ML20248L951

Partially Deleted Compliance Investigation Rept for License SNM-1002 on 680128-30.Items of Noncompliance Noted.Major Areas Investigated:Type a Exposure to Personnel & Shutdown of Facility from Plutonium 238 Release on 680118

ML20248L951
Person / Time
Site:	07001051
Issue date:	03/22/1968
From:	Book H, Metzger J, Julie Ward US ATOMIC ENERGY COMMISSION (AEC)
To:
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ML20248L208	List: ML20248L206 ML20248L223 ML20248L229 ML20248L256 ML20248L265 ML20248L271 ML20248L276 ML20248L282 ML20248L933 ML20248L939 ML20248L942 ML20248L943 ML20248L946 ML20248L951 ML20248L952 ML20248L955 ML20248L965 ML20248L969 ML20248L973 ML20248L978
References
FOIA-98-19 NUDOCS 9806120136
Download: ML20248L951 (34)

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{{#Wiki_filter:- - - _ _ - _ _ _ - - _ - - _ - -. _ _ _ _ _ _ - - - - - - - _ _ _.. - - _ _ _. _ _ u I-COMPLIANCE INVESTIGA'nON REPORT DIVISION OF COMPLIANCE REGION V e r l Subject U. S. Nuclear Corporation 801 N. Lake Street' Burbank, California License No. SNM-1002 Type A exposure to personnel, and shutdown of facility from a Plutonium 238 release on Jwuary 18,1%8. Period of Investigation: January 2. - 30.1%8. 1 (( Inveselgato. k ~ m JohnJ.% (Date) ) Investigator: [

f. /.

__ J p N . Metzger/ (Date) ' T E. A.A g/uhx i ..er: 9906120136 990603 a' -s / Herbert E. Book (bate) PDR FOIA / FRIEDmw99-19 _ PDR J e Ofoc t>of 36 $?

l REASON FOR INVESTIG ATION l An anonymous telephone call was received by Region V on January 22,1968. The caller reported extensive contamination at the licensee's facility, caused by cutting l into a source capsule. It was decided to conduct an investigation.

SUMMARY

OF FAC'IS On January 18, 1968, the active portion of a 35-curie Pu-Re neutron source was cut into when two licensec employees attempted to irmove its outer encapsulation. The operation was performed in a cican, open machinc shop area on the licenece's premises with no provision for containment of the contamination, and with inadequate health and safety procedures. The incident resulted in extensive contamination to the operating portion of the facility, machinc shop, and the shinping dock, as wpf t as spotty contamination throughout ths office area of the facility, the roof top of the building and sidewalks in the vicinity of the intilding. Contamination was picked up on employces'shocs, cars, and clothing and was tracked to three of their homes. Although plutonium contamination was exhausted through a forced air vent in the roof to the outside of the facility, there was no alpha contamination in air samples collected at a State sampling station two miles distant. Vegetation and soil samples taken within a two-block radius of the plant showed no significant dispersion of alpha activity to the environment. One licensee employee who cut into the capsule ingested by cspiration between 150 and 230wanocuries of Pu-238, as determined by whole body counting. Dis represents approximately 12 lung burdens. De health physicist and two other persons involved received less than one lung burden each as determined by whole body counting. An AEC medical consultant assisted the licensee's physician in evaluating the exposures. Publicity consisted of one factual local news story resulting from a release matie by the licensee. Items of noncompliance determined during the investigation, all of which contributed to or were caused by the incident, are as follows: 10 CFR 20.403(a) and (b) - Reporting Requirements - in that the licensee did not notify the Atomic Energy Commission either v immediately or within 24 Fours, although the loss of the facility was for more than a week (see paragraph 3. Details). License No. SNM 1002 - Authorized Use - The licensee performed operations not authorized by the license in that, plutonium-beryllium sources were fabricated in quantity greater than the 12 authorized under the license and in strength different from the i 400-curie sources authorized by the license (see paragraphs I, 2,17, and 44, Details). in that a location in a machine shop area, not authorized by the license ~ / was used for work on a plutonium source (see paragraphs 11,13 and 18. Details). / in that a cutting operation, not authorized by the license, was performed on the source (see paragraphs 1, 9, and 10. Details). - in that U. S. Nuclear administrative procedures submitted by USN application letter of March 22, 1967, were not followed in regard to the specific responsibilities of the corporate Radiological Safety Officer (see paragraphs 6 and 46. Details). 10 CFR 20.201(b) - Surveys in that surveys, i.e., adequate evaluations of radiation hazards, were not made incident to the use of radioactive materials. Most of the evaluations subseq6ent to the incident were made at the insistence of the AEC investigators (see paragraphs 8,10, 36, 37, 40, and 41, Details). 10 CFR 20.401 - Records of Surveys - in that no records of surveys were made of the radiation exposures of y the individuals involved in the Pu-238 incident (see paragraph 21 Details). t

10 CFR 20.In1(a) - Exposure of in.h.huis - in that the licen8ee used licensed material in such a maaner that individuals in restricted areas were caused to be exposed to airborne Pu 238 concentrations in excess of Part 20 limits (see paragraphs 30, and 37, Details). 10 CFR 20.401 - Records of Surveys - in that no records of air sample surveys had been maintained by the licensee of operations conducted prior to the incident, but subsequent to the AEC inspection of December,1967 (see paragraph 21, Details). b i 9 3 4

