 was not found in the urine of any Ashland employee at the Easton facility in excess of a minimum detectable activity of 2.2 picocuries/ liter.
Confirmatory measurements made by the NRC are still being evaluated, but preliminary results generally confirm the licensee's analyses.
However, two of the seventy-two samples were measured to be in the range between 613 and 823 picocuries/
liter.
The significance of these measurements will be evaluated.
These results tend to indicate that if employees had been exposed to the Po-E10 contamination, such radioactivity was not likely in a soluble form which would result in any significant uptake in the body.
No health effects are expected based on the samples analyzed.
Fecal samples remain to be evaluated.
6.
While it was not possible to precisely identify how many of the installed Model 903 ionizing air nozzles failed, radiological measurements suggest that at least 12 of the 14 r.ozzles that were installed on the Cozzoli bottle washer leaked Po-210 in such quantities to cause radioactive contamination of several plant areas.
The highest concentrations of radioactive contamination found in the Ashland facility were identified in and around the Cozzoli bottle washer.
In this case, the nozzles were subject to operate in a moist environment in which there was spraying warm water and resulting steam.
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While the effects of such conditions on the device are unknown, information fron 3M indicates that solvents, including water, may impair tho integrity of the nuclear source.
However, the presence of a moist environment as a possible causal factor for loss of source integrity is rot conclusive. There was evidence of leakage and area contamination in and around other 3M Model 908 devices that were not subject to ar,y abnormally moist environment.
7.
The compressed air systems used to supply service air to the Model 908 ionizing air nozzles were of normal standard grade.
However, in the case of the compressor system used to support the operation of ionizing air nozzles in the Cozzoli bottle washer, it was found that the system was not well maintained. Air filter elements were found missing ano the desiccant had not been changed since the unit was first installed about 1985.
Desiccant material, principt.lly aluminum silica or oxide, was generally found throughout the system, including downstream of some of the nozzle installations.
8.
Ionizing air nozzles that had been installed at and returned from Ashland's Ea'ston facility were previously identified by 3M to have been leaking in excess of 11,000 dpm (0.005 pCi), at least since April 1987. Quantification of such leakage was not reported to Ashland or to the NRC. While Ashland was informed verbally by 3M of "higher than normal" contamination on some devices about April 1987, Ashland was never provided with any specific information or qualifica-tion of 3M's observation.
9.
The 3M company, as is normal to leasing the devices to their customers, provided certification via the lease agreement, that the environment to which the devices would be exposed was acceptable.
Though such certification was provided by a 3M Static Analyst, it is not apparent that the person making the representation actually visited the facility to initialiy evaluate the environment or application.
A 3M Field Service Engineer had personally observed the use of the Model 908 ionizing air nozzles in the Cozzoli washer on May 29-30, 1987.
No indication was provided to Ashland from that visit that such application and environment was unsuitable for the devices, even though the Static Analyst observed evidence of device leakage at the time.
10.
Since there was a possibility that some chemical product packaged at the Easton facility may have been contaminated with Po-210, a product evaluation was performed prior to releasing the material for continued distribution.
The NRC concurred with Ashland's conclusion, based on product sampling and evaluation, that there was no health and safety risk associated with the continued distribution of chemicals from the Easton facility.
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4 B.
Inspection Details 1.
Persons Contacted The following personnel were contacted either directly or by telephone and provided information to the Augmented Inspection Team.
A.
Ashla d Chemical Company (Ashland), Columbus, Ohio Mr. David J. D' Antoni, Executive Vice President and Chief Operating Officer, Columbus, Ohio Mr. Herbert M. Richardson, Operations Manager. Columbus, Ohio Mr. Darrell S. String, Plant Manager, Easton, Pennsylvania Mr. Donald Warren, Manager, Environmental Health, Columbus, Ohio Mr. Brent McGinnis, Director of Public Relations, Columbus, Ohio Mr. James A. Duquin, Vice President and General Manager of Electronic and Laboratory Products Division, Columbus, Ohio Mr. Donald Coticchia, Group Vice President, Coltabus, Ohio Mr. Lawrence Opthof, Plant Engineer, Easton, Pennsylvania B.
Minnesota Mining and Manufacturing (3M), St. Paul, Minnesota Mr. Robert Wissink, Chairman, Radioisotope Committee St. Paul, Minnesota Mr. David Swenson, Chief Engineer, Static Controls Division, Austia, Texas Mr. Mark Fenner, Public Relations. St. Pau~1, Minnesota Mr. Fred Entwistle, Health Physics, St. Paul, Minnesota Mr. Richard Hughes, Field Service Engineer, Static Controls Division, Austin, Texas Mr. James Marshall, Corporate Attorney, St. Paul, Minnesota C.
Applied Health Physics, Bethel Park, Pennsylvania Mr. Robert Gallagher, President D.
I_nternational Techno'ogy Corporation, Oak Ridge, Tennessee Ms. Betty K. Revsin, Ph.D., Senior Health Physicist Mr. Richard L. Green, Sr., Health Physicist Mr. James Harvey, Laboratory Services Supervisor
5 2.
Notification of Event On January 22, 1983, at about 0900, NRC Region I was informed by a general licensee, Ashland Chemical Company, Division of Ashland Oil, Incorporated, that significant amounts of polonium-210 (Po-210) contamination had been detected in the company's chemical packagirg plant in Easton, Pennsylvania.
