Interim Review of Pinellas 

SEC-00256 Petition Evaluation 

Report

Stephen L. Ostrow, PhD, SC&A, Inc.

Advisory Board on Radiation and Worker Health, Pinellas 

Work Group

November 20, 2023
2

SC&A ER review appendices

SC&A included three appendices with additional information:

 Appendix A, “DOE Tiger Team Report”: reviews the 1990 

report, highlighting items that appear relevant to the SEC

 Appendix B, “Radiological Incidents”: summarizes all the 

incident and health physics investigation reports that involved a 

potential or actual radiological release, contamination, and/or 

personnel exposure

 Appendix C, “Former Worker Interview Notes”: summarizes 

all worker interview records
3

Background: SC&A SEC-00256 ER review

 SC&A issued SCA-TR-2023-SEC001, “Interim SC&A Review of the 

SEC Petition Evaluation Report for Petition SEC-00256: Pinellas 

Plant,” on June 16, 2023

 SC&A had no findings and 13 observations

 The report:

– Summarizes the plant history and site information

– Discusses radiation sources and types

– Examines radiation monitoring procedures and compliance pre- and post1990 U.S. Department of Energy (DOE) Tiger Team report

– Evaluates whether the ER adequately recognizes and addresses all petitioner 

concerns, incorporates worker interview information, and accounts for all 

relevant reported radiological incidents
4

Pinellas Plant background

 Located on ~100-acre site in Clearwater, FL

 Constructed in 1956 and operated though 1994 by General 

Electric to manufacture neutron generators

 After 10 years, expanded to include other specialized 

electronic equipment for the nuclear weapons program

 At peak operations, the plant employed ~2,000 people

 Decontamination and decommissioning activities from 1994 

through 1997

 Remediation activities in 1999, 2008, and 2009
5

Pinellas SEC background

 12/16/2019: Initial Pinellas SEC-00256 submitted to NIOSH

 5/20/2020, 8/17/2020: Petitioners revised class definition twice

 10/20/2020: NIOSH qualified the 8/17/20 petition and modified the class 

definition

 10/13/2021: NIOSH completed the SEC petition evaluation report:

 12/8/2021: NIOSH presented the ER at the ABRWH meeting, and the 

ABRWH requested SC&A review

 12/8/2022: SC&A presented status of ER review at the ABRWH meeting

 6/16/2023: SC&A issued its interim review, recognizing that several new 

issues have recently been raised by the petitioners that may have SEC 

implications and that documents found in recent data captures have not 

yet been reviewed.
6

SEC development

 The revised SEC petition of 8/17/2020 proposed a period from 

January 1957 through December 1997

 NIOSH determined that the petition qualified for evaluation under 

the F.4 basis – scientific or technical report issued by a government 

agency or peer reviewed journal that identifies dosimetry 

information is unavailable – based on two statements from the 1990 

DOE Tiger Team report:

– “GEND [General Electric Neutron Devices] estimated that 20 percent of 

the personnel that terminated in 1988 did not provide a termination 

bioassay.”

– “Seventy percent of the required monthly samples and 35 percent of 

the required weekly samples were not submitted.”
7

NIOSH evaluated class definition

 Since the 1990 Tiger Team report assessed conditions in 1988 and 

1989, NIOSH determined that the Tiger Team’s findings were not 

directly applicable to the period that followed because the plant had 

adequately and promptly addressed the bioassay compliance 

issues raised in the report by the end of 1990

 Consequently, NIOSH terminated the SEC class definition period on 

12/31/1990 rather than on 12/31/1997 as proposed in the petition

 NIOSH’s SEC class: “All employees of the Department of Energy, its 

predecessor agencies, and their contractors and subcontractors 

who worked at the Pinellas Plant in Clearwater, Florida for the 

period from January 1, 1957 through December 31, 1990”
8

SEC petition evaluation report conclusion

The ER asserts that NIOSH can reconstruct doses during the 

proposed SEC period:

 NIOSH concludes that it has access to sufficient information to 

estimate the maximum radiation dose, for every type of cancer 

for which radiation doses are reconstructed

 Therefore, NIOSH does not recommend adding the NIOSHevaluated class to the SEC
9

SC&A’s ER assessment conclusions

 SC&A believes that it may be possible to bound doses to 

workers covered by the SEC petition

 However, SC&A notes that it has yet to be demonstrated that a 

suitable co-exposure model can be developed for other soluble 

tritium compounds.
10

Pinellas site profile

 The ER and SC&A’s review rely, in part, on the technical basis documents 

(TBDs)

 NIOSH produced the original set of TBDs in 2005 and 2006

 SC&A submitted its assessment of the TBDs in 2006 and identified 11 

primary and 8 secondary issues

 NIOSH revised the TBDs beginning in 2011

 As of the 8/9/16 ABRWH meeting, the primary and secondary issues had 

been adequately resolved except Primary Issue 2 concerning stable 

metal tritides (SMTs), which is in abeyance until NIOSH revises the 

internal dose TBD

 The bases for many of the assertions and methods in the ER have 

already been reviewed favorably by both SC&A and the ABRWH
11

Source characterization

 Radioactive materials (sealed or unsealed) vs. radiation generators

– Neutron generators (NGs) containing tritium targets

– Radioisotope-powered thermoelectric generators (RTGs) containing 

plutonium dioxide

– Borosilicate glass structures containing uranium

– Leak-testing systems containing krypton-85

– Tritium storage systems, which may also contain uranium beds

– Check sources and analytical standards for lab analyses

 Potentially dispersible radioisotopes: tritium, carbon-14, nickel-63, 

krypton-85, plutonium-238 and -239, uranium-234, -235, and -238,
12

Potential external exposures

 Photon

– NG production area

– RTG production area

– Chemistry lab

 Beta (electron)

– Tritium (primary source)

– Kr-85 (leak detection)

– C-14 (tracer in solvents)

 Neutron

– NGs (intermittent)

– RTGs (continuous)

The ER claims: “While radioactive 

material and radiation-generating 

devices were necessary to the 

product manufacturing, the 

majority of the work performed at 

the Pinellas Plant did not involve 

exposures to external sources of 

radiation. This lack of external 

exposure potential is why the 

Pinellas Plant did not monitor 

many workers for external 

exposures.”
13

Potential internal exposure radionuclides 

 Tritium 

 Uranium

 Plutonium

 Carbon-14

 Krypton-85

 Strontium-90

 Cobalt-60

 Thallium-204
14

Tritium internal exposure potential

 ER asserts tritium is the only source of internal exposure risk

 ER references internal dosimetry TBD for guidance on 

reconstructing doses from soluble tritium—gas, oxide, organically 

bound tritium (OBT)—from bioassays, which:

– Calculates exposures to both 100% tritium gas and 100% OBT and selects 

the most claimant favorable

– Assumes workers exposed to insoluble tritium compounds (metal tritides) 

were also exposed to soluble tritium, which was monitored

 Claimant-favorable approach: Although workers probably had 

limited exposures to insoluble tritium compounds, NIOSH assesses 

all workers monitored for soluble tritium as though they were 

exposed to insoluble tritium at the same time
15

Tritium exposure review

 Potential tritium exposure and how to determine dose has been 

a subject of concern and scrutiny since SC&A’s earliest TBD 

review, which resulted in 2 primary and 1 secondary issues

 Subsequent discussions, papers, and reviews closed all issues 

except for Primary Issue 2 (potential doses from insoluble 

metal tritides not sufficiently addressed), which was put in 

abeyance pending NIOSH revising the internal dosimetry TBD

 SC&A and the Pinellas Work Group (WG) accepted NIOSH’s 

tritium dose reconstruction (DR) methods, except for issue 2
16

Stable metal tritide issue

 ORAUT-OTIB-0066, “Calculation of Dose from Intakes of Special 

Tritium Compounds” (rev. 01, 2020), provides background on the 

issue associated with determining doses from SMT exposures:

Stable metal tritides (SMTs) are a class of tritium compounds that cannot be 

detected by urine bioassay as easily as tritium oxide. “Stable” is used to 

indicate that the tritium is not easily separated from the metal matrix in 

which it is bound. This material is more strongly retained in the lung, 

resulting in much smaller fractions of the intake excreted in urine. 