DETAILS Back ground _ License No. SNM 1002, issued April 6,1967, authorized U. 5. Nuclear Corporation to receive 12 metal pellets of Ib-238 of 24 grams cach for theEach source was to ha l. 400 curies in strength, and to have been doubly encapsulated in stainless preparation of Pu-Be sources, stocl. The license does not authorize removal of this encapsulation. Twelve Pu Be sources were fabricated under a Westinghouse Dettis Atomic Power Plant contract for the U. S. Navy, Order 14o. 73-DY-373024-M, (Exhibit A). He 12 sources were completed on schedule, tested according to the license and specifications, and had been shipped. Westinghouse then contracted with the licensee to fabricate seve.,.auditional smaller sources under Order No. 73-Y-377762, (Exhtbit B). %ese sources 2. are similar in design to the larger ones and were to be approximately 45 curh~ in strength, and to have been made from saother 24 grams of metalin one e plutonium pellet provided by the Westinghouse Company. Wese seven sources also were to have been doubly encapsulated in stainless steel, tested, and 16, 1967, He order had been received on Ck:tober 1967. and the 24-gram Pu metal pellet for the order was received on November 17, ehlpped to the Bettis Plant. Introduction _ Region V received an anonymous telephone call which l 18, 1968, three employees of the icensee, b 3. On January 22,1968, the eve ing of January had been involved in an incident wherein a source reported th ich resulted in general contamination of the licensee's including had been cut open, Herbert E. Book, Senior Radia n Specialist facility. On January 22,1968. r in telpphone calls t rank Collins , Region V, attempted to clarify the matte the licensee's Health Ihysicist, and George Harwood, the licensee s Radiological Safety Officer. These persons admitted to a contamination ble incident at the facility which they rdnimized, and stated it was not a reporta No written report of the incident was made until the investigation incident. was under way (see paragraph 44, and Exhibit M). As a result of these conflicting reports, and in view of the potential hazards from plutonium contamination, an investigation of the incident was de 4. d J. R. Metzger, on January 23, and continued through January 30,1968. Radiation Specialist, Region V, and J. J. Ward, Investigation Specia!!st. Region IV, conducted the investigation. James Heacock of the State Div Dr. Kenneth McCormack, and the Director, Division of Information, SAN, Rodney Southwick, assisted the licensee in a medical evaluation of the exposures The investigation consisted of interviewing personnel involved, making independent surveys of the premises and environment, and and in its press release. auditing of surveys and bioassays made and contracted for by the licensee. Subsequent to the initial period of investigation, Region V Radiation Specialists 15, 20-21, 1968, for the observation 5. revisited the facility on February 5-9, February d for of decontamination procedures, verification of areas decontaminated, anob h appropriate the Westinghouse order. Interim reports of those activities, witd dated enclosures, were submitted to Compliance Headquarters by memoran a March 8 and March !!,1968. Some of the' enclosures are duplicated as exhibits to this report. Investigation, January 23 30, 1968 Interview with George E. Harwood, Radiological Safety Officer, Vice President and General Manager, U. 5. Nuclear _ George B. Harwood was the first person contacted at the facility the af ternoon because He was informed that the investigators were there 6. of the advice to Region V that there had been a contamination incident at the of January 23,1968. facility. Harwood stated that there had been a contamination incident at the I (1 L', i _7

facility. Harwood stated that there had been an incident which occurred the evening of January IN 1965. lic s 9ted the twn individuals who had been contaminated werc .and W an. that fecal and urine samples had been obtained from them. He stated was out that very af ternoon buying a large vacuum cleaner for decontamination of the building. Harwood stated that after the incident had occurred ggh l contamination had been tracked from the operatione area of the building { into the office area, and that some b d actually been found in Harwood's j I calls to Harwood the evening of January]18.when he made several telephone j office, apparently tracked in by When asked what c,aused the { contamination, Harwood stated it had been caused byWJutting into the outer capsule of a double sealed plutonium-beryllium source. Harwood stated that on January 18 at about 5:30 p.m. as he was makin - l n final u of the plant before going home that evening he oHherved hack in the health physics office and made some juke about them not ben.g on overtime and stating that it was time to go home. j Harwood stated that he did not know they were planning to cut into the ( capsule that evening. He stated he had not known or approved of any i plans for cutting into it. Harwood stated that the bntope Committee of the licensee was essentially disbanded, had not met for several months, and had not been consulted in regard to the cutting operations. (The licensee's March 22. 1967, application letter states that detailed procedures will be approved by the Isotope Committee prior to work. Attached to that letter arc ICN procedurcs. Section 3 of these procedurcs specify the specific responsibilities of the Corporato Radiological Safety the sour /fiarwoof. These procedures were not followed.) Harwood stated G,y Officer ce had not come up to specifications as a neutron source, and that the Materials Testing Laboratory's X-ray of the capuule (which was a required testing procedure) had showed the outer capsule to have a hairlinc crack. Harwood stated the contra stin ouse had wanted the outer capsule replaced. However, who Lnd attempted to do this t y ruptured I the innpr capsule. He state ghad done the cutting and had been watching the procedure, an t1at the cutting was done on a e. Harwood stated that a mechanical air sampler was gperating at the time, and it showed only low levels of about 10*l3 or 10~l uc/ml on a Whatman filter paper. Harwood stated that other work had been done on the same lathe at least as late as January 11. 7. Harwood stated that the source was one of seven little reactor standardization f 8 sources with a neutron emission of 10 neutrons per second or approximately 400 curies Pu-238. (Harwood at that point did not realize, or did not want to 1 admit, that an unauthorized smaller source was involved.) He stated they I were all done for Westinghouse and the capsule was one of two types of sources built for' Westinghouse. Harwood stated that the contamination from the incident had been tracked around and several other individuals were involved. He stated that spots of contamination were smeared and showed 50 to 70,000 cpm /100 cm2 Harwood stated that he was in the area on January 23 for a re - run of the air samples. He stated thatMiad taken some nose wipes g!b the night of the incident. Harwood indicated that capsules may have been cut open before (without contamination having occurred). He described the Encapsulation procedure as constating of sealing the matrix in an inner capsule which is then decontaminated. The inner capsule is then put into a storage container to be taken to the " outer facility" where the outer capsule is welded on. X-rays and leak testing are also done there. Harwood stated that there has been no other rupture of a capsule to his knowledge. He stated contamination was general throughout the facility, and that approximately 2 to 300 cpm /100 cm2 had been found on the floor in the office area. ) 8. Harwood stated there had been no thought of a' medical examination for the persons involved since there had not appeared to be that much of a problem. Harwood stated that the reason the lathe in the outer facility was used was because the lathe in the inside glove box was out of order. (At this point l Harwood did not know the lathe used was the one tri the machine shop, l recording tg his later statement to the investigators.) z5-i or l L___________

l l { Interview withfM_l s l 9. stated that he is th< l He stated that he had opened two c on previous occasions. He stated that, in addition toS) ytr capsul 1 had also been in the i ed ate vicinity and had been i I cofitaminated when the capsule was ruptured. , tated.that he started cutting into the capsule between 5:10 p.m. and 6:00 p.m. He stated he had worn a comfo air mask and that an air sampler had been operating. He stated that there was a small amount of antamination on the inner capsule. When the outer capsule had been rhceked, a flaw had been found which i consisted of a small, minute crack. He stated that he had set the capsule up in the lathe, and had cut all of the way through the ourcr capsule using a hacksaw with a three-foot extension on the handio e,o that he could stand j 80 behind a water tank during this operation. He stated that he noticed a change in the c f the filings coming from his operation. At about the samw