The telephone notification was made on behalf of the company by their health physics consultant, Applied Health Physics, Incorporated (AHP).
AHP indicated that the source of the contamination appeared to be static eliminating devices, i.e.,
ionizing air nozzles which use Po-210 to produce air ionization.
In a followup phone call to the initial notification, AHP indicated that contamination as high as 600,000 disintegrations per minute (dpm) had been detected in the vicinity of some of the ionizing air nozzles devices used in the facility. Contamination ranging from 6000 to 8000 dpm was reportedly measured on some clothing used by workers at the plant.
About 30 to 40 plant personnel were reported to have worked in the areas.
which were determined by the licensee's consultant to be contaminated by polonium-210.
Subsequently, all plant operations were shut down, and comprehensive surveys were initiated by the licensee's consultant to determine the extent of the contamination. The licensee's consultant indicated that urine samples would be collected from all affected workers to determine possible uptake of radioactive material by plant personnel.
This event notification was made in accordance with the general license provisions specified in 10 CFR 31.5 and 10 CFR 20.403.
Following the notification, NRC Region I issued Preliminary Notification No. PNO-1-88-11 and followup Preliminary Notification Nos. PNO-I-88-12, PNO-I-88-12A, PNG-I-88-118, and PNO-I-88-11C.
These are included in Appendix 1 to this report.
A Confirmatory Action Letter (CAL) was sent to the licensee which confirmed the licensee's commitment to collect and maintain records relative to the event, cooperate with NRC inspection efforts, and restrict the licensee's facility and products until the NRC provided the authorization for release.
An additional CAL confirmed that the ionizing air nozzles would be sent to Brookhaven National Laboratory for testing and evaluation.
The CAL's and associated correspondence are included in Appendix 2 to this report.
3.
Augmented Inspection Team Assignment In response to the licensee's report, NRC Region I sent an Augmented Inspection Team (AIT) to the licensee's facility.
This team arrived on site on January 23, 1938 and began an investigation of the event, including surveys of the facilities, collection of samples, interviews with personnel, observation of activities, and review of documentation.
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i The assigned objectives of the AIT were to:
a) conduct a timely, thorough, and systematic inspection related to the circumstances surrounding the event; b) assess the public health and safety significance; c) collect and analyze all relevant data pertaining to the event; d) determine, to the extent possible, the causes of the event, The AIT consisted of the following representatives:
John White, Team Leader Frank Costello, Assistant Team Leader Laurence Friedman, Team Member John Pelchat, Team Member Steve Baggett, Team Member Special inspection assistance was provided by the following NRC regional' personnel:
David Lange, Chief, Boiling Water Reactor Section Carl Sisco, Operations Engineer Thomas Thompson, Health Physicist i
John Miller, Health Physicist The charter of the AIT is included in Appendix 3 to this report.
4.
Description of Plant Operations Ashland Chemical Company, a division of Ashland Oil, Incorporated, owns and operates the chemical packaging facility in Easton, Pennsylvania, as part of their Electronic and Laboratory Products Division. The plant layout is depicted in Appendix 4.
This facility predominantly packages chemicals for distribution, and operates both automatic and manual packaging systems for this purpose.
The ionizing air nozzles are used on both the automatic and manual packaging systems, but most of the nozzles i
are installed on a bottle washer / dryer, manufactured by the Cozzoli i
Machine Company, which is part of an automatic packaging system.
Most chemicals packaged are manufactured elsewhere and delivered to the facility in bulk shipments.
Only hydrofluoric acid is manufactured at the Ashland facility.
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As of January 13, 1988, the plant used as many as nineteen 3M Model 908 ionizing air nozzles to support chemical packaging operations.
Fourteen of these units were used in Cozzoli bottle washing apparatus. The remaining units, except one used to support automatic capping of bottles, were used at manual bottle-filling stations.
Further details regarding the processes and products uf the Easton facility are provided in Appendix 5 of this report.
Appendix 6 provides an evaluation of Ashland's plant compressed air systems to which the 3M Model 908 ionizing air nozzles were attached.
Appendix 7 provides the organizational structure of the Ashland Chemical Company which is relevant to the Easton facility.
l S.
Background on 3M Model 908 Ionizing Air Nozzles The Ashland Chemical Company's packaging facility at Easton, Pennsylvania, utilizes Model 908 ionizing air nozzles manufactured by the Minnesota Mining and Manufacturing Company (3M).
The devices are used by the Ashland facility to eliminate-particles from bottles used to contain the chemical products packaged at the plant.
The 3M ionizing air nozzles have been used at the Ashland facility since 1983.
Following annual use, the devices are returned to 3M pursuant to the lease agreement and replaced with new units.
The 3M company is authorized by the NRC under 10 CFR 32.51 to distribute static eliminating devices containing as much as 216 millicuries of Po-210 to persons complying with the general license specifications of 10 CFR 31.5.
Appendix 8 provides the NRC registration sheet for the 3M static eliminator series 7B8 to whicn the 3M Model 908 device belongs.
The 3M Model 908 device uses 10 millicuries of Po-210 per unit.
The 3M Model 908 ionizing air nozzle is designed to use compressed air.
