Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

A FOCUSED REVIEW OF THE NIOSH SEC EVALUATION 

REPORT FOR GRAND JUNCTION OPERATIONS OFFICE, 

ADDENDUM TO PETITION SEC-00175 

Contract No. 211-2014-58081

SCA-TR-2016-SEC006, Revision 0

Prepared by 

Douglas Farver, CHP 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

May 2016 

DISCLAIMER 

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation & 

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE:

A Focused Review of the NIOSH SEC Evaluation Report for Grand

Junction Operations Office, Addendum to Petition SEC-00175

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SEC006

REVISION NO.: 0

SUPERSEDES: N/A

EFFECTIVE DATE: May 17, 2016

TASK MANAGER: John Stiver, MS, CHP [signature on file]

PROJECT MANAGER: John Stiver

DOCUMENT 

REVIEWER(S):

John Stiver

U. Hans Behling, PhD, MPH [signature on file]

Record of Revisions 

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 05/17/2016 Initial issue
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TABLE OF CONTENTS 

Abbreviations and Acronyms ............................................................................................................4

1.0 Background and Statement of Purpose ..................................................................................6

1.1 Relevant Background Information.............................................................................7

1.1.1 Overview of Facility History .........................................................................7

1.1.2 Review of SEC-00175 ...................................................................................7

1.1.3 Review of SCA-TR-PR2015-0093 ................................................................8

2.0 Summary of Issues Raised in SEC Petiton-00175 Addendum ..............................................11

2.1 Review of External Dosimetry Data .........................................................................12

2.1.1 External Dosimetry ........................................................................................12

2.1.2 Occupational Medical Dose ...........................................................................13

2.2 Review of Internal Dosimetry Data ...........................................................................13

2.2.1 Radon .............................................................................................................13

2.2.2 Air Monitoring Data ......................................................................................13

2.2.3 Internal Dose to Unmonitored Workers .........................................................16

2.2.4 Bounding Internal Doses................................................................................22

3.0 Summary of Findings and Concerns ......................................................................................30

4.0 References ..............................................................................................................................31

LIST OF TABLES 

Table 1-1. SEC-00175 ER Feasibility Findings ............................................................................. 8

Table 2-1. Addendum to SEC-00175 ER Feasibility Findings..................................................... 12

Table 2-2. GJOO Air Monitoring Data ......................................................................................... 13

Table 2-3. Available Bioassay Data .............................................................................................. 17

Table 2-4. Air Monitoring Data for the Sample Preparation Laboratory – Air Concentrations 

(μCi/m3) ........................................................................................................................................ 26

Table 2-5. Air Monitoring Results After 1990 ............................................................................. 27
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ABBREVIATIONS AND ACRONYMS 

AEC Atomic Energy Commission 

AEDE annual effective dose equivalent 

Advisory Board Advisory Board on Radiation and Worker Health 

AL annual limit 

ALI annual limit on intake 

Bi bismuth 

BZ breathing zone 

DAC derived air concentration 

D&D decontamination and decommissioning 

DCAS Division of Compensation Analysis and Support 

d/m/m3 disintegration per minute per cubic meter 

DOE U.S. Department of Energy 

DR dose reconstruction 

ER evaluation report

GA general area 

GJ Grand Junction 

GJOO Grand Junction Operations Office 

INEL Idaho National Engineering Laboratory 

INL Idaho National Laboratory 

IVC independent verification contractor 

μCi/ml microcurie per milliliter

μg/m3 microgram per cubic meter 

m3 cubic meter 

mg/l milligram per liter 

mg/m3 milligrams per cubic meter 

MPC maximum permissible concentration 

mrem millirem 

NIOSH National Institute for Occupational Safety and Health 

NYOO New York Operations Office 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 
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ORAUT Oak Ridge Associated Universities Team 

Pb lead

pCi/l picocurie per liter 

pCi/mg picocurie per milligram 

PER program evaluation report 

Po polonium 

PRSC Procedures Review Subcommittee 

Pu/Am plutonium/americium 

Ra radium 

RDC radon-daughter-concentration 

rem roentgen equivalent man 

RI/FS remedial investigation/feasibility study 

Rn radon

ROD Record of Decision 

RP reference point 

RWP Radiation Work Permit 

SEC Special Exposure Cohort 

SRDB Site Research Database 

Th thorium 

U uranium 

U3O8 triuranium octaoxide 

WL working level 
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1.0 BACKGROUND AND STATEMENT OF PURPOSE 

On April 29, 2011, the Secretary of Health and Human Services designated a Special Exposure 

Cohort (SEC) for workers at the Grand Junction Operations Office (GJOO) (NIOSH 2011). The 

SEC designation was based on the following deficiencies/limitations: 

 The National Institute for Occupational Safety and Health (NIOSH) determined that there 

are insufficient personnel monitoring, workplace monitoring, or source term data to 

estimate unmonitored external exposures for the period March 23, 1943, through 

December 31, 1959. 

 NIOSH determined that there are insufficient data to reconstruct internal doses from all 

potential sources (inclusive of radon) during the period from March 23, 1943, through 

January 31, 1975. 

No technical basis document has been developed for dose reconstructions (DRs) of workers at 

the GJOO. However, a “template” had been developed that contains the GJOO site- specific 

information and guidance in order to assess claimant exposures (hereafter referred to as the “DR 

template”). During NIOSH’s evaluation of the GJOO SEC petition, a substantial body of new 

information was discovered with the potential for significant impacts on previously completed 

DRs. The availability of new data for DR required the original DR template to be revised on 

September 5, 2012, and the subsequent issuance of DCAS-PER-047 (DCAS 2014) on March 26, 

2014, in order to evaluate the effect of these revisions on previous DRs. 

During a teleconference meeting by the Procedures Review Subcommittee (PRSC) of the 

Advisory Board on Radiation and Worker Health (hereafter referred to as the “Advisory Board”)

on August 28, 2014, SC&A was tasked to conduct a review of DCAS-PER-047 (DCAS 2014).

The SC&A report, A Review of NIOSH’s Program Evaluation Report DCAS-PER-047, Grand 

Junction Operations Office, SCA-TR-PR2015-0093, Revision 01, was issued on February 10, 

2015, and contained four findings. Two findings were resolved at the April 28, 2015, meeting of 

the PRSC. Findings 3 and 4 have yet to be resolved. 

On March 15, 2015, NIOSH issued an addendum to the SEC-00175 evaluation report (ER) 

(NIOSH 2015) addressing the time period from February 1, 1975, through July 31, 2010. On 

March 25, 2015, the Advisory Board approved the SEC-00175 ER addendum and tasked SC&A 

to review the addendum and available documentation, focusing on two issues: 

1. Appropriateness of the revised SEC time period 

2. Appropriateness of the air monitoring and bioassay data 

This report summarizes the issues addressed in the original SEC-00175 ER (NIOSH 2011) and 

SCA-TR-PR2015-0093 (SC&A 2015) and evaluates the changes identified in the addendum 

(NIOSH 2015). 
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1.1 RELEVANT BACKGROUND INFORMATION 

1.1.1 Overview of Facility History 

Between 1943 and 1946, the Manhattan Engineering District acquired the Grand Junction site in 

order to concentrate triuranium octaoxide (U3O8) from “green sludge,” which was considered a 

byproduct of vanadium production. Subsequently, in 1947, the U.S. Atomic Energy Commission 

(AEC) established a domestic uranium procurement program that was responsible for the receipt, 

sampling, and analysis of uranium (and vanadium) concentrates purchased from domestic ore 

processing operations until 1974. 

From 1974 to 1984, the GJOO supported the National Uranium Resource Evaluation Program in 

the preparation of samples prior to analysis. Sample preparation activities, which included 

crushing, sizing, and blending, posed the greatest potential for internal exposure. 