time, said that he was getting some alpha readin =

d that they should all back off. He stated be had been surveyed by md had showered. He stated he took a nose smear with a "Q tip', and had taken a bottle home f r a urine sample. He stated that be had a focal sample the followir.g day. Lated that the air samplce was two or three Icet away from their operation. @ stated that he had not gonc to a doctor nor had he been told to go to a doctor as a result of the incident. f low ' "r. on Monday, January 22. he had been examined by a Dr. Raymond Whall"). who is his family physician. (Dr. Raymond Whalley, 6777 Hollywood i Doulevard, telephone number 463 0966). stated that he had gone ) for a routine yearly physical that day and@had made the appointment for it approximately two weeks prior to that. He stated blood samples were taken and a routine physical was given him. He stated e did ot tell Dr. Whalley of the ir.cident of the preceding %ursday night. stated that no nose e smears had been taken of titm Friday morning, but tnat a nose smear had been taken gn' January 23 which was negative. grview with 10. is th or the licensee. He was interviewed Liter he re r d to the plant th n of rv 2 with the vacuum c

cleaner, tat and had been engaged in the cutting operation.

ad been calle immediately after the dent and had returned to the plant for decontamination procedures. Es,tated that he had a Gelman air sampler working at the time of the l ancident, and that he liter counted the filter from this air sampler which showed about 1.9 x 10-11 uc/ml. He stated that this was a late count, howevei, and this count was from memory as he had not made a written r of it. He stated he first realized something had gone wrong when hh' i as cutting into the capsule when he saw rust-colored filings dropping i When he saw this, he knew it was plutonium. He alerted the others rom it. rnd the,"went to mas'k." He then notified Mr. Harwood by telephone. stated that he knew people were still in the building when the ent a occurred. He stated Mr. Fallis had stuck his head in the door, but had told him to keep out, there was a contamination pr9blem. (Mr. Fallis is the General Director, Chemical and Radioisotopes Dtvision, ICN.) 6 stated that he had found some contamination on the floor of the office, hu shop had been hit harder. He stated there was a blower in that shop. stated that the contaminated people had taken showers before returning to their homes. He stated he had found contaminate n which e re embered to be in the order of 20 to 30,000 cpm in the hair o and himself. Ha stated the nose smars registered 500 to 1.000 cpm on a' portable alpha counter. He aid later smears were negative.' He stated after the incident h2 an losed up the lathe area that night and made a survey of the front office area. They checked the office from top to bottom. They found a rug in the sales office with 000,to 3,000 cpm. They found 50,000 cpm in places in the shop area. tated that w3s standi eight to nine feet $ck from the lathe wa ng to take home. stated that none of mem had any protective clothing on, except for lab coats. He stated they wore no masks. He stated that fecal and urine sam les taken g/L from himself and @had not yet been sent in for analysis, stated f" A v that h had turned these over in his assistant. Chuck Mitchell, and he didn't know o Mitchell had gotten further samples from. stated he had i not checked the fecal samples with a portable alpha co@unter for a rough i estimate of contamination because his stomach was too upsat for such a chore. l t

11. stated he had been told the inner capsules were clean. He intimated that the one involved may not hase been clean and the contamination occurred wh he outer capsule was cut into without cutting into the inner capsule. stated he has played the incident down because of the possibility of panic.,He stated that he did not know who might have alerted the AEC, but that it could ha e Merv Pointer, the machinist who ordinarily worked on the lathe. < explained that he called Ibinter that "Ihursday night, and he wanted him to work at Te ical Associates the next day, since the e, fathe area was contatninated. tated that Merv Pointer la afraid of i radiation and, therefore, not i erstanding the situation, could have {g made tbc report to AEC, whirl stated was not necessary since the situ.ition was under control, lie statec the other punnihihty is that the report was made by the Fire Department inspectors who had been in the office on Friday Mstated that it was important to keep people in the front ollice under controF.

12. Mstated that he andMhad worked closely together on the capsule..

He stated the lathe in the inner facility was mechanically gone, and that the cutting work had to be done outside the inner facility. He said that this - particular capsule was a rework from the Westinghouse order, and a crack had appeared when it was helium leak tested. He stated the capsule had been brought to the outer facility for outer encapsulation. They had supposedly been checked for cont et on and had been welded on Friday, the week before (January 12). jxplained the Navy neutron sources had been completed, and that all of the smaller Westinghouse sources had been helium tested, but they were not required to leak test the little ones. He explained mf the little ones had been made up from one plutonium slug which was crushed C.J Io to provide material for seven sources of about 24 curies each under another contract. He stated they were standard neutron capsules, similar to those . produced under the Navy contract. He stated that the capsule which had been cut info was in the inner facility glove box in a glass jar with a tid on it. 3

13. % stated that a nemosphere had been used on the job which had detected a neutron radiation of s ro imately 2 mrem /hr during the operation of cutting the capsule.

stated that he had pulled the badges for and himself which were provided by Radiation Detect 1 of Mountain View, but that he had not turned them t. He sta did not have a badge ) and was standing in the back, tated that aoout to 10 em was recorded on the neutron personnel dosimetern that he and wore, but that he had made no written record of this, stated snat 14 to 15 inner capsules trad bee icated. Seven of them a n earmarked for Westinghouse. then led the way to the machine shop area where the lathe was locate. At this point, George Harw c p the investigators and stated he didn't know until then that and had opened the g g (o

• capsule on the machine shop lathe. (A review of the scense and application reveals that only the plutonium lab and outer facility ** are described and author l zed as locations where work with plutonium can be conducted.)