The radioactive source, Po-210, an alpha emitter, is incorporated into microspheres and produces ionized air which is used to reduce static electrical buildup on surfaces, with the consequent elimination of dirt and dust particles. Appendix 9 provides cross-sectional views of the 3M Model 908 ionizing air nozzle and a diagram of a polonium microsphere.
Sources for the 3M static elimination devices are manufactured in New l
Brighton, Minnesota.
The polonium-210 is absorbed onto a zirconium pyrophosphate microsphere having an average diameter of about 35 microns.
The microspheres are sintered to incorporate the Po-210 as part of the ceramic material.
Following, the microspheres are coated with a thin layer of nickel to reduce the possibility of Po-210 leaching from the ceramic. Using a tape transfer method, the microsphere
- are incorporated into a epoxy matrix using 3M Type 2216 epoxy that is intended to be radiation-resistant during the life of the device.
The microspheres have a density of about 3 grams per cubic centimeter.
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8 The manufacturer has provided the NRC information which indicates that broken microspheres or fines do occur in the production of microspheres but that the process is designed to minimize the occurrence.
Additionally, 3M indicated that a microsphere can range in activity from 0.01 microcuries to 0.2 microcuries of polonium-210, but is nominally about 0.1 microcuries.
Microspheres are reported to be chemically inert.
The nozzle device is a hollow brass or stainless steel cylinde~r which is about two inches long and one-half inch in diameter.
The epoxy element with the microspheres is bonded to the inside of the cylinder. An inner nut is installed in the device to restrict air flow and access.
The device is labeled to meet the requirements of 10 CFR 32.51(a)(3).
General instructions to users of 3M static elimination devices, including the 3M Model 908, are included as Appendix 10 of this report.
These instructions warn the user that the integrity of the devices may be compromised by environmental conditions which would subject them to:
a) ambient t'mperatures exceeding 200'F; b) solvents of any kind, including water; c) mineral acids or caustics; d) constant vibration or physical impact; e) flying abrasive matter; f) direct contact with steam.
No special installation requirements are provided except for connecting the device to a source of compressed air.
No operating limitations are specified relative to air pressure, velocity, or other compressed air requirements.
The instructions recommend that the user install a filter prior to the static eliminator to prevent decrease in efficiency due to dust, water or oil droplets coating the nuclear source.
The general licensee is not required to perform leak testing or other maintenance provided that the device is returned to 3M within the 12 month lease period.
The 3M personnel at the Ashland facility examined the ionizing air nozzles 4
at the facility in the presence of AIT members.
The examination included a visual inspection of the interior of each device and a "tap" test.
During this test, a length tape was affixed to each end of the device and the device was struck lightly onto an unyielding surface.
The tape was then removed and surveyed for dislodged radioactive material.
The results of the tap tests it.dicated that most of the devices showed some evidence of failure as indicated by tapped out debris measuring as high as 220,000 dpm.
l To better understand the factors that may have contributed to device failure, all of the units that were found at Ashland's Easton facility, including 12 new and unused nozzles, were sent to Brookhaven National l
Laboratory for examination and testing.
Similarly, 3M is conducting
)
examination of selected units at Battelle Northwest Laboratories.
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i 6.
Chronology of Events i
The Augmented Inspection Team interviewed representatives of Ashland Chemical and 3M to establish a chronology of events associated with the use of ionizing air nozzles at the Easton facility.
The descriptions of these events provided by the representatives from both Ashland and 3M were in essential agreement. The detailed chronology is provided in Appendix 11 to this report.
The following is a summary of the events.
The Ashland Chemical Easton facility received the first three 3M Model 908 ionizing air nozzles in November 1983. The records indicate that a 3M Static Analyst determined that the environmental conditions at the facility would be acceptable for the ionizing air nozzles. A replacement set of ionizing air nozzles has been sent to Ashland Chemical each subsequent November.
The replaced nozzles were returned by Ashland Chemical Company to 3M. Ashland representatives involved with the devices stated that they were never informed by 3M that any of the returned n]zzles had been determined to be leaking.
In March 1985, fourteen additional ionizing air nozzles were shipped by 3M to the Cozzoli Machine Company in Plainfield, New Jersey for installation into Ashland's custom-built bottle-washer.
The machine was delivered to Ashland Chemical in June 1985, tested during that summer, and placed into serviceinSepteqber1935.
In March 1986, a set of ionizing air nozzles, including those frem the Cozzoli bottle-washing machine, were exchanged between Ashland and 3M.
No results of the leak testing of the returned nozzles were provided by 3M following this exchange.
e i
In March 1987, a set of ionizing air nozzles, including those fron the Cozzoli bottle-washing machine, were exchanged between Ashland and 3M.
Following the exchange, a Field Service Engineer from 3M informed Ashland that "higher-than-normal" contamination levels were found on the returned nozzles.
The Field Service Engineer visited the Ashland Chemical Easton facility in May 1987, to inspect the Cozzoli bottle-washing machine.
Reportedly, the 3M representative found radioactive contamination on the machine and on one spot on the floor.
The individual inspected the bottle-i washer device application and the air supply system.
The individual indicated to the AIT that he found no problems with the installation or application of the ionizing air nozzles, but did inform Ashland that some small nozzle end-caps would have to be replaced because they could not be decontaminated.