Other activities included cleanup under the Uranium Mill Tailing Remedial Action program 

starting in 1978, and the Grand Junction Remedial Action Program, involving 600 vicinity 

offsite properties from 1972 to 1988. However, offsite soil samples were prepared and analyzed 

in onsite facilities. By 2001, remediation that included onsite buildings had been completed and 

the facility had been approved for unrestricted use, but it remains under the U.S. Department of 

Energy’s (DOE’s) purview to this day.

1.1.2 Review of SEC-00175 

On January 11, 2011, NIOSH submitted the SEC ER for SEC-00175 to the Advisory Board. In 

that report, NIOSH determined that (1) there are insufficient personnel monitoring, workplace 

monitoring, or source term data to estimate unmonitored external exposures for the period March 

23, 1943, through December 31, 1959; and (2) that there is insufficient information to 

reconstruct internal doses from all potential sources (inclusive of radon) during the period from 

March 23, 1943, through January 31, 1975. 

The SEC period end date of January 31, 1975, was established because of a lack of radon data 

for reconstructing internal dose during the period of sampling operations. By February 1, 1975, 

sampling operations had ended and the large quantities of uranium concentrate were removed 

from the site. NIOSH determined there are sufficient data to reconstruct internal dose for the 

period from February 1, 1975, through July 31, 2010. However, NIOSH also concluded that 

external exposures cannot be estimated for March 23, 1943, through December 31, 1959,

because sufficient data were not found to bound external doses prior to 1960. However, there are 

sufficient data to reconstruct external dose for the period from January 1, 1960, through July 31, 

2010.

Table 1-1 summarizes the results of the SEC-00175 ER feasibility findings.
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Table 1-1. SEC-00175 ER Feasibility Findings 

Source of Exposure 

March 23, 1943, through 

January 31, 1975 

February 1, 1975, through 

July 31, 2010 

Reconstruction 

Feasible 

Reconstruction 

Not Feasible 

Reconstruction 

Feasible 

Reconstruction 

Not Feasible 

Internal — X X —

– Radon — X X —

External X 

(Jan. 1, 1960 

through 

Jan. 31, 1975) 

X 

(Mar. 23, 1943 

through 

Dec. 31, 1959) 

X —

– Gamma X X X —

– Beta X X X —

– Neutron X N/A X —

– Occupational Medical

X-ray X 

(Mar. 23, 1943 

through 

Jan. 31, 1975) 

— X —

1.1.3 Review of SCA-TR-PR2015-0093

During a teleconference meeting by the Advisory Board’s PRSC on August 28, 2014, SC&A 

was tasked by the Advisory Board to conduct a review of DCAS-PER-047, Grand Junction 

Operations Office (DCAS 2014). 

DCAS-PER-047 states: 

No Technical Basis Document exists for Grand Junction Operations Office 

(GJOO) claims. However, a template has been used as guidance to complete 

claims. During the evaluation of a Special Exposure Cohort petition, additional 

information was discovered that required a change to the template. The template 

was edited on 9/5/2012 to incorporate the additional information. This PER is 

intended to evaluate the effect of these changes on previous dose reconstructions. 

Subtask 2 of the SC&A report pertains to a review of the external doses, internal doses, and other 

information from the SEC-00175 ER that was used in the revised DR template. 

External Dose 

During the preparation of the SEC-00175 ER, NIOSH discovered a data report provided by the 

Idaho National Laboratory (INL), which contained more than 15,000 records of external 

monitoring data of GJOO workers for the period 1982 to 1998. These records identify gamma 

(penetrating) doses and the contribution of the beta dose to the skin. Records also include a 
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limited number of workers who were assessed for neutron exposures in the early years, but 

whose numbers increased in later years. 

SC&A reviewed the dosimetry data and assumptions used to determine the external deep, 

shallow, and neutron doses to unmonitored workers at GJOO for the time period beginning in 

1960 through the end of the SEC period. The SC&A (2015) report identified two findings 

regarding the external dose data. Both findings were resolved during the PRSC meeting on 

April 28, 2015. 

Occupational Medical Dose 

NIOSH determined it was feasible to bound the occupational medical dose to workers at GJOO 

for the entire SEC time period from March 1943 through July 2010. SC&A reviewed the revised 

DR template and raised an observation about the wording in the template of the guidance for the 

assignment of medical x-rays (SC&A 2015). This issue was discussed at the April 28, 2015,

PRSC meeting and resolved. 

Air Monitoring 

SC&A reviewed the available air monitoring data and how they were used in the DR template. 

Air sampling was performed in the Sample Plant during July 1980 while ore samples were being 

prepared. The most concentrated sample contained 0.0046 milligrams per cubic meter (mg/m3) 

of uranium. This result is used by NIOSH to assess unmonitored intakes during sample 

preparation from 1975 to 1984. 

In 1986, time-weighted exposures for the first quarter were calculated in terms of maximum 

permissible concentration (MPC)-hours for individuals performing grinding operations of 

uranium mill tailings in the sample preparation laboratory. The exposure in MPC-hours was 

documented for the highest-exposed individual. For the period 1985–2003, intake values were 

based on time-weighted MPC-hours exposure to the highest exposed individual. The assigned 

MPC-hours exposure was conservatively assumed to represent thorium-230 (Th-230). 

In addition, NIOSH states that 569 air sample measurements were recovered for onsite 

decontamination and decommissioning (D&D) work, including both general area and breathing 

zone samples. These samples are to be used to assign doses to D&D workers and others if 

individual bioassay results are not available. 

SC&A reviewed and verified the 1980 air sample result and the 1986 documented time-weighted 

MPC-hours exposure result. However, no reference was initially provided that identifies the 

source document for the 569 air samples. Although NIOSH later provided multiple references to 

SC&A, SC&A still has a concern about implementation; that is, how the dose reconstructor will 

use the air sample information in lieu of bioassay results. This issue, identified as Finding 3 in 

SC&A 2015, was discussed at the April 28, 2015, PRSC meeting and remains open. 

Radon 

SC&A reviewed the radon concentrations/exposures cited in the DR template and found that the 

template does not identify these studies in its Reference List. Upon request, NIOSH then 
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provided additional information in support of the radon data. SC&A reviewed the additional 

information and concurs with radon exposure estimates cited in the revised GJOO DR template.

Internal Doses for Unmonitored Workers 

The internal dose assessments are divided into two areas: sample preparation and D&D. Sample 

preparation is further divided into two time periods; 1975–1984 and 1985–2003. 

Sample preparation internal exposures from 1975 to 1984 are based on the 1980 air sample result 

of 0.0046 mg/m3of uranium. The internal exposures from 1985 to 2003 are based on the 1986 

documented time-weighted MPC-hours exposure result. SC&A was able to verify the internal 

exposure calculations from 1985 to 2003. However, during their derivation of intake rates for 

radium-226 (Ra-226) and Th-230, SC&A determined that NIOSH failed to employ activity 

fractions cited in the DR template. Identified as Finding 4 in SC&A 2015, this issue was 

discussed at the April 28, 2015, PRSC meeting and is in abeyance. 

Unmonitored exposures from D&D activities that occurred from 1989 to 2006 are based on the 

previously described 569 air sample measurements that NIOSH recovered for onsite D&D. This 

issue is related to Finding 3 and, as such, SC&A was unable to verify the internal exposure 

calculations for this time period. 
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2.0 SUMMARY OF ISSUES RAISED IN SEC PETITON-00175 

ADDENDUM 

NIOSH concluded in its initial SEC-00175 ER (NIOSH 2011) that internal dose reconstruction 

was likely feasible for the period from February 1, 1975, through July 31, 2010, and that external 

dose reconstruction was likely feasible for the period from January 1, 1960, through July 31, 

2010. NIOSH also found it likely feasible to reconstruct occupational medical dose for the GJOO 

workers with sufficient accuracy from March 23, 1943, through July 31, 2010. 