14. Mstated that his urine and fecal an urine and fecal sarrples would be sent in on January 24 to U had been received fror1%

. 5. Testing. He stated no urine or fecal Inttrview wi 15. stated that he normally worked in the C-14 labs and had been present wnen the capsule was cut into only because he was to takeWhome. ted that he had been in the machine shop only a couple of minutes when old him that somethmg was wrong, and asked him to go back to the health hysics office. tated he wore no mask orprotective clothin and can't recall that an11r simpler was present. stated that made a survey of him back in the health physics.o ace and had him take of all of his clothes. He stated he had a nose wipe before3he shower. He did vh i not know wlbst the count was. He stated he had a film badge and a dositneter hA in his pants pocket, but they were picked up with the clothing which he did not get back. He said he showered after removing his clothing, and was surveyed after the shower. He stated he took a urine sample twiric home the night of the 18th, and combined the sample for 24 hours. He stated a man had l been sent out to pick up the samples from him on January 24. He stated t e fecal sample picked up on the 21m was from a voiding of the 19th, statal that he had come to work the next day. January 19, and that he told Fallis he wanted to quit on January 19. He rtated he had made this decision to the incident of the nW nf January 18. He stated the reasons were r and had no bearing," the contaminadon incident. He steed that he had voltmiarily quit, and this had been no action on the part of the licensee

l volved in the incident. %] stated that because of his havin heen he did not think that hhad a mask on at the time of the incident. He didn't think that they had lah coats on, and he could not see what {M they were cutting. Interview with" 16. )tated he is a technician and he was called back to work between ately 7:00 p.m. und 8:00 p.m. the evening of January 18. He stated l had called him and asked him to bring soap for decontamination. l tated he wore a comfo mask, a lab coat, shoe covers, a personnel' e dosimeter.and a film hadgc. He stated they first had made surveys and then started cleaning up. He stated he was asked to fill a urine bottle on Monday, January 22, efore, and that he had furnished a fecal sample on January 24. stated that he had a nose blow samplu. but no sputum sample was taken until that Monday, January 22. He stated that the source involved was on. of seven regular plutonium slugs. He stated he didn't know where the incident occurred; he saw no shield and he kne about the inci c th it wa f the seven small slugs, stated that he, an orked until approximately mounight de co t'immatmg the place. Interview with other employees

17. At this point in the anwstigation, Bill Bradley, the USN Sales Manager, contacted the investigator in Mr. Fallis' office to provide information on the sources prepared for Wcshnghounc. Ifc mated they had been manufactured according to Westinghouse engineering drawing No. 911117 8 6 of which he furnished a copy of a change order (Exhibit C) showing the configuration of the capsule. He provided fur inspection a copy of the contract, Wem bmhouse Order No.

73-Y 377762, dated October 6,1967, whirh spceified that the seven sources were to be fabricated from a 24 gram pellet of Pu 238 metal supplied by Westinghouse. ExceptTor the first two sheets of the contract (Exhibit D, above), the rest of the contract was a standard form, No. 73495K. Article ' No. 32 of this form covers Health and Safety requirements and states "All government agency regulations will apply." Dradley stated the failed source was No. SN-W424, as noted on the engineering change drawing. He produced a copy of the radiographic test report dated January 12, 1968, which reporte,d " crack opposite welded end." (Exhibit D). Bradley stated the order did not specHy the number of curies each source contained, but specified a neutron emission rate. Bradley stated the final assay for the failed source was recorded as 5.1 x 107 n/s emission rate. George Harwood, who was present then, performed the following calculations to show this emission rate was equivalent j to 35.3 curies. I 24 g a Pu-238 in original pellet 1 16.2 = c/g of Pu-238 5.63 x 108 n/a = emission rate of total matrix 7 5.1 x 10 n/s emission rate of source j 5.1 x 107 x 24 x 16.2 s 35.3 curies plutonium in source i 5.63 x 105 18. was briefly reinterviewed on January 26 af ter he had been whnle y counted and after his house had been checked for contamination. %] stated that he had taken two showers at the plant immediately after the incident had taken off all his clothing and@put it in a bag. He on January 18. He stated he and iad surveyed each other and that he dh had other clothing g* g and shoes in a locker which he put on to wear home. tated that on two other occasions he had successfully cut off the outer capsulelii of the larger (400 curie) sources which were about 12 inches long. He stated that had beeri ( done in the inner facility. He stated the cutting could not be done on the outer facility lathe since that lathe was set up for welding only and would automatically l turn when something was put in the chuck. tated the larger capsules had been cut open by using a pipe cutter place on he d of the capsule which was placed on end in a paraffin block for shielding. further explained this procedure later, saying that they used a long handle on the pipe cutter and crouche4down to avoid exposure from the top of the source, and turned the l pipe cutter by walkin in a circle around the sout 'n the paraffin block.) On January 18, stated he attempted to 1. pe cutter on the smaller source which m ured about 9/16 inch diametet, found that the cutter was too large for it to grip the source. He stated that he andgthen decided to uso the chuck of the machine shop lathe as a vise to grip tne source while i ttioy ctet the und off with a hacksaw. 110 stated he had used a body shield to protect him for this operation. He described st as a wooden frame filled with i paraffm blocks which is on rollers and can be. olled up to the work by the man behind if.Mstated again that he had worn a part'r enat, no gloves, no head cover, and no shoc covers. He stated again that he had worn a comfo mask, He stated his lung deposition had probably occurred when he inhaled l as he, was taking the mask rdf. l 1 ]

l 19. R. M. liaslett, the Technical Sales Director nf the lirenew '.end former 7 Hot lab Supervisor, was briefly interviewed on January 25 concerning 3 the information furnl& 1 m the two orders by lhll Bradicy (see paragraph 17, above). Haslett stated that while the Navy order had called for 12 pellets (which would total the 288 gram limitation of the license), the licensee had actually received more than this number over the period of the contract since some had been exchanged and sent back to Westinghouse. In toto, however, Haslett stated the licensee had received only 12 pellets ." Z. except for the additional one, making 13, from which the seven smaller sources were fabricated. Haslett provided copies of the two orders, engineering drawing and test sheet, appearing as Exhibits A, D, C, and D of this report.

20. Merv Pointer, the machinist whose lathe had been used I and Mthe night of January 18 and who had been told by to report k

t 4 for work at Technical Associates the following morning, was interv!cwed 'En at that company on January 25. Pointer stated that he had not reported to 8011.ake Street after the o and had not been able to get his tools out of } the facility. He state had informed him that they were contaminated. He stated the company had (mught him a new tool box and would buy him a new set of tools if they could not adequately decontam nate the ones he I{ left behind in the machine shop. 3 i Survey Records 1

21. According th, no records were maintained of surveys performed during and after the meident. The air sample log book showed that the last entry was made on December 12, 1967 (De last day of the last routine AEC inspection.) A few air sample results, taken after the incident, were calculated from datawritten on bits of scratch paper. Dese ranged from 1.4 x 10-13 ue/cc to 5.4 x 10-12 uc/cc, covering the days January 18-24, Also, no dose rate surveys of the capsule and no nasal 1 of 3

the employees involved in the incident were recorded. ecalled that nose wipes revealed 500 to 1,000 cpm ulpha and hair contammation from { 20,000 to 30,000 cpm alpha, using an Eberline PAC 3G alpha detector, but had not the time to make "ecords of this. There were no records available on clothing and skin contamination, nor on the extent of contamination spread following the incident. Some of these survey requests were recorded t (evidently from memory) in the 30-day report required by 20.405(a), submitted by the licensee on February 17, 1968. Decontamination Efforts { q

