DRAFT

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A’S REVIEW OF REMAINING SITE PROFILE ISSUES 

FOR MOUND LABORATORY RELATED TO CURRENT 

TECHNICAL BASIS DOCUMENTS 

Contract No. 211-2014-58081 

Document No. SCA-TR-2016-SP002, Revision 0 

Prepared by

Joseph E. Fitzgerald, Jr. 

Saliant, Inc.

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 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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S. COHEN & ASSOCIATES: SC&A’s Review of Remaining Site Profile Issues for Mound 

Laboratory Related to Current Technical Basis Documents

DOCUMENT TITLE: SC&A’s Review of Remaining Site Profile Issues for Mound 

Laboratory related to Current Technical Basis Documents

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SP002 

REVISION NO.: 0

SUPERSEDES: N/A

EFFECTIVE DATE: February 11, 2016

TASK MANAGER: Joe Fitzgerald

PROJECT MANAGER: John Stiver, MS, CHP

DOCUMENT 

REVIEWER(S): John Stiver, MS, CHP

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 02/11/2016 Initial issue
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TABLE OF CONTENTS

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

1.0 Introduction and Background ..............................................................................................5

2.0 Site Description TBD: ORAUT-TKBS-0016-2, Revision 01 .............................................5

3.0 Occupational Medical Dose TBD: ORAUT-TKBS-0016-3, Revision 02...........................6

4.0 Occupational Environmental Dose TBD: ORAUT-TKBS-0016-4, Revision 01 ................6

5.0 Occupational Internal Dose TBD: ORAUT-TKBS-0016-5, Revision 02 ...........................6

5.1. Matrix Issue #5 (Pu-240, 241) .................................................................................7

5.2. Matrix Issue #6 (Tritides) ........................................................................................7

5.3. Matrix Issue #9 (High-fired Pu-238) .......................................................................8

5.4. Matrix Issues #11, 12, and 13 (Internal Dosimetry Data Completeness) ................8

5.4.1. Uncertainties and Low Recovery for Polonium Bioassay Procedures .............. 8

5.4.2. Other Radionuclide Data (SC&A Data Comparison) ....................................... 9

5.4.3. Secondary/Other Radionuclide Data (MJW Evaluation) .................................. 9

5.4.4. Tritium Logbooks Missing for 1976 and 1977 ............................................... 10

5.4.5. Tritium Bioassay Data Adequacy .................................................................... 11

5.4.6. Plutonium Data Comparison ........................................................................... 11

5.4.7. Polonium Data Comparison ............................................................................ 12

5.4.8. Fecal Bioassay Data ........................................................................................ 12

5.4.9. Tritium (HTO) Data Comparison .................................................................... 12

5.4.10. Thorium Bioassay Data ................................................................................. 13

6.0 References ..........................................................................................................................15
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

CFR Code of Federal Regulations

D&D decontamination and decommissioning

DOE U.S. Department of Energy 

HPNO health physics number 

HTO tritiated water vapor 

IMBA Integrated Modules for Bioassay Analysis

LANL Los Alamos National Laboratory 

MDA minimum detectable activity

MDC minimum detectable concentration

MJW MJW Corporation Inc. 

MESH Mound Environmental Safety and Health 

NIOSH National Institute for Occupational Safety and Health

ORAUT Oak Ridge Associated Universities Team

OTIB technical information bulletin

Po polonium 

Pu plutonium 

PORECON polonium urinalysis bioassay results database 

PURECON plutonium urinalysis bioassay results database 

RFP Rocky Flats Plant

SEC Special Exposure Cohort 

SRDB Site Research Data Base

SSN social security number

TBD technical basis document 

Th thorium 

V&V verification and validation

WG Work Group 
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1.0 INTRODUCTION AND BACKGROUND 

At its November 18–19, 2015, meeting in Oakland, California, the Advisory Board on Radiation 

and Worker Health (ABRWH) tasked SC&A, Inc. with a review of revised technical basis 

documents (TBDs) for Mound Laboratory in the context of remaining site profile issues 

stemming from the original SC&A review and subsequent Mound Plant Work Group review of 

the Special Exposure Cohort (SEC) evaluation. SC&A reviewed the four TBDs that had 

undergone revision subsequent to SC&A’s original site profile review in 2006: 