During its presentation of the initial SEC-00175 ER (NIOSH 2011) to the Advisory Board, 

NIOSH indicated that it had recently received additional data that were pertinent to the post-1975 

period at Grand Junction, which had not yet been fully evaluated. At that time, NIOSH indicated 

that it would continue its evaluation of the post-1975 period and include its findings in a revision 

to the SEC-00175 ER, or in the issuance of an addendum. 

NIOSH prepared an addendum to SEC-00175, dated March 12, 2015 (NIOSH 2015). The 

NIOSH dose reconstruction feasibility findings contained in that addendum are based on the 

following: 

 Principal sources of internal radiation dose for members of the evaluated class included 

exposures to natural uranium and thorium and their decay products. The modes of 

exposure were inhalation and ingestion during the processing of ores or ore concentrates, 

or during the subsequent resuspension of these materials. 

 In this current evaluation, NIOSH has determined that there are insufficient data available 

to bound intakes of uranium, thorium, and their associated long-lived progeny, for the 

period from February 1, 1975, through December 31, 1985. Although sampling 

operations had ended by February 1, 1975, and the large quantities of uranium 

concentrate (the major source of radon emissions) had been removed from the site, 

NIOSH has determined that smaller-scale operations involving crushing and grinding of 

uranium and thorium ores continued at least through 1988. Operations in the Sample 

Plant involving high-grade uranium and thorium ores, particularly the crushing and 

grinding operations, were a potential source of internal exposures. NIOSH has now 

concluded that there are insufficient internal dosimetry data or air monitoring data 

available to estimate uranium or thorium intakes prior to 1986. Beginning in the first 

quarter of 1986, air monitoring data are available that are sufficient to bound intakes of 

uranium and thorium until the site internal dosimetry program was fully implemented by 

1991. 

 Based on the lack of internal dose monitoring data or air monitoring data for GJOO 

workers during the period from February 1, 1975, through December 31, 1985, NIOSH 

has determined that sufficiently accurate internal dose reconstruction is not feasible. 

However, NIOSH has identified sufficient information and data to support bounding 

internal dose estimates for the period from January 1, 1986, through July 31, 2010, using 

available air monitoring and bioassay data. 
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 NIOSH finds that it is likely feasible to reconstruct dose from radon for the GJOO

workers with sufficient accuracy from February 1, 1975, through July 31, 2010.

 NIOSH finds that it is likely feasible to reconstruct occupational medical dose for the

GJOO workers with sufficient accuracy from February 1, 1975, through July 31, 2010.

 NIOSH finds that it is likely feasible to reconstruct external dose for the GJOO workers

with sufficient accuracy from February 1, 1975, through July 31, 2010.

Table 2-1 summarizes the results of the SEC-00175 ER addendum (NIOSH 2015) feasibility 

findings.

Table 2-1. Addendum to SEC-00175 ER Feasibility Findings 

Source of Exposure

February 1, 1975, through

December 31, 1985

January 1, 1986, through

July 31, 2010

Reconstruction 

Feasible

Reconstruction 

Not Feasible

Reconstruction 

Feasible

Reconstruction 

Not Feasible

Internal — X X —

– Radon X — X —

– Thorium and

Uranium (and their

associated long-lived

progeny)

— X X

External X — X —

– Gamma X — X —

– Beta X — X —

– Neutron X — X —

– Occupational

Medical X-ray

X — X —

2.1 REVIEW OF EXTERNAL DOSIMETRY DATA 

2.1.1 External Dosimetry 

Exposure records are maintained at the Grand Junction office and in a database maintained by 

INL. Since the issuance of the initial SEC-00175 ER (NIOSH 2011), a data report was provided 

by INL that includes personnel believed to be associated with Grand Junction through the use of 

INL location codes. The dosimetry report has data between the years 1982 and 1998 and contains 

over 15,000 records, each with a gamma and beta result and occasional neutron results. 

NIOSH has determined it is feasible to reconstruct external dose for the GJOO workers with 

sufficient accuracy from February 1, 1975, through July 31, 2010. This is the same as NIOSH’s 

feasibility determination described in the original SEC-00175 ER (NIOSH 2011) as shown in 

Table 1-1.
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SC&A reviewed the unmonitored external dose assessment in SCA-TR-PR2015-0093 (SC&A 

2015) and concurs with NIOSH’s feasibility determination.

2.1.2 Occupational Medical Dose 

NIOSH finds that it is likely feasible to reconstruct occupational medical dose for the GJOO 

workers with sufficient accuracy from February 1, 1975, through July 31, 2010. This also is the 

same as NIOSH’s feasibility determination described in the original SEC-00175 ER (NIOSH 

2011) as shown in Table 1-1. 

SC&A reviewed the occupational medical dose assessment in SCA-TR-PR2015-0093 (SC&A 

2015) and concurs with NIOSH’s feasibility determination.

2.2 REVIEW OF INTERNAL DOSIMETRY DATA 

2.2.1 Radon 

NIOSH finds that it is likely feasible to reconstruct dose from radon with sufficient accuracy 

from February 1, 1975, through July 31, 2010. This is the same as NIOSH’s feasibility 

determination described in the original SEC-00175 ER (NIOSH 2011) as shown in Table 1-1.

SC&A reviewed the unmonitored radon dose assessment in SCA-TR-PR2015-0093 (SC&A 

2015) and concurs with NIOSH’s feasibility determination.

2.2.2 Air Monitoring Data 

Table 2-2 shows the air monitoring data captured by NIOSH (2011). As noted in SCA-TRPR2015-0093 (SC&A 2015), prior to 1989, air samples generally lacked information about 

location. Between 1945 and 1961, the results were generally particulate samples counted for 

gross alpha, which was then interpreted as uranium. For the 1960s, only radon or radon daughter 

results are available. In 1986, time-weighted exposures for the first quarter were calculated in 

terms of MPC-hours for individuals performing grinding operations of uranium mill tailings in 

the sample preparation laboratory. Beginning in 1989, there are numerous air sample 

measurements for onsite D&D work, including both general area (GA) and breathing zone (BZ) 

samples.

Table 2-2. GJOO Air Monitoring Data 

Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1945 3 GJ Mill (Refinery) 16855 All results below 25 μg/m3; collected in Jun 

1945 3 GJ Warehouse Area 16855 2 results above 25 μg/m3

1945 2 Sampling Lab 16855 All results below 25 μg/m3 

1953 10 American Cyanamid 6650

Samples taken in May, Jul, and Aug. 3 

samples in May are in terms of alpha 

counts/m3. 

1954 1 American Cyanamid 6650 Sample from Jun 

1956 64 Lucius Pitkin 3307, 3397 Results appear to be GA; Jun and Sep; some 

are BZ samples 
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Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1956 6 Lucius Pitkin 3307, 3397 Results appear to be Ra; Ra analysis on some 

GA samples 

1956 3 Lucius Pitkin 3337

Report in July of “high” air samples in auger 

sampling room; no concentrations given in 

this report but probably are those used for 

comparison with 1959 samples in 3343. 

1956 See Notes Lucius Pitkin 3393

Report not attached. Summarized as “In the 

initial sampling room the air samples were 

between 200 and 400 d/p/m3. In the blender 

room they were of the order of 2,000.”

Probably included in 3307/3397. 