Since Ashland had spares for these end-caps, the 3M representative removed them and returned with them to his office in Minnesota.
Ashland was not informed of the significance of these findings relative to the integrity of the ionizing air nozzles.
Reportedly, Ashland personnel were led to believe that the natter was of no consequence.
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10 Beginning in August 1987, and continuing through January 1983, representa-tives from International Business Machines, Incorporated (IBM) questioned Ashland about the possibility of radioactive materials in certain of Ashland's products supplied to IBM.
The principal concern was the apparent presence of polonium-210 in sulfuric acid.
The IBM inquiries were focused on products supplied to IBM's manufacturing facility in East Fishkill, New York.
On January 21, 1938, IBM sent a representative to the Ashland's Easton facility to perform radiological surveys.
The representative detected alpha contamination at the facility. A copy of the IBM survey report is provided as Appendix 12.
In response to this finding, Ashland Chemical Company contracted with a consultant, Applied Health Physics (AHP), to supply radiological services.
On January 22, 198S, this consultant notified the NRC of the contamination event on behalf of the Ashland Chemical Company.
7.
Surveys by Augmented Inspection Team The Augmented Inspection Team performed radiological surveys of each of the buildings where radioactive contamination was suspected. Appendix 13 describes the instrumentation used by the AIT and provides the detailed results of these surveys.
Appendix 14 provides the licensee's decontami-nation plan which includes the NRC criteria for contamination in unre-stricted areas.
For polonium-210, the applicable limits for contamination are 1000 dpm per 100 square centimeters removable, 5000 dpm per 100 square centimeters aversged, and 15,000 dpm per 100 square centimeters maximum.
The AIT survey techniques and instrumentation were capable of detecting as low as 300 dpm of alpha contamination per 100 square centimeters.
The following summarizes the results of NRC surveys:
Contamination levels measured by the AIT were in the range 1,000 -
560,000 dpm per 100 square centimeters in many areas of the facility.
Contamination on swabs of nozzles were generally less than the 10 CFR 31.5 reporting limit of 11,000 dpm (.005 microcuries).
Most contamination could be readily removed by applying a piece of adhesive tape to the floor and then removing the tape to pick up the contamination.
No contamination was found near the air exhaust stack on the roof of Building 9.
Low concentration of polonium-210 were found in drain samples and in the facility's discharge to the Lehigh River.
These concentrations were within the applicable NRC limits for liquid discharges of polonium-210 to the environment.
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4 11 Air samples did not indicate any detectable radioactivity attributable to Po-210.
Survey of HEPA filter units in the immediate area of the Cozzoli machine in Building 9 did not indicate the presence of any Po-210 activity.
8.
Bioassays The AIT split urine samples obtained from Ashland's Easton employees with the licensee and sent them to the Idaho National Engineering Laboratory (INEL) for analysis.
Such confirmatory measurements are still being evaluated, but preliminary results generally confirm the licensee's analyses which indicates no detectable activity attributable to Po-210 greater than the minimum detectable activity of 2.2 picocuries/ liter.
However, two of the seventy-two samples analyzed by the Idaho National Engineering Laboratory, on behalf of the NRC, indicated measured activity in the range between 6 3 and 8 3 picocuries/ liter.
The significance of such measurements will be evaluated. Appendix 15 provides the results of the licensee's analyses and NRC's preliminary data as supplied by Idaho National E,gineering Laboratory.
9.
Ashland Chemical Decontamination Activities The licensee, with the assistance of a consultant, International Technology Corporation (ITC) of Oak Ridge, Tennessee, commenced decontamination activities following the characterization of the extent and degree of contamination at the facility.
At the conclusion of the AIT, these activities were being performed in accordance with a plan which was reviewed and approved by the NRC Augmented Inspection Team.
The decontamination plan is included as Appendix 14 to this report.
10.
Exit Interview An e<it interview was conducted by telephone on February 29, 1988 with Mr. James Duquin, Vice President and General Manager of the Electronic and uaboratory Products Division, Ashland Chemical Company.
The findings of this inspection, as detailed in this report, were discussed.
In this discussion Mr. Duquin indicated that analysis of fetal samples from the personnel having the highest potential for uptake had been initiated.
Preliminary results were expected by March 8,1958.
Appendix 1 Preliminary Notifications Regarding Contamination at Ashland Chemical Company's Easton, Pennsylvania Facility a
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DCS No: 999999012288 Date:
January 22, 1988 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-I-88-11 This preliminary notification constitutes EARLY notice of events of POSSIBLE safety l
or public interest significance.
The information is as initially received without verification or evaluation, and is basically all that is known by the Region I staff on this date.
Facility:
Licensee Emergency Classification:
Ashland Chemical Corporation Notification of Unusual Event l
Easton, Pennsylvania Alert General Licensee Site Area Emergency General Emergency X Not Applicable
Subject:
POLONIUM-210 CONTAMINATION OF FACILITIES AND PERSONNEL FROM STATIC l
ELIMINATING DEVICE l
The licensee's radiation consultant notified Region I at about 0900 on January 22, 1988 that it had been determined that polonium-210 contamination as high as 600,000 dpm per smear had been detected at the facility.