22. The licensee had effected some decontamination by the time of the investigators' j

arrival on January 23. According toMnd Harwood, decontamination of the building began immediately after the incident on January 18 and continued through that night. 'Ihis included mopping and painting surfaces to hold down the reinaining contamination. The licensee began using spray foam on ' ertical ] v f surfaces on Wednesday, January 24, with some success in one office room. fo Attempts at using this technique on the " bay" floor wqre unsuccessful since the contamination had worked down into the rough-finished concrete. A vacuum blaster was purchased by the licensee on February 5, and its use proved effective for decontamination of the concrete sidewalks and floors. Independent Surveys Extent of Contamination Spread l I I

23. Independent surveys were made by AEC inspectors during the days of January

{ 23, 24, 25, 26, 30, and February 5, 6, 7, 8, and 9 on various arcas to check l the extent of contamination and progress of decontamination. Photographs of the survey operation and equipment involved were taken January 24-30. j (Exhibit E). Flot plans and sketches showing results of these independent surveys are> attached (Exhibit F. Annexes A, B, C, and D). The contam4 nation found was particulate in nature, except in areas very close to the machir$e shop incident area where the contamination was general. j

• 9

( L __________._____J

n_--- Surveys outside of Buildine

24. Surveys were conducted outside of the buildmg on the public sidewalks and the buildmg roof by the AEC investigators. Surveys were made by the licensee in two U. S. Nuclear employees' homes with the investigators observing.

James H. Heacock of the California State Civision of Industrial Safety helped in conducting surveys of the building and sidewalks. Further surveys were made subsequently by the licensee on the sidewalk to check cleaning progress and in five additional employees' homes.

25. Particulate contamination was found outside the building (see Annex A). Specks of contamination reading as high as 30,000 cpm alpha were found near the entrance doors, tapering off to < 500 cpm near Victory Street and towards the Environmental Sciences building on Lake Street. Addmonal contamination,

was found in the U. S. Nucicur parking lot in the pathway from the side entrance door. Additional surveys in the streelN and away from the building revealed no contamination. A large amount of contamination had been washed underneath the large roll-up door to the sidewalks on Lake Street from a decontamination operation inside. Decontamination of the public areas outside the U. S. Nuclear building was completed on February 7,1968. The method of decon: amination was vacuum blasting. De AEC inspectors checked the decontaminated arcas and resurveyed the entire sidewalk and found no contamination above ABC criteria for rel m. Survcvs of the Dullding Roof

26. A survey of the roof revealed minor spots of contamination in the form of specks exccpt on one exhaust vent which had general contaminnH% m hour sides of the wire screen around the outlet to 50,000 cpm alpha. A smear of the screen revealed 2.500 cpm alpha (see Annex C). De exhaust was operating during the incident and was open to the building via a 10-inch diameter hole in the side of the squirrel-cagc blower housing located on top of the lower roof over labs 6 and 7 (see photograph Exhibit E and Exhibit F, Annex A -

" Waste Room"). he hole in the housing was located about 60 feet from the shop where the incident occurred and overlooks the shop walls (the shop has no ceiling). After the roof survey, the licensee was asked to secure all exhaust fans that did not have an absolute filtering system. %is was done. Mr. Fallis obtained a wipe sample of the e':haust vent contamination to have it analyzed to determine whether the contaminant was plutonium or actually polonium, which the licensee had used years before. The result of that analysis (NSEC No. E8-Il-78) indicates 50% Pu-238, 27% polonium, and 23% of unknown alpha emitters, as noted in the licensee's report (Exhibit G). Building Surveys

27. De extent of the contamination was as shown in Annexes A, B, and D of Exhibit F. De contamination was mostly particulate, except on the inside of the ;" Outer Facility" and in the immediate area of the shop lathe. %e highest speck density was found to be in the dock " bay" area (see Annex A).

(No painting had been done in the bay. De contamination had been painted over in other places.) Several specks of contamination were still detectable on the painted surfaces of the floor and walls (see Annex B). De high roof rafters were not surveyed by the investigators because of inaccessibility.

28. The hi.

t levels of contamination were found on the Outer Facility surfaces, gjb ,tated this was caused when the source, which had been cut into, e was brought from the machine shop to the Outer Facility to be put into the glass jar there on the night of January 18. (The glass jar was later placed in the remote control box of the inner facility'.) Surveys prior to cleaning were not conducted inside the outer facility because of the potential hazard of spreading the contamination. De top of an " aquarium"(a glass water-hlled enclosure used for neutron shielding) which sets in front of the facility (see Exhibits E and F) showed an indication of 400,000 cpm a direct. After the facility was$ cleaned and painted, the contamination on the pside (vertical) surface of ti e aquarium revealed 800,000 cpm per 500 cm removable. Both the top and vertical sides of the aquarium were cleaned to < 100 cpm alpha, removable, by February 15. %e health physics office (the only office located in the work aren) was contaminated as shown in Exhihit F. De licensee was asked to move the office records and equipment (after decontaminating) to another office in the office area. his was done on January 25. On February 5, it was observed that the licensee had moved back into the health physics office where considerable contamination was still remaininth Pepecially in the adjacent supply room (see Annex A). l.

Air Samidhm

29. According i on air sampler was operating during the capsule cutting operation at a distance of four feet away from the lathe. He said that the sample was removed and counted, revealing the concentration to be 9.34 x 10-12 uc/cc of alpha (decay from 1.9 x 10-11 uc/cc). No records gg4 ihstantiate this and the sampic was thrown away counting, P

were availab n according to

30. Other samples were removed from labs 4, 6, and 7 (see Annex A) on hursday, January 25, eight days after the incident, but which included the day of the incident. %e eight-day (192 hr.) diluted samples showed 1.7 x 10-10 uc/cc alpha, 2 x 10-10 ue/cc alpha, and 5.9 x 10-30 uc/cc alph.,

for labs 4, 6, and 7 respectively. Recounts of these samples after suitable time Intervals showed no change. (%c 40-hour nyerage concentration limit for Pu-238 is 3 x 10-11 uc/ce.) An air sample from the stack exhaust (which showed contamination on the outlet as mentioned abcve) showed 6 x 10-13 u6/cc. The tygon hose sample line runs from the stack, across the lower lab roofs, and to the sample head in lab 22. De long hose may have prevented much of the althorne contamination to be picked up by the stack sampler. De stack sampirr,which monitors the exhaust from lab 22, showed a concentration of 2.6 x 1011 uc/cc alpha.