1956 See Notes National Lead 3382

Report not attached. Summarized as “of the 

79 employees who were studied, all but 

[Redacted per Privacy Act] had exposures 

which were less than 50 d/m/m3. Only 

[Redacted per Privacy Act] of the remaining 

[Redacted per Privacy Act] had a really 

significant exposure. [Redacted per Privacy 

Act] was exposed to uranium dust in a 

concentration of approximately 250 mg/m3 

(350 d/m/m3).”

1956 79 National Lead 10241 Samples from Jul and Sep 

1957 25 National Lead 10241 Samples from Apr and Sep 

1959 14 Lucius Pitkin 3307, 3397 Results appear to be GA; Nov 

1959 3 Lucius Pitkin 3343

22 samples taken in Aug by Grand Junction. 

Only three results were reported by NYOO in 

terms of concentrations 

1959 22 Sampling Plant, Lucius Pitkin 11452 Samples from Aug 

1960 28 Falling Stream Pilot Plant, 

Lucius Pitkin 3307, 3397 Results appear to be GA; Jun and Jul 

1960 41 Grand Junction (general) 11452 Samples from Jun and Jul - Outside areas 

(environmental-type) 

1961 12 Grand Junction (general) 11452 Samples from Nov - Outside areas 

(environmental-type)

1961 80 Sampling Plant, Lucius-Pitkin 3307, 3397 Results appear to be GA; Jun (most) and Sep 

1967 5

Grand Junction AEC 

Compound 17031 Rn-222 levels in pCi/l; Jul, Sep, Oct, and Nov; included in 17034 

1967 7

Grand Junction AEC 

Compound 17034 Rn-222 levels in pCi/l; Jul, Sep, Oct, Nov, and Dec 

1967 16 Grand Junction (general) 82790

Radon levels in GJ area 1967-1968; 16 

measurements are for one station in or near 

the AEC compound. 

1968 9 Grand Junction (general) 17034 Rn-222 levels in pCi/l; Jan, Feb, Mar, Apr, 

Jun, and Aug 

1986 See Notes Grand Junction (general) 90851

Annual Environmental Report with 

particulate monitoring results for three 

stations. 
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Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1986 See Notes Grand Junction (general) 29855

Statement that there are “no significant 

radionuclide emissions from GJPO facilities 

including the laboratories, sample 

preparation facility, and the radon chamber.”

1986 300 Grand Junction (in doors) 6640

100 radon-daughter-concentration (RDC) 

measurements in each of Bldgs. 33, 34, and 

35. RDCs averaged 0.0051, 0.177and, 0.0069 

WL, respectively with 0 percent thoron. 

1986 3 Grand Junction (in doors) 98100

MPC-time weighted exposure for first 

quarter 1986. Measurements taken in sample 

prep lab during time of grinding of uranium 

mill tailings. 

1987 See Notes Grand Junction (general) 90847

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); radon 

monitoring results for three stations. 

1988 See Notes Grand Junction (general) 90846

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); radon 

monitoring results for three stations. 

1989 See Notes Grand Junction (general) 90856

Annual Environmental Report with 

particulate monitoring results for four 

stations (total U, Th-230, Ra-226); radon 

monitoring results for three stations.

1989 569 Grand Junction (general) 

89872, 89909, 

89926, 89931, 

89938, 89979, 

89991, 90015, 

90087, 90105, 

90118, 90154, 

90155, 90164, 

93709 

Air sample measurements for on-site D&D 

work, post-1988, including both general area 

and breathing zone samples. 

1990 See Notes Grand Junction (general) 90845

Annual Environmental Report with 

particulate monitoring results for four 

stations (total U, Th-230, Ra-226); radon 

monitoring results for three stations. 

1990 1 Grand Junction (general) 37700 Annual atmospheric release of radioactive 

material 

1990 16 Grand Junction (in doors) 100231

Technical basis document for internal 

dosimetry. Includes isotopic air concentration 

measurements for Bldg. 7A Sample Prep 

Laboratory. 

1991 See Notes Grand Junction (general) 90853

Annual Environmental Report with 

particulate monitoring results for four 

stations (total U, Th-230, Ra-226); radon 

monitoring results for eight stations. 
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Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1991 1 Grand Junction (general) 37700 Annual atmospheric release of radioactive 

material 

1991 30 Grand Junction (in doors) 13191 Results of the DOE indoor radon study; 19 

occupied buildings measured. 

1992 See Notes Grand Junction (general) 90860

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); radon 

monitoring results for seven stations. 

1992 1 Grand Junction (general) 37700 Annual atmospheric release of radioactive 

material 

1993 See Notes Grand Junction (general) 90857

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); radon 

monitoring results for seven stations. 

1993 1 Grand Junction (general) 37700 Annual atmospheric release of radioactive 

material 

1994 1 Grand Junction (general) 37700 Annual atmospheric release of radioactive 

material 

1996 1 Grand Junction (general) 76642 Annual atmospheric release of radioactive 

material 

1998 1 Grand Junction (general) 44873 Annual atmospheric release of radioactive 

material

1999 1 Grand Junction (general) 44873 Annual atmospheric release of radioactive 

material 

2000 1 Grand Junction (general) 44873 Annual atmospheric release of radioactive 

material 

2001 1 Grand Junction (general) 44873 Annual atmospheric release of radioactive 

material 

Source: NIOSH 2011. 

After a review of the available air monitoring data, SC&A concludes that the lack of adequate air 

monitoring data prior to 1961 and the absence of air monitoring data from 1962 to 1985 support 

NIOSH’s position that it is not feasible to reconstruct internal doses from February 1, 1975,

through December 31, 1985.

2.2.3 Internal Dose to Unmonitored Workers 

According to the SEC ER addendum (NIOSH 2015), there is no comprehensive database of 

bioassay results for the Grand Junction site. Only a limited number of bioassay results are 

contained in documents captured by NIOSH for the period 1945 through 1999, as shown in 

Table 2-3. NIOSH also found that, while some workers do have bioassay measurements included 

in their records, there are not enough claimants with bioassay information available to indicate 

which workers were routinely included in a bioassay program. 
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Table 2-3. Available Bioassay Data 

Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1945 11 GJ Mill (Refinery) 16855 U in urine, 1 set in Jun 

1949 7 None shown 3306 U in urine, all from Dec. 

1953 11 American Cyanamid 6645 U in urine, 2 sets - Jul and Dec 

1953 4 American Cyanamid 11452 U in urine, 1 set in Dec 

1953 32 American Smelting 3319 U in urine, 3 sets Feb, May, and Sep 

1953 22 American Smelting 11452 U in urine, 2 sets - Feb and May 

1954 10 American Cyanamid 6645 U in urine, 2 sets - Feb and Jul 

1954 10 American Cyanamid 11452 U in urine, 2 sets - Feb and Jul 

1954 24 American Smelting 3319 U in urine, 2 sets - Jan and Nov 

1954 13 American Smelting 11452 U in urine, 2 sets - Jan and May 

1956 66 Lucius Pitkin 3307, 

3397 U in urine; 3 sets - May, Jun, and Oct 

1956 1 None shown 76923 U in urine; result reported Aug 0.009 

mg/l 

1956 1 None shown 76924 U in urine; result reported Jul 0.078 

mg/l 

1956 47 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1957 49 Lucius Pitkin 3307, 

3397 U in urine; 2 sets - May and Oct 

1957 49 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1958 25 Lucius Pitkin 3307, 

3397 U in urine, 1 set - Jun

1958 29 Lucius Pitkin 11451 U in urine, 1 set in Dec 

1958 1 None shown 76938 One "composite" U in urine sample, 

0.016 mg/l from Feb 

1958 1 None shown 76940 U in urine; one sample, 0.032 mg/l 

from Jan 

1958 63 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1959 31 Lucius Pitkin 3307, 

3397 

U in urine, 1 set - Jun; plus 1 Aug 

result 

1959 28 Lucius Pitkin 11451 U in urine, 1 set in Dec 

1959 59 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1960 49 Lucius Pitkin 3307, 

3397 U in urine, 2 sets - Jun and Dec 

1960 49 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1961 57 Lucius Pitkin 3307, 

3397 

U in urine; 2 sets - Jun and Dec; plus 2 

Jan results and 1 Mar result. 