Therefore, a relatively small amount of tritium in a urine sample can indicate 

a large intake of an SMT.

 All issues closed by the Subcommittee for Procedure Reviews 

(SPR) 11/3/2021 meeting.
17

OTIB-0066, rev. 01, and internal dose TBD

 OTIB-0066, rev. 01, was reviewed by SC&A, all issues closed, 

and methodology accepted by the SPR at its 11/3/2021 

meeting

 The revised OTIB-0066 removed the recommendation to 

use ORAUT-OTIB-011 for assessing OBT exposures and 

added a discussion on interpreting urinalysis results following 

assumed intake of SMTs

 The current internal dose TBD (rev. 03) was issued in 2016, 

before OTIB-ORAUT-0066 (rev. 01)
18

Uranium internal exposure potential

 Depleted uranium (DU) was used in tritium storage beds.

 Secondary issue 8 from the original SC&A TBD review concerns the 

potential for missed DU intakes from inhalation of loose DU from 

cutting and machining of the beds.

– A NIOSH investigation and SC&A review established that such activities were 

conducted off site at a GE plant in Milwaukee, not at Pinellas.

 Pinellas used borosilicate glass containing 1.5% by weight of 

naturally occurring uranium oxide (U3O8).

– As part of plant operations, this glass was cut and chemically etched. 

– Site health physicists evaluated the exposure risk and determined that 

minimal external and no internal hazards were present.
19

Plutonium internal exposure potential

 The Pu issue has been discussed since SC&A’s initial review of the 

site profile in 2006. As of 2016, the issue was resolved as follows:

– Pinellas received triply encapsulated RTGs and did not open them, so the 

only chance of exposure was from surface contamination.

– Surface contamination levels of the capsules were quite low.

– At its October 2011 meeting, the WG considered the issue resolved and that 

no further consideration is necessary unless new information becomes 

available.

 For this SEC ER review, SC&A revisited the potential for Pu 

exposure, beginning with a more detailed look at the form, handling, 

and plant operations involving Pu, and concluded that the potential 

for Pu intakes has been adequately addressed and resolved.
20

Carbon-14 internal exposure potential

 According to the State of Florida Dept. of Health and Rehabilitative 

Services, approximately 0.00034 Ci of C-14 were released from 

plant stacks 1979–1983.

 The potential for C-14 internal exposure was identified by SC&A in 

its site profile review and discussed at the June 2009 Pinellas WG 

meeting.

– The quantity of material released was determined to be negligible and 

contributed less than 1 mrem/year dose.

– At the meeting, the Pinellas WG considered this issue resolved.

 Unless new information is identified, SC&A believes the potential for 

C-14 intakes has been resolved. C-14 does not contribute 

significantly to the internal dose hazard on site.
21

Krypton-85 internal exposure potential

 According to the State of Florida Dept. of Health and 

Rehabilitative Services, approximately 846 Ci of Kr-85 were 

released from plant stacks 1963–1992.

 As a noble gas, Kr-85 does not react chemically within the 

body and, when it is breathed in, it is soon breathed out. Since 

it has a 10.8-year half-life, little decay would occur in the lungs.

 The ER asserts that Kr-85 is not a significant internal exposure 

hazard.

 SC&A reviewed the ER’s assumption and concurs.
22

Strontium-90, cobalt-60, and thallium-204

 The petition requests that Pinellas be added to the SEC partly 

based on the claim of incomplete radiological characterization of 

Sr-90, Co-60, Tl-204, and beryllium (beryllium is an element, not a 

radionuclide).