The source of the activity was traced I
to one or more Model 908 Ionizing Air Guns manufactured by the 3M Corporation under a specific license; The devices are ieased by Ashland Chemical for drying bottles.
Each device contains 10 millicuries of poloniu.n-210.
Eighteen of the devices are currently on site. All have been removed from service.
Contamination, 6000 to 8000 dpm, has been found on some clothing that is used by workers at the plant.
Affected creas in the plant and equipment have been isolated.
CONTACT: J (346-5102) er (346-5251) g DISTRIBUTION:
H. St.
MNSB Phillips E/W Willste_
Mail: ADM:DMB Chairman Zech EDO NRR NMSS DOT:Trans only Comm. Roberts PA OIA RES Comm. Bernthal OGC AE00 NRC Ops Crt Comm. Carr Comm. Rogers ACRS Air Rights INPD----
SECY SP NSAC----
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Region I Form 83 (Rev. August 1987) gfG
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i 005 No:
999999012288 Date:
January 22, 1988 PRELIMINARY NOTIFICATION OF EVENT OR UNUSVAL OCCURRENCE--PNO-I-88-11 J
Due to the natare of the predominant radiation associated with polonium-210, i.e.
alpha, internal deposition of the isotope is the major radiological health and safety factor associated with this event. The licensee's health physics consultant has initiated urine sampling in an effort to characterize the extent of contamination to 4
1 workers, and ts performing surveys to determine the extent of facility contamination.
I The problem was first detected by a representative of the IBM Corporation on i January 21, 1988, who was inspecting the facility in an effort to determine the cause of alpha contaminatioti in chemicals that IBM uses for micro-chip production.
! Two health physicists from the regional office have been dispatched to the site. NRC
! Region III, NRC Headquarters, and the Commonwealth of Pennsylvania have been informed of this event. The Region I Public Affairs Officers is prepared to respond to media inquiries.
The licensee intends to issue a press release.
The HQ Duty Officer has i been informed.
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DCS No: 999999012233 Date:
January 25, 1988 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-I-88-12 This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance.
The information is as initially received without verification or evaluation, and is basically all that is known by the Region I staff on this date.
Facility:
Licensee Emergency Classification:
Ashland Chemical Corporation Notification of Unusual Event Easton, Pennsylvania Alert General Licensee Site Area Emergency General Emergency X
Not Applicable
Subject:
POLONIUM-210 CONTAMINATION OF FACILITIES AND PERSONNEL FROM STATIC ELIMINATING DEVICE On January 22, 1983, Ashland Chemical Company, Easton, Pa., reported to Region I that one or more of its ionizing air guns held under a general license had apparently become defective, allowing polonium-210 (Po-210) contamination to be spread to areas of the Easton plant and to workers' clothing. The ionizing air gun devices were manufactured by 3M Corp.,
St. Paul, Mn, Two inspectors dispatched to the Easton site confirmed the presence of contamination.
On January 23, an Augmented Inspection Team (AIT) comprised of Region I and NMSS representatives began an inspection into the cause of the incident, the extent of contamination and the potential health and safety impact on workers and the public. ACC and its health physics consultant, Applied Health Physics (APH), distributed sample bottles to first (day) and second (evening) shift workers on January 22, and directed that 24-hour urine samples be collected throughout the weekend and returned to the site on Monday, January 25.
These samples will be split with NRC for analysis. All plant operations were shut down to permit characterization of the extent of the contamination and initiation of cleanup operations.
Thus far, no evidence of contamination of f the site has been identified as of the evening of January 24.
Preliminary radiation /contaminatio surveys of the buildings and grounds of the Easton facility indicate that the contamination is limited to three large production buildings where the ionizing units are used to neutralize stitic electricity on product containers and to remove dust.
Preliminary information accumulated to date indicates that the microspheres on which the Po-210 is adsorbed have ccme loose from the epoxy base that holds them to an interior
>.m l
i i
PNd-I-8812 2
S l
~
surface of tne pressurized air guns. The particles, about 35 microns in dianeter, apparently settle out of the air stream and based on air samples r
taken by Region I, do not constitute an airborne problem at the present time.
The manufacturer, 3M, reports that the microspheres are very insoluble and, if i
ingested, would move through the intestinal tract and be excreted from the body. Analysis of the urine specimens cbtained from the workers should indi-l cate whether this conclusion is valid, since the presence of polonium in the l
urine would indicate that the ingested material was or has become soluble. Any potential health impact woulc ce minimi:ed if any ingested material was and remained insoluble.
During the weekend, ACC determined that ioni:er units of the same type (3M model no. 908) were installed at its facility in Dallas, Texas. APH repre-sentatives were flown to Dallas, where they determined th'it similar contamination existed. The Texas Bureau of Radiation Control (BRC) reportedly dispatched an inspector to that facility on January 24 to monitor containment and cleanup activities at that location.
Region IV and State, local and Indian Tribe Programs are maintaining contact with the Texas BRC. ACC also 2
reported that model 903 ionizer units are in use at its facility in Newark, CA, and at a pilot facility in Columbus, OH, but checks of those units revealed no evidence of centamination.
i The 3M Company is cooprating with ACC and a three person team, including a l
recogni:ed expert in ioni:er devices, has been at the Easton site since the morning of January 23. A management team from ACC corporate headquarters also I
arrived on site the morning of January 23 to direct radiation control and cleanu;4 activities. Region III has maintained a dialogue with 3M relative to e
the production and distribution of ioni:er devices ano cispatcheo inspectcrs ta i
the New Brighton, MN plant where the devices are meufactured.