1961 58 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1962 26 Lucius Pitkin 3307, 

3397 U in urine, 1 set - Jun; plus 1 Jan result 

1962 49 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1963 44 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 
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Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1964 See Notes Lucius Pitkin 14442

Annual report for 1964. 8 employees 

sampled in Jul and Dec. One additional 

in Dec. Results were in the range from 

0.008 to 0.021 mg/l, below the 

reference point (RP) of 0.05 mg/l. 

1964 10 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1965 47 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1966 64 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1967 71 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1968 70 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1969 See Notes Lucius Pitkin 13800

Annual report for 1969. In Mar, 23 

samples were collected. All were 

below the reference point of 0.025 

mg/l with 4 exceptions who were resampled. In Oct, 17 samples were 

collected and all were below the RP 

with again 4 exceptions. Re-sampling 

showed 3 of 4 were below. Two 

employees are listed by name with 

results of 0.054 and 0.077 mg/l. 

1969 55 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1970 27 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1971 30 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1972 See Notes Lucius Pitkin 13802

Annual report for 1972. No. of samples 

not given, but all were in the range of 

0.001 to 0.008 mg/l. 

1972 11 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1973 See Notes Lucius Pitkin 13803

Annual report for 1973. No. of samples 

not given, but all were in the range of 

0.001 to 0.056 mg/l. 

1973 52 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11 

1974 14 Lucius Pitkin 98104 Urinalysis Report, collected 5/24/11

1984 1 Bendix 97742 Exposure history for specific 

individual, collected 5/23/11 

1984 1 Bendix 97813 Exposure history for specific 

individual, collected 5/25/11 

1984-

1986 1589 Bendix 98107 Urinalysis Sampling Log, collected 5/24/11 

1986 16 INEL 97808 Bioassay Report for Grand Junction, 

collected 5/21/11 

1986 8 UNC Technical Services 98096 Bioassay Report for Grand Junction, 

collected 5/24/11 

1986 8 INEL 125901 Bioassay Report for Grand Junction, 

collected 5/24/11 

1990 2

Lawrence Livermore 

National Laboratory 97808 Internal Dose Assessments for 1990, collected 5/21/11 
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Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1990 133 Thermo Analytical 97828 Radiological Analysis Results for Ra 

in urine, collected 5/24/11 

1990 109 GeoTech 97828 1990 Bioassay Results, collected 

5/24/11 

1991 8 Thermo Analytical 97828 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97847 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97849 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 6 Thermo Analytical 97851 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 43 Thermo Analytical 97852 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 30 Thermo Analytical 97854 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 30 Thermo Analytical 97856 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 5 Thermo Analytical 97857 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 8 Thermo Analytical 97858 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 1 GeoTech 97637 Exposure history for specific 

individual, collected 5/23/11 

1991 1 GeoTech 97679 Exposure history for specific 

individual, collected 5/23/11 

1991 22 Thermo Analytical 97838 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 18 Thermo Analytical 97839 Radiological Analysis Results in urine, 

collected 5/24/11

1991 11 Thermo Analytical 97842 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 5 Thermo Analytical 97843 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 13 Thermo Analytical 97871 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97878 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 24 Thermo Analytical 97880 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97882 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 65 Thermo Analytical 97883 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97884 Radiological Analysis Results in urine, 

collected 5/24/11 
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Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1991 27 Thermo Analytical 97885 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 20 Thermo Analytical 97886 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 7 Thermo Analytical 97887 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 32 Thermo Analytical 97888 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 1 Thermo Analytical 97889 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 63 Thermo Analytical 97890 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 31 Thermo Analytical 97891 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 24 Thermo Analytical 97892 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 49 Thermo Analytical 97893 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 49 Thermo Analytical 97894 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 49 Thermo Analytical 97895 Radiological Analysis Results in urine, 

collected 5/24/11 

1991 49 Thermo Analytical 98090 Radiological Analysis Results in urine, 

collected 5/24/11 

1991-

1992 139 GeoTech 97763 Radon log in sheets, collected 5/24/11 

1992 15 Chem-Nuclear Geotech 97762, 

97809 

Internal Dose Assessments for 1992, 

collected 5/21/11

1992 7 GeoTech 97792

Memo about bioassay results and 

recommended follow-up testing, 

collected 5/23/11 

1992 28 GeoTech 97784 Evaluation of Uranium Oxide Spill, 

collected 5/23/11 

1992 18 Thermo Analytical 97841 Radiological Analysis Results in urine, 

collected 5/24/11 

1995 12 RUST Geotech 97828

Internal Radiation Dose Assessment 

for Individuals Visiting, collected 

5/24/11 

1995 7 RUST Geotech 90511

7 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U) 

1995 10 RUST Geotech 90512

10 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U, 

Th-230, and Ra-226). 
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Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1995 18 RUST Geotech 90513

18 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U, 

Th-228/230, and Ra-226). 

1995 7 RUST Geotech 90514

7 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis. 4 

Pu/Am and 3 U for 6 personnel (one 

had both) 

1995 10 RUST Geotech 90515

10 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U) 

1995 12 RUST Geotech 90516

12 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U, 

Th-230, and Ra-226) 

1995 10 RUST Geotech 90517

10 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 10/3/95 

1996 11 MACTEC 90528

11 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U) 

1997 12 MACTEC 90528

12 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U) 

1997 9 MACTEC 90508

9 post-job fecal samples collected 5 

days after potential exposure; sent to 

Teledyne Brown Engineering 

Environmental Services for alpha-spec 

analysis (U). Additional urine and 

fecal baseline results on pdf p. 65 

1997 45 MACTEC 90510

45 urine samples sent to LockheedMartin Idaho Lab in 1997. Total U 

results in μg/l. 

1997 10 MACTEC 90523

10 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 1/6/97 

1997 11 MACTEC 90524

11 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 11/12/97

1997 11 MACTEC 90525

11 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 11/12/97 
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Year 

Approx. 

No. of 

Results 

Company/Organization SRDB 

Ref IDs Notes 

1997 9 MACTEC 90526

9 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 11/12/97 

1997 10 MACTEC 90527

10 urine samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 4/1/97 

1997 23 MACTEC 90528

23 fecal samples sent to Teledyne 

Brown Engineering Environmental 

Services for alpha-spec analysis (U), 

collected 11/11/2010 

1998 6 MACTEC 90507

4 urine samples collected in June 1998 

sent to Lockheed Martin Idaho 

Technologies Company Bioassay 

Laboratory for total U as the result of 

an off-site incident (facial 

contamination from windblown 

tailings at Monticello). 2 fecal samples 

collected in September 1998 and 

analyzed for isotopic U following 

demolition work at the GJO site. 

1999 670 MACTEC 90509

Radon personal dosimeter data for 

individuals using Landauer “DRNT” 

detector (track detector). Two quarterly 

periods and one semi-annual period. 

Exposures reported in pCi/l-days. Of 

the total, 24 were area monitors. 

Based on the available bioassay and air monitoring data, NIOSH has determined that the data are 

not sufficient to accurately reconstruct the internal doses during the period from February 1, 

1975, through December 31, 1985. SC&A has reviewed the limited bioassay data available and 

the air monitoring data and agrees the available data are not sufficient to accurately reconstruct 

the internal doses during the period from February 1, 1975, through December 31, 1985. 