31. Air sampl[5 taken during decontamination and other opurations after the incident showed an overare of 10-13 uc/cc with some samples falling into the 10-12 uc/cc range. The licensec began operating three air samplers after the incident outside of the lab areas, one near the Outer Facility area, l

one in the shop where the incident took place, and one in the bay area, in l addition to the lab and stack samplers. I Surveys of Autos and Hom'es

32. On Wednesday, January 24, automobiles belonging to U. S. Nuclear employees were surveyed by the AEC ins

. Two autos were found to-be contaminated. The auto belonging t U. S. Nuclear employed laborer, had 8, d e floor mars an dpm on the seat. %c auto belonging t howed 500 dpm on the floor mat. No contamination was li found m other autos. 33 da innuary 25. the licensee surveye ome at n the presence of the AEC inspector. No contamina on was found on any surfaces inside the home e walkway outside. However, one pair of trousers belonging t which were 4 g ( hanging in the closet and which had been worn on Monday, January 22 for decontamination work at U. S. Nuclear prior to the AEC visit, revealed j 8,000 dpm general on the front of the trousers. We trousers were placed ( in a lastic bag and taken back to U. S. Nuclear.

34. On th i of Dursday, January 25, home at was surveyed by the licensee in the presence of the AEC 4

investigators. Two specks reading 2,500 dpm and 1,100 dpm were found on the rug at the base of the sofa in the living room, in addition, one speck of 500 dpm was found on the back of the sofa. The specks were removed with masking tape. A bath towel with general contamination of 1,100 dpm was removed from a bathroom towel eack, placed in a plastic bag, and taken back r by Mr. Fallis. No other contamination was found in

35. On the same day (January 25), it was tpe inspectors ggh that the licensee survey the homes of This was done on Monday, January 29, by the IEe e.

The licensee reported that l one speck of contamination was found g and removed. j According to'Mr. Fallis, no other contamination,was found in either of e two homes, sand on Monday, February 19, the licensee reported that fiv additional homes were surveyed with no contamination found. 11 l l l

I pioassay [

36. According tc the three employees associated with the incident and cibers on the decontamination crews submitted urine samples on January 18, 1968, after the incident. The samples were not sent in until Dursday, J.muary 25 to

.L estin-ro i any, Richland. Washington. Some fecal samples from nd ere also submitted. l De licensec was asked to continue with urine and fecal samples. He yg AEC medical advisor, Dr. K. McCormack, advised U. S. Nuclear that the four employees associated with the incident should provide " complete i v " samples. This was done until February y when, except for they were stopped by Dr. Oneal, the licenseo physician, r, ical had been advised by the AEC consultant, Dr. McCo ack, that at date samples were no longer necessary onM and I as l yond the usual periodic sam 't that continued ses and I comp etc voiding were necessary on " (see Exhibit K).

37. On Wednesday, January 24 wcru sent to a

Dattelle Northwest laboratones for whoic tuly counting at the request of the AEC investigators. Finn mits were reported on Friday, January 26. De whole body count n. showed that hc had 150 to 200ionnocurice of Pu-238 in his lungs (maxunum allownhie by ICRF C. tree D report is J 161sanocuries) or 10 to 14 lung hurdens. A count of showed that he l had < 10 Manocuries.(10 is minimum detectable) or as high as 20 manocuries I l since the Cs-134 and Co.60 components in his lu s may have masked out {jg l some of the plutonium, were wnt for whole body cuunting on January 29 The counts to nd @ revealed - < 10 manocuries.

38. On February 5, as sent back to 11attelle Northwest for a recount.

%c count show< 70-225Nanocuries, which was higher than the first count. l j %c lbttelle people said that the plutonium had worked deeper into the lungs, f j making it closer to the detectors, so that a higher reading would bc obtained; i they said it ennt that ihcre was no changc.I Mr. Fallis said that counts o on a quarterly basis were being started on February 19, 1968.

39. Urine sampic results (described as preliminary and i re available for samples submitted prior to the whole body count.

ample e s nding to the 0-200 inanocuries y( j revealed 1.07 dpm plutonium per 100 ml i in the lung by whole body counting) an ample revealed 0.61 dpm per l 100 ml, corresponding to 10-201ganocuries in the lung from whole body counting res uits. Environm ental Samp1kng

40. De licensee was asked by the AEC inspectors to propose a plan for taking j

environmental samples. On Friday, January 26, Dr. Darnell of Environmental l Sciences (a U. S. Nuclear subsidiary) said that they had found out that, at the time of the incident, the wind was blowing from the northeast at five knots. He said that they had taken seven vegetation samples and one soll sample in the southwest windrowand sent the samples back to Pittsburgh, Pennsylvania, j for analysis. Rcsuits of the soil and vegetation analyses showed no significant contamination (Exhibit G). He inspector calle:1 jules Zarchin, California l l State Bureau of Radiological Health, regarding environmental air samplers which had been operating during the incident. He said that one, located two miles west of the U. S. Nuclear plant on Beverly Boulevard, Hollywood, showed 0.03 pc/1, 0.01 pc/1, and 0.01 pc/l for the days January 17,18, and 19, respectively, and further said that these were statistically insignificant. Also, the Atomics International environmental air sampler at Santa Susana, 20 miles west of U. S. Nuclear, showed no indication during the same period. Personnel Dosimetry

41. He film bag;es of the employees involved in the incident were removed but not sent in for analysis until nursday, January 25. Results were received on February 19,1968 by the AEC and the report from the vendor (Radiation Detection Company, Mountain View, California) inspected on Februar 96(.

b i Mhadge revealed a dose of 110 mrem, all neutrons, whil badge showed 100 mrem neutron. A copy of this repon is attached (Exhibit H). see As required by 10 CFR 20.405(h), notice to the employees involved in the incident on February 21,1968. Copies of thme nn ces are attact ed ( ft I).,.