 SC&A did not find that the presence of the three radionuclides in the 

Pinellas inventory represents a sufficient internal exposure risk that 

should have been monitored for by Pinellas.

– All Co-60 and Tl-204 sources were sealed (not loose), so there was no 

potential for direct exposure unless there was leakage. (A Co-60 leakage in 

1961 was found by a routine survey and corrected immediately.)

– Sr-90 was present in both sealed and unsealed forms. However, the unsealed 

sources were small.

– While these radionuclides can be used in RTGs, no evidence has been found 

so far that such was the case at Pinellas.
23

Radiation monitoring

SC&A reviewed the radiation monitoring data available for two 

time periods: before and after the 1990 Tiger Team review.

 SEC period: 1957–1990 

 Post-SEC period: 1991–1997 
24

Rad monitoring: SEC period 1957–1990 (ER)

The ER states for the SEC period:

 Both external and internal dosimetry results are available, and the 

available data extend beyond 1981.

 Claimant records provided by DOE generally include both internal 

and external dosimetry results for potentially exposed workers.

 Pinellas did monitor potentially exposed personnel and did not find 

indications of lack of monitoring for the class under evaluation.

 NIOSH concludes that it has sufficient data to perform dose 

reconstructions.
25

Rad monitoring: SEC period 1957–1990

 During its review, SC&A did not have access to the searchable 

NOCTS database to analyze claimant data. As a workaround, 

SC&A manually reviewed the list of ~2,500 documents made 

available by NIOSH.

 SC&A reviewed those documents that, based on their titles, 

could potentially contain bioassay or external dose data.

– The data contain tritium and some plutonium bioassay results as well 

as external monitoring records for photons, betas, and neutrons as 

applicable.

– SC&A cannot make a definitive judgment on the adequacy of the 

internal dosimetry data during the SEC period at the time of this review.
26

Rad monitoring: post-SEC period 1991–1997

 NIOSH ended the petitionerrequested SEC period at 

12/31/1990 because Pinellas 

significantly improved its 

monitoring performance 

post-Tiger Team.

 Bioassay compliance 

tracking results 1990–1995: 

The annual ALARA reports 

showed improvements in 

compliance. 

– For example, the 1990 report 

states that the bioassay 

program average participation 

was 78%. 
27

Rad monitoring: SC&A observations

After examining the available bioassay data, SC&A had two 

observations:

 Observation 4: Lack of bioassay records for 1988–1990. Few 

records (3–10 claimants per year) available for approx. 

1,750 employees. 

 Observation 5: Bioassay schedule noncompliance. 

Appropriate bioassay compliance levels is a subjective 

judgment to be made by the Board. NIOSH should 

demonstrate that an appropriate co-exposure model can be 

constructed to address incompleteness in the tritium bioassay 

program. 
28

Rad monitoring: post-SEC period – Tiger Team 

The 1990 Tiger Team report made several relevant comments that SC&A 

captured in observations 6–11:

 Observation 6: Praise for the overall radiological protection program at 

Pinellas for providing adequate radiological protection for all employees

 Observation 7: Bioassay sampling frequency requirements not followed

 Observation 8: Contamination controls generally good

 Observation 9: Bioassay sampling program implementation 

inadequacies

 Observation 10: Deficiencies root causes: mindset of production and no 

unusual risks

 Observation 11: Transition year of 1990 after assessment led to overall 

reduced exposures
29

Computer-assisted telephone interviews 

(CATIs)

 SC&A reviewed 490 available CATI reports for indications of internal and 

external monitoring and incidents and their followups

 SC&A did not have access to individual claimant monitoring files to 

compare CATI statements to relevant dosimetry records

 16% of the CATIs indicated that the EE was involved in a radiological 

incident

 38% of the CATIs stated that the EE received urinalysis after the incident

 Of the CATIs that were completed with the EE themselves:

– 46% recalled being internally monitored and 45% externally monitored

– 27% did not recall if they were involved in an incident

 Therefore, the number of EEs involved in incidents might be 

underestimated if using CATI information alone
30

Dose reconstruction cases

 As part of its work with the Subcommittee for Dose Reconstruction 

Reviews, SC&A had reviewed a few Pinellas cases. 