2.2.4 Bounding Internal Doses

NIOSH believes there are sufficient data to support bounding internal dose estimates for the 

period from January 1, 1986, through July 31, 2010, using available air monitoring and bioassay 

data.

The time period for the bounding internal dose estimates is divided into pre-1991 and 1991 

forward. Sample preparation activities occurred from 1986 to 1990 and D&D activities from 

1988 to 1990. After 1991, DOE Order 5480.11, Radiation Protection for Occupational Workers, 

was implemented (DOE 1988). The order specifies that bioassay shall be collected if exposure 

indicates that a worker could be exposed to inhalation intake during the year that exceeded 200 

derived air concentration (DAC)-hours and that a monitoring program must be in place for all 

workers who have the potential for 40 DAC-hours. 
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Sample Preparation 

NIOSH determined sample preparation to be the highest onsite exposure potential scenario in the 

post-1985 time period. According to the SEC addendum (NIOSH 2015): 

For the period of time from January 1, 1986 through December 31, 1990, 

bounding daily uranium intake rates for operators and laborers may be assigned 

by assuming that a worker received the MPC-hour limit every quarter. 

Thorium-230 may be assumed to be the limiting radionuclide. The applicable 

limiting MPC for Thorium-230 is 2.00E-12 μCi/mL.

SC&A believes the method proposed by NIOSH to bound the uranium intakes is reasonable and 

adequate. 

NIOSH states that the method for bounding uranium intakes during this time period is also 

appropriate to bound thorium intakes for the same period. The rationale for this conclusion is that 

the controls used for crushing and grinding uranium ore were the same as those used for crushing 

and grinding thorium, and both operations took place in the same facility. 

NIOSH goes on to state: 

Based on interviews (Personal Communication, 2014e; Personal Communication, 

2014g; Personal Communication, 2014h) with former workers, the time required 

to complete the construction of a calibration pad, either uranium or thorium, 

would not exceed a calendar month. The physical crushing and grinding of the 

thorium ore, which is the main source of exposure, would actually have been 

completed in much less time than a full month. For the purpose of bounding 

potential intakes of thorium from these operations a full calendar month of 

exposure to thorium ore is assumed for each operation involving crushing and 

grinding of thorium ore. Laborers and operators may therefore be assumed to be 

exposed to the MPC for a full month for each thorium operation if employed at 

that time. Since the exact dates of the construction of the pads are not known, the 

most claimant-favorable period (first potential month) should be assumed for the 

assignment of the thorium exposure. Thorium progeny should also be assumed to 

also be present, and at the same concentration as Th-232. [emphasis added]

SC&A carefully reviewed the three personal communications cited above. 

One document is an interview with a manager. The other two documents are interviews with the 

supervisor/manager. The supervisor/manager described the sample operations time frame when 

asked: “What were the typical times for the entire process?” (Personal Communication, 2014e) 

The crushing and grinding operation together would take about one week. 

I estimate the times involved for handling the batch materials to be: 

• 5–10 minutes to load 
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• 5–10 minutes to unload 

• 2–3 minutes to add the active material 

It took about 30 minutes to blend a batch inside the V blender. When a model was 

being made, the blending of batches went on for about two weeks. 

So, with crushing/grinding taking about one week, and blending taking about two 

weeks, the preparation of material for a model would average about three weeks. 

The longest campaign (if it was a large model) would have been about one month. 

While SC&A has no reason to doubt the interviewee, we do have one concern. 

Concern 1: 

Both interviewees are management-level employees, not operators or laborers who performed 

the actual work. It would be beneficial to obtain information from the actual workers about work 

conditions and controls to supplement the current information. 

Decontamination/Decommissioning 

According to the SEC addendum (NIOSH 2015): 

Investigations for site remediation began in 1984. The remedial 

investigation/feasibility study (RI/FS) was done in 1989. The Record of Decision 

(ROD) was approved in 1990. The tailings were removed in 1989-1994. A closeout survey by the independent verification contractor (IVC) for the outdoor areas 

of the site was completed in 1995. Additional close-out surveys and verifications 

were done for each building on site that was released for unrestricted use). Each 

close-out report includes a statement about the successful use of health and safety 

practices during the clean-up. In 2001, the site was turned over to a non-profit 

corporation and DOE leased back office and laboratory space. 

Thousands of pages of health and safety data (e.g., RWPs, survey maps, field 

measurements, air samples) have been recently captured for the period 1991–

2007, when most of the D&D activities took place (Building 7 H&S Data, 1991–

2001; Building 11 H&S Data, 1993–1997; Building 12 H&S Data, 1991–2000; 

Building 18 H&S Data, 1991–2001; Building 20 H&S Data, 1990–2000; Building 

26 H&S Data, 1980–1998; Building 28 H&S Data, 1986–2000; Building 29 H&S 

Data, 1997; Building 31/31A H&S Data, 1990–1992; Building 36 H&S Data, 

1992–1996; Health and Safety Checklists, 1990–1991). Some bioassay data have 

also been captured for the period 1995–1999. There is no database of results that 

can readily be used for a co-worker study. However, from these data it is evident 

that the most highly-exposed workers were monitored. If no data are available 

for a D&D worker, the bounding dose scenario can be constructed from the 

health and safety data. For example, Buildings 7 and 7A were used for sample 

preparation and were extensively contaminated. Building 7 was remediated to 

unrestricted area levels and was transferred to the U.S. Army Reserve. 
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Contaminated concrete was removed with a concrete saw and jack-hammer or 

“scabbled” (mechanical removal of a thin layer by a power tool). Walls with 

internal contamination were removed and rebuilt. Health and Safety monitoring 

data are available for these operations (Building 7 H&S Data, 1991–2001; 

Building 7A H&S Data, 1991–--2001; Building 7A H&S Data, 2001; Building 7 

H&S Data – Phase I, 1972–1999; Building 7 H&S Data – Phase II, 1980–2000). 

The bounding dose could then be assigned to other years with less data or lessintrusive work. NIOSH concludes that sufficient data are available to bound doses 

for D&D workers. By extension, these doses would bound workers with jobs 

requiring less exposure to contaminated materials. [emphasis added]

Concern 2: 

SC&A was not tasked to perform a comprehensive data review. As such, it is not clear how the 

“thousands of pages” of health and survey data will be used by the dose reconstructors or what 

guidance will be provided to assess the unmonitored internal dose to a D&D worker with no 

bioassay data. 

DOE Order 5480.11 Implementation 

The 1990 document, Technical Basis for Bioassay Sampling for Sample Preparation Plant and 

Grand Junction Vicinity Property Workers (Geotech 1990), describes the implementation of 

DOE Order 5480.11 for monitoring workers. It states that bioassay will be collected if exposure 

indicates that a worker could be exposed to inhalation intakes during the year that exceeded 200 

DAC-hours. It further states that a monitoring program must be in place for all workers who 

have the potential for 40 DAC-hours. This document was issued in early 1990; NIOSH is 

assuming that full implementation was not in place until the end of 1990. 

SC&A reviewed the bioassay sampling technical basis document prepared by Geotech (1990). It 

describes how the requirements of DOE Order 5480.11 will be implemented. The Executive 

Summary states: 

The interim bioassay program consists of collecting routine urine samples which 

are analyzed for Ra-226. The detection of Ra-226 in urine allows the performance 

standard of the workplace monitoring program (i.e., detection of an intake 

resulting in a dose of 100 mrem committed effective dose equivalent) and the 

individual routine monitoring program (i.e., detection of an intake resulting in a 

dose of 100 mrem annual effective dose equivalent) to be accomplished. The 

program has two components: 1) prospective (workplace) monitoring; and 

2) retrospective (individual worker) monitoring. 