Since tre cause of the failure of the devices has not been determined, and because of the widespread use of the devices (3M reports about 3,000 customers in the U.S., with at least 20,000 units in use), the NRC issued an Order to 3M
[
on January 25, suspending the license under which the model 908 and similar i
devices are distributed.
The Order also requires 3M to inform any customer to
}
i who specified models of the device have been distributed of the incidents described above and any information on possible causes of the leakage of f
Po-210, to instruct such users of the devices to inform 3M of any suspected failures of the devices, and to call to the attention of the users the requirements of 10 CFR 31.5(c)(5) (i.e., suspend use of the device if removable contamination of 0.005 microcuries is icentified).
The Order also l
requires 3M to irf:,rm NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any device failures that are reported, to institute a testing crogram to idertify the scope of the device f ailure probleen and to provide to NRC within 14 days a plan for identifying any l
additional failed devices.
An analysis of causes of device failures is also l
required.
1
PM0-I-88-12 3
l ACC issued two press releases between January 22 and 24, and the NRC has responded to numerous media inquiries.
The Com.monwealth of Pennsylvania and the States of Texas and Minnesota have been informed of the incident.
This information is current as of 11:00 a.m., January 25, 1933.
i
)
i CONTACT:
J. White (346-5102)
J. Joyner (346-5251)
DISTRIBUTION:
H. St. __
MNBB Phillips E/W Willste Mail:
ACM:0M3 Chairman Zech EDO NRR NMSS DOT:Trans only Comm. Roberts PA OIA RES Comm. Berntnal OGC AE00 NRC Ops Crt Comm. Carr j
Comm. Rogers ACRS Air Rights INPO----
SECY SP NSAC----
CA PCR Regional Offices TMI Resident Section RI Ratident Offd:e Licensee:
(Reactor Licensees)
)
Region I Form 83 (Rev. August 1987) l
}
DCS No:
999999012288 Date:
January 25, 1983 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-I-88-12A This preliminary notification constitutes EARLY notice of events of POSSIBLC safety or public interest significance.
The information is as initially received without verification or evaluation, and is basically all that is known by the Region I stafr on this date.
Facility:
Licensee Emergency Classification:
~
~~
Ashland Chemical Company Notification of Unusual Event Easton, Pennsylvania Alert General Licensee Site Area Emergency General Emergency X
Not Applicable
Subject:
POLONIUM-210 CONTAMINATION OF FACILITIES AND PERSONNEL FROM STATIC ELIMINATING DEVICE - (UPDATE)
On January 22, 1988, Ashland Chemical Company (ACC), Easta h., reported to Region I that one or more of its ionizing air guns held ut.;
general license had apparently becomo defective, allowing polonium-210 (Po-210) contamination to be spread to areas of the Easton plant and to workers' clothing.
The ionizing air gun devices were manufactured by 3M Company, St. Paul, Mn, Two inspectors dispatched to the Easton site confirmed the presence of contamination.
On January 23, an Augmented Inspection Team (AIT) comprised of Region I and NMSS representatives began an inspection into the cause of the incident, the extent of contamination and the potential health and safety impact on workers and the public. ACC and its health physics consultant, Applied Health Physics (APH), distributed sample bottles to first (day) and second (evening) shift workers on January 22, and directed that 24-t.our urine samples be collected throughout the weekend and returned to the site on Monday, January 25.
These samples will be split with NRC for analysis. All plant operations were shut down to permit characterization of the extent of the contamination and initiation of cleanup operations.
As of the evening of January 24, no evidence of contamination of f the site had been identified.
Preliminary radiation / contamination surveys of the buildings and grounds of the Easton facility incicate tnat the
- -t:mir.aticn involves at least three large production buildings where the ionizing units are used to neutralize static electricity on product containers and to remove dust.
Preliminary information accumulated to date indicates that the microspheres on which the Po-210 is adsorbed have come loose from the epoxy base that holds them to an
i b
PN I-88 12A 2
i interior surface of the pressurized air guns.
The particles, about 35 microns i
in diameter, apparently settle out of the air st.eam and, based on air samples taken by Region I, do not constitute an airborne problem at the present time, The manufacturer, 3M, reports that the microspheres are very insoluble and, if ingested, would move through the intestinal tract and be excreted from tha f
body.
Analysis of the urine specimens obtained from the workers should indi-i, cate whether this conclusion is valid, since the prasence of polonium in the ur'ne would indicate that the ingested material was or h?s beco:re soluble.
Any potential health impact would be minimi:ed if any ingested material was and 3
remained insoluble.
I I
During the weekend, ACC determined that ioni:er units of tne same *ype (3M
(
model no. 903) were installed at its facility in Dallas, Texas.
APH repre-sentatives were flonn to Dailas, where they determined that similar contaminaticn existed.
The Texas Bureau of kadiation Control (BRC) reportedly dispatched an inspector to that facility on January 24 to monitor con +.ainment
}
and cleanuo activities at the Dallas location.