 SC&A summarized the monitoring history of each individual and 

compared it with the CATI reports and internal monitoring NOCTS history.

 Due to the limited available data, this comparison cannot be used to tell if 

the records are complete, but it can be used more broadly to identify the 

presence or absence of records in the EE’s files.

 The comparison shows that, for this limited sample, internal monitoring 

records match the claimant recollections reported in the CATI.

 The external monitoring results are less conclusive: Several claimants 

reported being externally monitored, while the external data were not 

available at the time of the DR. SC&A did not have access to NOCTS to 

check if these records have since been located.
31

Recordkeeping procedures

 SC&A reviewed the procedure used for obtaining claimant 

records and found that occasionally all the claimants’ records 

and other information are not contained in the files that DOE 

sends to NIOSH following a record request from NIOSH.

 NIOSH has placed, and is still placing, these documents in the 

SRDB system.

 Upon receipt of new information for a noncompensated, 

completed DR, NIOSH reworks the case to ascertain any 

impacts.
32

Documented communications with former 

workers

 SC&A evaluated available interview summaries to determine if 

they contain information pertinent to the SEC evaluation.

 Appendix C to SC&A’s review report summarizes these 

interviews.

 The interviews reflect the total period Pinellas operated and 

encompass a broad range of professions.

 Observation 12: SC&A believes that the recollections reported 

in the interviews, in general, are consistent with those in the 

ER.
33

Petitioner concerns

 The ER identifies and addresses 9 different concerns extracted from 

the SEC petition. SC&A also examined the petition and categorized 

the same set of concerns into 12 different issues.

 SC&A determined that each of the 12 issues was addressed by 

NIOSH to various extents in the ER, although not always explicitly 

point-by-point. 

 The issues related to DR were not explicitly addressed in the ER, 

but the common practice employed by NIOSH is to assign job titles, 

work locations, and work processes for any given year or dosimetry 

exchange period based on the information provided by the claimant 

or in the employment records. When in doubt, NIOSH assigns 

parameters that yield the highest doses.
34

Additional petitioner concerns

 The petitioners or their representatives also made several additional 

submittals after the petition was received up to (and beyond) the time 

SC&A was preparing this review.

 SC&A preliminarily looked at submittals made after the December 2022 

Board meeting (which had a session on the Pinellas petition, the ER, and 

SC&A’s progress in evaluating the ER), up to the beginning of March 

2023.

 These new concerns and submittals through March 2023 involved 

subjects such as: “leaking” Pu, multiple myeloma study, history of 

radiologic incidents report, metal tritides, the occupational internal dose 

TBD, the “Pinellas Plant Environmental Baseline Report,” a request to 

investigate a report on cancer incidence in Pinellas County, and some 

nontechnical or not relevant communications.
35

SC&A review: Observations overview

 SC&A has no findings but 13 observations. 

 SC&A is especially concerned about compliance with bioassay 

program requirements before the Tiger Team assessment in 

1990

– Summarized in observations 2, 4, 5, 7, and 9
36

Observation summary (1–2)

 Observation 1: Neutron 

generator production was fairly 

steady. SC&A reviewed NG 

production from 1974 through 

1993 and found it fairly steady.

 Observation 2: Potential for 

tritium contamination is 

adequately addressed. Key 

aspect 4 of the NIOSH SMT 

model indicates that SMT 

exposures would only be applied 

if the worker were also monitored 

via urinalysis. However, given the 

uncertainties noted by the Tiger 

Team in the performance of the 

bioassay program as late as 

1990, relying on bioassay 

completeness to establish 

exposure potential is likely 

inappropriate. 
37

Observation summary (3–4)

 Observation 3: The ER does 

not reference recent special 

tritium compound document. 