Prospective (workplace) monitoring will consist of air monitoring and urine 

sample collection. Air monitoring will be the primary method of monitoring the 

workplace. Urine samples will be collected from representative workers (i.e., 

workers chosen to represent a particular work environment) every 6 days. This 

will be accomplished by rotating the workers on the routine bioassay program 

such that each individual employee submits a urine sample every 26 days. If the 

air monitoring data or urine samples indicate an intake, all workers in the work 
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environment will be required to submit two follow-up urine or fecal samples.

[emphasis added]

Retrospective (individual worker) monitoring will consist of routine urine sample 

collections from individual workers every 26 days. If the routine urine sample 

indicates an intake, two follow-up fecal samples will be required. In addition, 

urine samples will be required for new hires and radiation workers transferring 

to another facility if they report previous work with the same radionuclides. Urine 

samples will also be required from employees terminating employment. 

Section 4.0 of Geotech 1990 describes the performance capabilities for workplace monitoring 

programs. It states, in part: 

Air monitoring shall be the primary method for monitoring the workplace. 

Bioassay measurements may also be used to support the prospective monitoring 

program but shall not provide the primary bases for monitoring for loss of control 

in the workplace. 

The only workplace air samples SC&A found were the 16 air sample results listed in Table 1 of 

the bioassay sampling technical basis document from the sample preparation laboratory located 

in Building 7 (Geotech 1990). These results are shown in Table 2-4 below. The limiting DAC for 

Th-230 is 3.00E-12 microcurie per milliliter (μCi/ml) or 3.00E-06 microcurie per cubic meter 

(μCi/m3). Two of the 16 air samples exceed the limiting DAC for Th-230. 

Table 2-4. Air Monitoring Data for the Sample Preparation Laboratory –

Air Concentrations (μCi/m3) 

Sample 

ID# Po-210 Ra-226 Th-230 Pb-210 U-238 Bi-210

MDN651 8.10E-07 0.00E+00 9.30E-07 9.30E-07 0.00E+00 9.30E-07

MDN652 2.60E-06 0.00E+00 3.10E-06 3.10E-06 0.00E+00 3.10E-06

MDN653 2.10E-06 2.20E-06 2.40E-06 2.40E-06 0.00E+00 2.40E-06

MDN654 6.40E-07 4.90E-06 6.40E-07 6.40E-07 0.00E+00 6.40E-07

MDN655 5.60E-07 0.00E+00 9.30E-07 9.30E-07 0.00E+00 9.30E-07

MDN656 4.80E-07 0.00E+00 4.80E-07 4.80E-07 0.00E+00 4.80E-07

MDN657 6.80E-07 0.00E+00 9.00E-07 9.00E-07 0.00E+00 9.00E-07

MDN658 5.60E-07 2.10E-06 1.10E-06 1.10E-06 0.00E+00 1.10E-06

MDN659 3.10E-06 7.80E-07 3.10E-06 3.10E-06 0.00E+00 3.10E-06

MDN660 3.20E-07 0.00E+00 4.20E-07 4.20E-07 0.00E+00 4.20E-07

MDN661 0.00E+00 0.00E+00 5.00E-07 5.00E-07 0.00E+00 5.00E-07

MDN662 1.30E-07 0.00E+00 2.60E-07 2.60E-07 2.70E-06 2.60E-07

MDN663 1.70E-07 0.00E+00 5.00E-07 5.00E-07 0.00E+00 5.00E-07

MDN664 5.90E-07 0.00E+00 5.00E-07 5.00E-07 0.00E+00 5.00E-07

MDN665 5.00E-07 0.00E+00 3.40E-07 3.40E-07 0.00E+00 3.40E-07

MDN666 3.50E-07 0.00E+00 2.60E-07 2.60E-07 0.00E+00 2.60E-07

Source: Geotech 1990, Table 1. 

Section 7.0 of the bioassay sampling technical basis document (Geotech 1990) describes how the 

air monitoring and bioassay programs are to demonstrate compliance with DOE Order 5840.11: 
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7.1 Workplace (Prospective) Monitoring Program 

Air monitoring data will be tracked by use of a database program presently 

being developed. This program will track the derived air concentration (DAC) 

values of the air samples, sample location, worker’s present, reductions due to 

respirator use, and the occupancy time. This will allow the determination of the 

need for follow-up bioassay sampling when a worker is suspected of having an 

intake equivalent to 0.02 ALI (40 DAC-h). When the air data indicates a potential 

intake of 0.02 ALs the worker will be required to submit a urine sample which will 

be sent to the TMA/NORCAL for analysis on a rush order. If the follow-up urine 

sample confirms an intake, two (special) bioassay samples will be taken to 

determine the internal dose resulting from the intake. The two follow-up bioassay 

samples shall consist of two urine samples if the time between the suspected 

intake and the follow-up sample collection time is less than 26 days. The two 

follow-up bioassay samples will consist of fecal samples if the time between the 

suspected intake and the follow-up sample collection time is greater than 26 days 

and preferably less than 53 days. This sampling schedule would meet the 

performance standard of follow-up samples detecting intakes at the 100 mrem 

AEDE objective. [emphasis added]

Urine samples will be collected from a representative worker (i.e., a worker 

chosen to represent a particular work environment) every 6 days. If five or more 

workers are involved in the same work environment, individual employee will give 

a sample every 26 days (see section 7.2 routine bioassay) and will be on a 

rotational schedule such that at least one urine sample is received from a 

representative employee every 6 days. If the work environment consists of four 

workers, each employee would be required to supply a urine sample every 24 

days, and the workers will be on a rotational schedule such that one urine sample 

is collected from a worker every 6 days. Air monitoring data will provide the 

basis for the prospective monitoring program for work environments which have 

less than four employees on the bioassay program. 

Table 2-5 contains the available air monitoring information during and after the time period 

when the technical basis for bioassay sampling was implemented. With the exception of the 

workplace air monitoring results contained in the technical basis, no other workplace air 

monitoring results are found. 

Table 2-5. Air Monitoring Results After 1990 

Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1990 See Notes Grand Junction (general) 90845

Annual Environmental Report with 

particulate monitoring results for four 

stations (total U, Th-230, Ra-226); 

radon monitoring results for three 

stations. 
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Year 

Approx. 

No. of 

Results 

Area/Company/Organization SRDB Ref 

IDs Notes 

1990 1 Grand Junction (general) 37700 Annual atmospheric release of

radioactive material 

1990 16 Grand Junction (in doors) 100231

Technical basis document for internal 

dosimetry. Includes isotopic air 

concentration measurements for 

Bldg. 7A Sample Prep Laboratory. 

1991 See Notes Grand Junction (general) 90853

Annual Environmental Report with 

particulate monitoring results for four 

stations (total U, Th-230, Ra-226); 

radon monitoring results for eight 

stations. 

1991 1 Grand Junction (general) 37700 Annual atmospheric release of 

radioactive material 

1991 30 Grand Junction (in doors) 13191

Results of the DOE indoor radon 

study; 19 occupied buildings 

measured. 

1992 See Notes Grand Junction (general) 90860

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); 

radon monitoring results for seven 

stations. 

1992 1 Grand Junction (general) 37700 Annual atmospheric release of 

radioactive material 

1993 See Notes Grand Junction (general) 90857

Annual Environmental Report with 

particulate monitoring results for three 

stations (total U, Th-230, Ra-226); 

radon monitoring results for seven 

stations. 