Region IV and State, local and Indian Tribe Programs are maintaining contact with the Texas BRC. ACC also reported that series 900 foni:er units are in use at its facility in New rk, i
CA, and at a pilot facility in Columbus, OH, but checks of those units I
ky the licensee revealed no evidence of contamination.
A three person team fecm the 3M Company, including a recogni:ed u pert in i
ioni:ing devices, has been at the Easton site since the morning,f January 23.
A management team from ACC corporate headquarters also arrived on site the 3
morning of January 23 to direct control and cleanup activities.
Region III has maintained a dialogue with 3M relative to the production and distribution of ioni:ing device: r.d ci:pctchd 5;e:t:-s to the h Eri; Sten, ':S plant where ne devices are man;factured.
f j
Since the cause of the failure of the devices has not been determined, and beca
' of the widespread use of the devices (3M reports about 8,000 customers i
in t
' S., with at least 20,000 units in use), the NRC issued an Order to 3M on Ja try 25, suspending the license under wnich the ma'el 903 and similar devic 3re distributed.
The Order also requires 3M to nform any customer to whom y ified models of the device have been distributed of the incidents describ above and to provide any information on possitie causes of the i
leakap
,,f 90-210, to instruct such users of the cevices to inform 3M of any
{
suspected failures of the devices, and to call to the attentian of the usert the requirements of 10 CFR 31.5(c)(5) (i.e., suspend use of the oevice if j
removable contamination of 0.005 microcuries is identified).
The Order a?so j
requires 3M to inform NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> cf any device fa. lures that are reocrted, to institute a testing program to identify the St. ope of the 6 s;e i
failure problem and to provide to NRC,,ithin 14 days a plan for identifying any additional failed devices.
An analysis of causes of device failures is D so required.
I I
i l
i i
PN0-I-88 12A 3
ACC issued two press releases between Januacy 22 and 24, and the NRC has responded to numerous media inquiries.
In addition, NRC issued a press release in connection with issuance of the Order to 3M on January 25.
The Commonwealth of Pennsylvania and the States of Texas and Minnesota have been informed of the incident.
This information is current as of 1:00 p.m.,
Janua ry 25, 1988.
CONTACT:
J. Joyner (346-5251)
T. Martin (346-5220; DISTRIBUTION:
H. St.
MNBB Phillips E/W Willste Mail: ADM:DMB Chairman Zech EDO NRR NMSS DOT:Trans only Comm. Roberts PA OIA RES Comm. Bernthal OGC AE00 NRC Ops Crt Comm. Carr Comm. Rogers ACRS Air RigFts INP0----
SECY SP NSAC----
CA POR Regional Offices TMI Resident Section RI Resident Office Licensee:
(Reactor Licensees)
Region I Form 83 (Rev. August 1987) l 1
l l
l
DCS No: 999999012288 Date:
February 1, 1988 PREL NINA3Y NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-I-88-11B This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance.
The information is as initially received without verification or evaluation, and is basically all that is known by the Region I staff on this date.
Facility:
Licensee Emergency Classification:
Ashland Chemical Company Notification of Unusual Event Easton, Pennsylvania Alert General Licensee Site Area Emergency General Emergency X Not Applicable
Subject:
POLONIUM-210 CONTAMINATION OF FACILITIES AND PERSONNEL FROM STATIC ELIMINATING DEVICE - (UPDATE)
On January 22, 1988, Ashland Chemical Company, Easton, Pa., reported to Region I that one or more of its ionizing air guns held under : general license had apparently become defective, allowing polonium-210 (Fo-210) contamination to be spread to areas of the Easton plant and to workers' clothing.
The ionizing air gun devices were manufactured by 3M Company, St. Paul, Mn.
An NRC Augmented Inspection Team was dispatched to the Easton site and confirmed the prasence of contamination.
A Confirmatory Action Letter dated January 22, 1988 was issued to Ashland Chemical Company which required, among other items, that there be no shipment of product from the facility until certain steps were taken.
These steps included the performance of appropriate surveys, the evaluation by the licensee of the hazards of the potentially contaminated product, and the concurrence by the NRC.
On January 27, 1988, the NRC received the licensee's letter dated January 27, 1988 which included a preliminary report of findings by Ashland Chemical Company in reference to potential radiological contamination of the products from the Easton, Pennsylvania facility.
The licensee concluded that contamination of product from the Easton facility is not extensive or severe, that the form of the detected contamination precludes significant biological effects, and that the proposed end uses of any product will not include food, beverage, cosmetic or pharmaceutical applications.
In accordance with the NRC's letter dated January 22, 1988 and in consideration of the licensee's survay results and conclusions, the NRC accepted the licensee's request to release the potentially contaminated product from the Easton facility.
The NRC's letter documenting this result noted that the NRC's consideration of acceptability 4
related only to public health and safety and did not consider other aspects of product purity or quality which might be important to Ashland Chemical's customers.
All other commitments documented in the NRC's January 22, 1988 Confirmatory Action Letter remain in effect.
The Commonwealth of Pennsylvania and the States of Texas, Ohio, California and
~
Minnesota have been informed of the incident.
CONTACT:
J.
(346-5102)
T in (346-5280)
_eppp-y
DCS No:
999999012288 Date:
February 3,1988 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-I-88-11C This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance. The information is as initially received without verification or evaluation, and is basically all that is known by the Region I staff on this date.