Neither the ER nor the internal 

dosimetry TBD incorporate 

guidance for dose 

reconstruction for intakes of 

SMTs from revision 1 of 

ORAUT-OTIB-0066. NIOSH 

should evaluate whether it has 

any consequential effects on 

the ER.

 Observation 4: Lack of 

bioassay records for 1988–

1990. Despite between 129 

and 201 employees reportedly 

bioassayed from 1988 to 1990, 

NIOSH only has monitoring 

records for 3-10 claimants per 

year. According to the Tiger 

Team report, approximately 

1,750 people were employed at 

Pinellas in 1989.
38

Observation summary (5–6)

 Observation 5: Bioassay 

schedule noncompliance by 

the plant. This was one of the 

principal Tiger Team findings. In 

addition, the level of 

compliance with the bioassay 

program is unknown for prior 

years. SC&A believes that 

NIOSH should demonstrate 

that an appropriate co- exposure model can be 

constructed to address 

apparent incompleteness.

 Observation 6: Radiological 

protection program 

commended by Tiger Team.

The Tiger Team report stated 

that its overall assessment was 

that all levels of the 

organization are receiving 

adequate radiological 

protection.
39

Observation summary (7–9)

 Observation 7: Bioassay 

sampling frequency 

requirements not followed as 

noted by the Tiger Team. The 

Tiger Team compliments the plant 

for maintaining low overall internal 

dose exposures but also makes a 

finding on noncompliance issues. 

This is one of the bases of the 

SEC petition.

 Observation 8: Contamination 

controls found generally good 

by Tiger Team.

 Observation 9: Bioassay 

sampling program 

implementation inadequacies 

noted by the Tiger Team. 20% of 

personnel terminated in 1988 did 

not provide a sample. In 1989, 

70% of the required monthly 

samples and 35% of the required 

weekly samples were not 

submitted. This is one of the 

bases of the SEC petition.
40

Observation summary (10–11)

 Observation 10: Tiger Team 

assessment of deficiency root 

causes: emphasis on production 

and mindset that Pinellas poses 

no unusual radiological risks. The 

Tiger Team report states that:

– Emphasis on production has 

traditionally overshadowed interest in 

fully complying with environment, safety, 

and health requirements.

– There is a wideset mindset that the 

Pinellas Plant poses no unusual or 

unique risks.

 Observation 11: Transition year of 

1990 after Tiger Team assessment 

led to overall reduced exposures. 

Data indicate a significant decrease 

in external doses from 1990 to 1991, 

but an increase in internal doses 

from tritium from 1990 to 1991 (due 

to an incident), then a gradually 

decreasing trend from 1992 to 1995. 

SC&A has not found indications that 

there are issues with exposure 

records that would prevent DR 

feasibility for the SEC period 1957– 1990, nor for 1991–1997.
41

Observation summary (12–13)

 Observation 12: ER is 

consistent with interview 

records. SC&A reviewed all 

available documented 

communications records that 

reflect the total period operated 

and encompass a broad range of 

jobs. In general, the workers in 

physics, engineering, chemistry, 

and lab-related professions had 

experience with the site’s internal 

and external monitoring program. 

The recollections from these 

interviews are consistent with the 

ER.

 Observation 13: Pinellas plant 

diligent in following up on 

contamination-related incidents 

and personnel exposures. 

SC&A concurs with the conclusion 

in the ER. However, given the lack 

of bioassay records for 1988– 1990 described in observation 4 

and the issues surrounding 

bioassay noncompliance 

described in observations 5, 7, 

and 9, it is possible that the 

program might not have captured 

all the internal exposures related 

to contamination incidents.
42

Potential path forward (if tasked by WG)

Evaluate all new data from 

data collection activities 

made available after this 

report was produced 

Respond to any new 

reports, presentations, 

etc. 

Revise ER review 

incorporating all new 

information
43

Questions?