1993 1 Grand Junction (general) 37700 Annual atmospheric release of 

radioactive material 

1994 1 Grand Junction (general) 37700 Annual atmospheric release of 

radioactive material 

1996 1 Grand Junction (general) 76642 Annual atmospheric release of 

radioactive material 

1998 1 Grand Junction (general) 44873 Annual atmospheric release of 

radioactive material

1999 1 Grand Junction (general) 44873 Annual atmospheric release of 

radioactive material 

2000 1 Grand Junction (general) 44873 Annual atmospheric release of 

radioactive material 

2001 1 Grand Junction (general) 44873 Annual atmospheric release of 

radioactive material 

NIOSH states on page 29 of the ER addendum (NIOSH 2015): 

Therefore, starting in 1991, it is assumed that unmonitored radiation workers 

would not have exceeded 200 DAC-hours in a given year (if they had they would 
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have then been placed on a bioassay program). In addition, it is assumed that 

non-radiation workers would not have exceeded 40 DAC-hours in a given year. 

Finding 1: Workplace air monitoring data do not support the assumption that 

unmonitored radiation workers would not have exceeded 200 DAC-hours or that nonradiation workers would not have exceeded 40 DAC-hours in a given year. 

Although the technical basis document for bioassay programs (Geotech 1990) describes how the 

program should operate to detect intakes resulting in a dose of 100 mrem, no document or 

database was presented containing air monitoring results, sample locations, workers present, etc. 

to demonstrate that the workplace controls described in the technical basis document had 

actually been implemented. SC&A does not believe NIOSH has shown sufficient workplace air 

monitoring data to support its assertion that unmonitored radiation workers would not have 

exceeded 200 DAC-hours or that non-radiation workers would not have exceeded 40 DAC-hours 

in a given year. 
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3.0 SUMMARY OF FINDINGS AND CONCERNS 

SC&A was tasked to review the addendum to the SEC Petition-00175 ER (NIOSH 2015) and 

available documentation focusing on two issues: 

1. Appropriateness of the revised SEC time period 

2. Appropriateness of the air monitoring and bioassay data 

During SC&A’s focused review of the addendum to the SEC Petition-00175 ER, we concluded 

that the revised SEC time period beginning February 1, 1975, through December 31, 1985, is 

appropriate based on the lack of sufficient air monitoring data prior to 1986. 

However, SC&A did identify one finding and two issues of concern regarding the air monitoring 

and bioassay data. 

Finding 1: There are insufficient workplace air monitoring data to support the assumption that 

unmonitored radiation workers would not have exceeded 200 DAC-hours or that non-radiation 

workers would not have exceeded 40 DAC-hours in a given year. 

Concern 1: Both interviewees from the Sample Preparation Laboratory are management-level 

employees and not operators or laborers. It would be beneficial to obtain process and duration 

information from the workers who performed the work to supplement the information provided 

in the interviews. 

Concern 2: SC&A was not tasked to perform a comprehensive data review. As such, it is not 

clear how the “thousands of pages” of health and survey data will be used by the dose 

reconstructors or what guidance will be provided to assess the unmonitored internal dose to a 

D&D worker with no bioassay data. 

Also, SC&A believes it would be beneficial for the Advisory Board to review the DR template 

when it is revised to incorporate the changes proposed in the addendum. 
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4.0 REFERENCES 

Building 7 H&S Data, 1991–2001, Compilation of Building 7 Health and Safety Information and 

Data; various contractors at the Grand Junction Projects Office; various dates in 1991–2001.

[SRDB Ref. ID 89872] 

Building 7 H&S Data - Phase I, 1972–1999, Compilation of Building 7 Phase I Health and 

Safety Information and Data, various contractors at the Grand Junction Projects Office; various 

dates in 1972–1999. [SRDB Ref. ID 90164] 

Building 7 H&S Data - Phase II, 1980–2000, Compilation of Building 7 Phase II Health and 

Safety Information and Data, various contractors at the Grand Junction Projects Office; various 

dates in 1980–2000. [SRDB Ref. ID 90155] 

Building 7A H&S Data, 1991–2001, Compilation of Building 7A Health and Safety Information 

and Data, various contractors at the Grand Junction Projects Office; various dates in 1991–2001.

[SRDB Ref. ID 90118] 

Building 7A H&S Data, 2001, Compilation of Building 7A Health and Safety Information and 

Data, various contractors at the Grand Junction Projects Office; various dates in 2001. [SRDB 

Ref. ID 90154] 

Building 11 H&S Data, 1993–1997, Compilation of Building 11 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1993–1997.

[SRDB Ref. ID 89928] 

Building 12 H&S Data, 1991–2000, Compilation of Building 12 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1991–2000.

[SRDB Ref. ID 89926] 

Building 18 H&S Data, 1991–2001, Compilation of Building 18 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1991–2001.

[SRDB Ref. ID 89931] 

Building 20 H&S Data, 1990–2000, Compilation of Building 20 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1990–2000.

[SRDB Ref. ID 89938] 

Building 26 H&S Data, 1980–1998, Compilation of Building 26 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1980–1998; 

[SRDB Ref. ID 89942] 

Building 28 H&S Data, 1986–2000, Compilation of Building 28 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1986–2000.

[SRDB Ref. ID 89979] 
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Building 29 H&S Data, 1997, Compilation of Building 29 Health and Safety Information and 

Data, various contractors at the Grand Junction Office (GJO); various dates in 1997; [SRDB Ref.

ID 89966] 

Building 31/31A H&S Data, 1990–1992, Compilation of Building 31/31A Health and Safety 

Information and Data, various contractors at the Grand Junction Office (GJO); various dates in 

1990–1992. [SRDB Ref. ID 89991] 

Building 36 H&S Data, 1992–1996, Compilation of Building 36 Health and Safety Information 

and Data, various contractors at the Grand Junction Office (GJO); various dates in 1992–1996.

[SRDB Ref. ID 90015] 

DCAS 2014. Grand Junction Operations Office, DCAS-PER-047, Revision 0, National Institute 

for Occupational Safety and Health, Division of Compensation Analysis and Support, Cincinnati, 

Ohio. March 26, 2014. 

DOE 1988. Radiation Protection for Occupational Workers, DOE Order 5480.11, U.S. 

Department of Energy. December 21, 1998. 

Geotech 1990. Technical Basis for Bioassay Sampling for Sample Preparation Plant and Grand 

Junction Vicinity Property Workers, UNC Geotech. March 1990. [SRDB Ref. ID 100231] 

Health and Safety Checklists, 1990–1991, Collection of Health and Safety Checklists, UNC 

Geotech and Grand Junction Projects Office; various dates in 1990–1991. [SRDB Ref. ID 

89900] 

NIOSH 2011. SEC Petition Evaluation Report for Petition SEC-00175, Grand Junction 

Operation Office, Revision 0, January 11, 2011. 

NIOSH 2015. Addendum to SEC Petition Evaluation Report, Petition SEC-00175, Grand 

Junction Operation Office, Revision 0, National Institute for Occupational Safety and Health. 

March 12, 2015. [SRDB Ref. ID 141458] 

Personal Communication 2014e. Personal Communication with a Former Grand Junction 

Employee, Telephone Interview by ORAU Team, December 18, 2014, 11:00 AM EST. [SRDB 

Ref.ID 139114] 

Personal Communication 2014g. Personal Communication with a Former Grand Junction 

Employee, Telephone Interview by ORAU Team, December 10, 2014, 11:00 AM EST. [SRDB 

Ref. ID 139116] 

Personal Communication 2014h. Personal Communication with a Former Grand Junction 

Employee, Telephone Interview by ORAU Team, October 24, 2014, 9:00 AM MST. [SRDB 

Ref. ID 139128] 
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SC&A 2015. A Review of NIOSH’s Program Evaluation Report DCAS-PER-047, Grand 

Junction Operations Office, SCA-TR-PR2015-0093, Revision 01, SC&A, Inc., Vienna, Virginia.

February 10, 2015.