l ) I i Medical Evaluation,9 42.. At the request of the Director, Region V, Dr. Kenneth R. McCormack, Chief of the Nuclear Medicine Section, Mount Zion 110m 'tal, San Francisco, acted as medical consultant in the case. Dr. McCorm..k was present at the licensee's facility on January 24 and on January 25 conferred with the licensee's physician, Dr. William J. Oncal of the Los Angeles Tumor Institute, who is 4 treating the exposed individuals. Dr. McCormack has furnished a preliminary report to the AEC (Exhibit ]), and furnished written advice to Dr. Oneal (Exhibit K). Publicity

43. Mr. Rodney S. Southwick, Assistant to the Manager for Public Information, SAN, was at the facility on January 24 and 2

'nd arranged with J. C. Brantley, ICN Vice Pusident, for the preparation of.: news release on the incident. De release was made to the Burbank Daily Review and the Glendale Press e on January 26, 1968. One article appeared in the Burbank Daily Review on January 26,1968 (Exhibit L). Discussions with Manacement

44. %roughout the investigation and subsequen sia reto, there were and have been discussions with licensec's management. In the first phase of the investigation, these persons were J. C. Drantley, Vice President, International Chemical and Nuclear Corporation, and Richard M. Fallis, General Director. Chemical and Radioisotopes Division, ICN On January 24, Mr. Fallis was first informed of the requirement to report the incident which, as evident at the time the incident occurred, should have been donc at most within 24 hours. He was told he should submit an immediate report to AEC stating his plans to make a competent evaluation of the contamination to the facility and exposure to personnel, and that he should stop operations at the facility until it was decontaminated and surveys confirming safe limits had been performed by AEC. Fallis stated he concurred and subsequently submitted a report by telegram dated January 24. A responding telegram from AEC Compliance Division of the same date confirmed salient points omitted from the licensee's telegram (Exhibit M). In subsequent discussions during the decontamination phase of the AEC operations at the facility, an inventory of plutonium material on hand was obtained from the licensee (Exhibit N), it lists plutonium metal received in excess to the 12 pellets for which authorization was originally applied for, and it indicates sources have been or were intended to be febricated for three customers other than Westinghouse. His information reinforces that found during the investigation as to the use of material not authorized by ths licensee.

45. Mr. James Heacock, State Division of Industrial Safety, also held a discussion on January 26 with Messrs. Brantley and Fallis at which the AEC investigators were present upon request of Mr. Heacock. Mr. Heacock advised Brantley and Fallis that the California State licensed operations at the facility would have to be terminated until further notice because of the general contamination.

Heacock stated the licensee could do this voluntarily but, if not, a " cease and desist" order would be issued. The licensee stated it would cease operations 4 until decontamination was completed. His was confirmed by State letter of Jaruary 26,1968 (Exhibit O).

46. At the conclusion of the investigation on the afternoon of January 30,1968, a discussion of the results of the investigation was held in the office of Mr. Milan Panic, President, International Chemical and Nuclear Corporation, with Mr. Panic present, as well as Messrs. Fallis, Harwood, Heacock, Dr. R. C. Koch, assistant to Mr. Panic, and the two AEC investigators.

Mr. Panic was informed of the items of noncompliance as determined from the investigation. After considerable discussion on each point, Mr. Panic stated that he recognized their applicability and that corrective action had been or would be tagen. Subsequent to the investigation, upon review of the licensee's application letter of March 22,1967, the f act that the licensee's administrative procedures furnished with that letter had not been followed, at least in respect to isotope committee review and the specific responsibilities of the corporate RSO (George Harwood), was noted and the citntion for procedure was added' in the violations of license untlitions. Mr. Fallis was informed of this item W a subsequent telephone call. Attachmmtwl j Exhthits A. O .I1

I INDEX OF EXHIBPrS_ ' PURCilASE ORDER lM' 't SOURCES FOR Tile NAVY A-PURCil ASII ORDHH FOlt 7 SMALLER SOURCES D SKETCil OF SMALL SOURCE C 2 RADIOGRAPillC TEST RI'.I' ORT D PHCTPOGRAPils E i' F PLOrP PLAN OF CONTAMINATION (Annexes A B C, and D) ENVIRONMENTAL RESULTS G FILM BADGE REPORT H WHOLE DODY COUNTS I MEDICAL REPORT - J MEDICAL ADVICE TO LICENSEE PHYSICIAN K 3 NEWS STORY L LICENSEE *S REPORT M PLUTONIUM INVENTORY N STATE LETPER TO LICENSEE O 4 ? e 5 4 6 4 ) a e

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UNIT PRICE TUIAL CON 1RMING VERDAL, MR. W. J. DRADLEY, 3/23/67 00 NOT D.UPLICATE 6 SETS PLUTONIUM-CERYLLlUN NEUTRON SOURCES IN ACCORDANCE WITH THE SPECIFICATIONS AND REQUIREMENTS OF THE ATTACHED PAGES 2 THRU 15 WESTING 110VSE FORMS 73850C AND 73049C APPLY TO THIS ORDER. WESTING 110USE BETTIS AND GOVERNMENT INSPECTION REQUIRED AT PLAC OF MANUFACTURE. MIL 0-9050, AS SUP?LEMENTED CY QRC-02C, AND THE MANUAL For. SOURCE INSPECTION AND AOMlHISTRAT10N OF NAVY PROCUR (MAVEXOS-P-1034, APPENDIX A) IS HERE0Y IUCCRPORATED !!! AND PART OF TMIS ORDER. WESTINGHOUSE DETTIS AND GOVERNMENT INSPECTION IS REQUIRED PRIOR TO SU.!PNINT FROM SUPPLIER'S PLANT. PROMP'iLY NOTIFY THE GOVERNMENT REPRESENTAT1VE WHO NORMALLYUPON REC - SERVICES YOUR. PLANT SO THAT APPROPRI ATE-PLANNING FOR GOVERN INSPECTION CAN DE ACCOMPLISHED. DO E2 APPLIES CERTIFIED FOR DEFENSE USE UNDER DMS REG. #1, FAIR LADOR STANDARDS AMENDMENTS OF 1966 APPLY. }y(f.U;D ? . FORM 73495 K ART. I THRU 53 APPLY ! FORM 73634G APPLIES - APPENDIX l APPLY TO THIS ORDER pV i

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....' Nu'elcar Science Division

.\\ Ib eaanut.4 inarrnali. nut Grenes si & Nucl. ar Corporaaen l rm. a. lowi l*m.i.urpli. I'rna 3 ui.ia 1."dM 1 9, Q C ?.\\,6 Tel:412: 4 4 4000 X'MXXX'X 0 February 16, 1968 p@l3 -Mr.. George Harwood U. S. Nuclear Corporation 801 North Lake Street . Burbank, California 91503 u.