Facility:
Licensee Emergency Classification:
Ashland Chemical Company Notification of Unusual Event Easton, Pennsylvania Alert General License Site Area Emergency General Emergency X
Not Applicable
Subject:
POLONIUM-210 CONTAMINATION OF FACILITIES AND PERSONNEL FROM STATIC ELIMINATING DEVICE - (UPDATE)
On January 22, 1988, Ashland Chemical Company, Easton, Pa., reported to Region I that ona.or more of its icnizing air gur,s held under a general license had apparently become defective, allowing polonium-210 (Po-210) contamination to be spread to areas of the Easton plant and to workers' clothing.
The ionizing air gun devices were manufactured by 3M Company, St. Paul, MN.
Similar contamination from failed ionizing air guns was found at Ashland's Dallas, Texas facility as well. An NRC Augmented Inspection Team was dispatched to the Easton site a.id confirmed the presence of contamination. The State of Texas dispatched inspectors to the Dallas' facility.
The Augmented Inspection Team completed its on-site activities on February 1, 1988 and began work on its report on February 2.
Analysis of urine samples obtained from Ashland employees revealed no uptake of soluble polonium-210 by any of 72 employees sampled at the Easton, Pennsylvania, facility, or of 42 enzployees sampled at the Dallas, Texas, facility.
The urine samples obtained from the Easton employees were split with NRC and analyzed by both an NRC reference laboratory and by an Ashland contractor laboratory. Both labs reported comparable negative results. Analysis of 70 fecal samples obtained from Ashland employees is continuing with results expected within two weeks.
Results of these analyses will reveal the presence of any insoluble polonium that may have been ingested by the employees.
Decontamination of both the Easton and Dallas facilities by an Ashland contractor (International Technology Corporation) is continuing.
Low level polonium-210 contamination is widespread within the process buildings at both sites, but has generally been fairly easy to clean by vacuuming, since it appears to consist primarily of microspheres.
It is not yet known when decontamination will be completed.
The Commonwealth of Pennsylvania and the States of Texas, Ohio, California and Minnesota have been informed of the incident.
CONTACT:
J. Joyner T. Martin 346-5251 346-5280 g a ananno g g 7 fa n '
Appendix 2 Confirmatory Action Letter to Ashland Chemical Company and Associated Correspondence
(
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,. - -,..v.r--
,,,n--,
UNITED STATES
-e NUCLEAR REGULATORY COMMISSION y
j REGION 1 l
u 2
475 ALLENDALE ROAD af KING OF PRUS$lA, PENNSYLVANIA 19408
- ~**
ma, m Docket No. 99990001 General Licensee CAL No. 88-03 Ashland Chemical Company ATTN: Mr. James Diquin Vice President Post Office Box 2219 Columbus, Ohio 43216 Gentlemen:
Subject:
Confimatory Action Letter 88-03:
Radioactive Contamination From Static Elimination Devices On January 22, 1988, at approximately 9:00 a.m., we were informed by your consultant that radioactive contamination had been detected in your Easton, Pennsylvania facility. The contamination apparently originated from one or more static elimination devices containing polonium-210 that are used in that facility.
As a result of infomation provided by your consultant, and subsequently confirmed by our inspectors, I contacted you by telephone on January 22 and infomed you that our Augmented Inspection Team (AIT) would be sent to the site on January 23.
The team will (1) independently verify that your consultant has successfully detemined the extent of the contamination, mitigated any health risks and is appropriately controlling and cleaning up the contamination, and (2) detemine the cause of the incident.
During the telephone call you agreed that the following actions have been or will be taken:
l 1.
All records, logs and notes concerning this event, the subject devices and Ashland Chemical's response to the event will be collected and maintained for review by the NRC.
1 i
2.
The AIT Leader will be provided access to infomation on customers who obtained any chemicals from the Easton facility that are possibly contaminated as a result of the apparent failure of the static elimination devices.
3.
The AIT Leader will be consulted prior to initiation of any movement, troubleshooting or repair activities related to the static elimination devices or systems connected thereto.
N
/
Ashltnd Chemical Company 2
4.
No portion of the facility will be returned to nonnal access or operation, including shipment of product, until (a) appropriate radiation surveys are conducted, (b) you conclude from those surveys that there is no radiological hazard to your employees or the public, (c) you conclude that the determination of the root cause of the apparent failure of the static eliminator device would not be compromised by the startup, and (d) the AIT Leader concurs in y' :r conclusions.
5.
A written report will be provided to the Regional Administrator, NRC Region I, 475 Allendale Road, King of Prussia, Pennsylvania, 19406, within 30 days after resumption of operations including the following:
a.
An evaluation of the root cause(s) of the event b.
Corrective action taken to prevent recurrence c.
Safety implications of this event The AIT Leader will be Mr. John R. White.
If your understanding of the actions to be taken are different that those described above, please contact this office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of this letter.
Thank you for your cooperation.
Sincerely,
~
Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:
Darryl String, Plant Manager RD 4, Island Park Road Easton, Pennsylvania 18044 Public Document Room (PDR)
Nuclear Safety Information Center (NSIC)
(
Comonwealth of Pennsylvania State of Ohio I