Dear Mr. Harwood:

The following are the results on the environmental samples submitted to Nuc1 car l Science for analysis by U. S. Nuclear: l I Vegetation Samples I NSEC No. Designation Gross Alpha c/g Ash, Gross Beta p c/g Ash i-E8-11-70 A

0. 0

• 2. 6 -

88

• 6

-71 3

0. 0

• 3. 6 39
• 6

-73 D

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• 8 l

-75 F

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• 3. 6 72
• 6

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• 5.4.

204

• 10

-77 H

2. 7

• 4. 5 -

126*8 j. Soil Sample Gross Beta c/g i j NSEC No. Designation Gross Alpha 4 c/g_ i 'E8-11-72 C

3. 3

• 0. 8 6.9
• 0.6

) 4 The smcar sample (NSEC # E8-11-78) dated 1-26-68 contained 280 dpm total iI alpha. We ran an alpha spectruta on the sample with the following results-50% of total - Pu-238 I i ' 27% of total - Po-210 (this figure could include small amount of Pu-238) 13% of total - unidentifiable due to energy degradation. i. I If you have any questions, please do not hesitate to contact me.

i '

Very truly yours, f,, l g. Arnold S.' Levine t' Supervisor of Analytical Services l mli l, I e>wzszr G i

~ A h. r:X E t w : a a J,. n/ g ; T,{., ?,'~n J., f ./Q'.-/...7.**, - > wa v., 4 335 LG AVENUE, MOUNTAIN VIEW, C AllFORNI A 94042. Phone (415) 967-2837 9 D O SIM ETRY REPORT Ma.. DICK COLLINS U. f;. NUCLEAR CORT'. 501 N. LAKE STRE C BU2 DANK, CALIF 0"NIA 91502 jr.,gy p NO CARAON Af oult(D c TO BE FILLED IN SY CLl!NT REPORT PE RIOD ,w f AOM iO, [ ogyg pgogg$$gg %QNT90t NilM8fR N !s nlIA'

> !/ri&.1l l

c5 . / / t I M P L O Y([ NAME o,c, Ont,,) N Treska l Plesels Cd Al O.W.j Pb O X+G 8 N ______J1$1AstJ2 /* O , n2 g l26 ffo /cX' jU Ql 15 gav t-M /::& //6 sJ5 V \\ I l dM / M6% G:w }%t 2 -lr-66 /C$ v 4 l el e ?s Eh /7 Y

AlmEX ? l . February 21, 19u8 I \\ ) '\\p l l l Daar Follouing nro the results of tho wholo body counts taken on 1/25/68 and l 2/5/6o. '* e no Dnto Jsotone hocntien Amount OMPDoc 1-25'-68 Pu Lung Arca 150 to 200 nCi 040 to 1250 l 1-25-60 Co-60 1! hole Dody 160 nCi - 1.6 1-25-63 Cc-137 t!hoic Lody 233 nCi (1 l 2-05-60 Pu Lung Arca 170 to 230 nCi 1000 to 1435 l -count) ~ '2-05-68 Co-60 tlhoic Dody 72 nCi C1 i 2-05-68 Cs-137 tl holo Body 210 nCi <3 Detection Limit is 10 nCi

• • Neximun permissibic ' burden for location listed i

f This.eport is furnished to you under the provisions of the Atomic Energy {. ' Conr.:ission regulations entitlod " Standards for Protection Against Radiatio :" (10 CFR Part 20). You should proscrvo.this roport for futuro rcrcrenco. j j Vory truly yours, t l U. S. NUCLEAR CORPORATION i 1 j g 1 l I hj ~$ upm Goorgo E. liarwood Gonoral Managor l l l C211t dk I l 1 1 e a 0 Y c0 s-TX4.'L~d/ 7 Z

6 9 4 1 February 21, 1908 Following arc the results of the whole body counts taken on 1-29-68. Nrne D ito Isotonc l.ncation A:, nun t OMPP.' n Uholo Body,10* to 20 nCi '62 to 125 1-29-68 .Pu Lung Arca 581 nCi 1.9 1-29-6S Cs-137 I n Dctcction Linit is 10 nCi '* Macimun permissible burden for location listed i i This report is furnisired to you under the provisions of tho Atonic Energy i Connission regulations entiticd " Standards for Protection Against Radiation" (10 CFR Part 20). You should preservo this roport for futuro re fe rence. i Very truly yours, U. S. NUCLEAR CORPORATION f I ) n l/. ,.. L.:- r. ( . - u/ /9..uvor/ [ l Georno E. Ilarwood - 1 General.Managor i 1 Cell:dk i 1 1

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e Fo'oruary 21, 1968 Following are the rosults' of the whole body counts taken on 1/25/63.! N n ec_ Date Isotonc _I.$ cation Anount OMPD * * ' 1-25-68 Pu Lung Arca 10 nCi* 62 i 1-25-68 Co-60 t.'holc Body ISS nCi ,1 l 1-25-68 Cs-137 ?! hole Body 248 nCi ', 1 Detection Limit is 10 nCi

• • Sfaximum permissibic burden for location listed l

This report is furnished to you under the provisions of the Atomic Energy .l Comnission regulations entitled " Standards for Protection Against Radiation" (10 CFR Part 20). You should proscrvo this report for futurc I rc:cronco. l Very truly yours, i U. S. NUCLEAR CORPORATION l l /.- Ln e. jv%c li. t:larwood ~~ ~~ Cc . I General Manager l-j Cell:dk I i i Av i -u w gy Ewagir Z

4 February 21, 1968 l Following are the results of the whole body counts taken on 1/20/68. N nr.c 'I)at e Isotone Location _ Anount tMPBa* ~ 1-20-68 Pu Lung Arca 2 10 nCi* < 62! 1-29-68 Cs-137 Ilhole Body 18 nCi , 1l Dotoction Linit is 10 nCi

• • Maxiraun permissibic b rden for location listed This report is furnished to you under the provisions of the Atonic Energy Connission ronulations entitled " Standards for Protection Against Dadiation" (10 CFR Part 20).

You should preservo this roport for futuro reference. i Very truly yours; i U. S. NUCLEAR CORPORATION ] ~ g / k ;.. p re- )Coorge U. Ilarwood ~~ ~~ Conorni Manager C' ll:dk l d I H n (e) ' E N R G /7' Z~ .. _...}}