• Site Description TBD: ORAUT-TKBS-0016-2, Revision 01 (revised April 1, 2013) 

• Occupational Medical Dose TBD: ORAUT-TKBS-0016-3, Revision 02 (revised 

March 14, 2013) 

• Occupational Environmental Dose TBD: ORAUT-TKBS-0016-4, Revision 01 (revised 

February 7, 2013) 

• Occupational Internal Dose TBD: ORAUT-TKBS-0016-5, Revision 02 (revised April 18, 

2013) 

The Occupational External Dose TBD, ORAUT-TKBS-0016-6, Revision 00 (August 11, 2004), 

has not yet been revised and was not reviewed. In its review, SC&A compared its original 2006 

site profile findings and any subsequent site profile-type issues stemming from ABRWH work 

group deliberations for the SEC with the treatment that is afforded these issues in the current, 

revised TBDs. The baseline for this review comes from various issue matrices that were 

developed for the Work Group, from Work Group meeting transcripts, and from the extensive 

white papers and reviews that were generated during SEC deliberations. Where adequate 

treatment was found to be given, closure is recommended to the Mound Plant Work Group for 

consideration. Where such treatment is not adequate or is unclear, further follow-up with the 

National Institute for Occupational Safety and Health (NIOSH) is recommended. 

2.0 SITE DESCRIPTION TBD: ORAUT-TKBS-0016-2, REVISION 01 

This TBD essentially has the same content as the previous version (ORAUT-TKBS-0016-2, 

Revision 00, March 30, 2004), with (as noted by NIOSH) revisions to incorporate SEC Petitions 

SEC-00090, SEC-00171, and SEC00207, including SEC-related information pertaining to the 

SW (“Semi-Works”) Building and an update to Table 2-1 to add information for 2003 and 2010. 

While SC&A has no specific comments about the scope and content of this TBD, which we had 

found acceptable, our original site profile comments in 2006 provided this cautionary note: 

One interviewee said that in spite of these extensive listings, some room numbers 

and the isotopes used in these rooms had not made it into these summaries. It is 

also apparent from worker interviews that D&D characterization studies may 

have shown the presence of radionuclides in certain facilities not identified as 

such by the King report. [SC&A 2006a]
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Given its lengthy operational history and the complexity and diversity of radionuclide use at 

Mound Laboratory, it continues to be important to remind dose reconstructors that the King 

report, and other surveys like it, represented operational “snapshots” and compiled histories and 

likely did not match all potential exposure source terms with time and location.

3.0 OCCUPATIONAL MEDICAL DOSE TBD: ORAUT-TKBS-0016-3, 

REVISION 02 

In SC&A’s site profile review of the Pantex Plant (SC&A 2006b) Occupational Medical Dose

TBD (ORAUT 2006), SC&A found that “other examinations should be included, such as special 

job exams (e.g., respiratory protection, beryllium workers, asbestos workers, etc.) and 

termination exams.” SC&A further noted that the Occupational Medical Dose TBD “does not 

recognize this change from the previous Revision 2 of OTIB-0006 (Kathren and Shockley 2005), 

and also assumes that special chest radiography for respirator certification, beryllium and 

asbestos workers, and food handlers are accomplished as part of the annual physical, if these jobs 

are defined as ‘at-risk’ workers.” The SC&A review concluded that “NIOSH should review its 

interpretation of included medical exposure, and should reasonably adopt a broader interpretation 

of occupational medical dose, as provided in the most recent version of OTIB-0006 (Kathren and 

Shockey 2005).” 

This concern appears to be only partially addressed in the 2013 version of the Mound 

Occupational Medical Dose TBD (ORAUT 2013b), with asbestos and “at-risk” workers 

categorized as receiving annual x-rays. However, no mention is made of beryllium workers and 

those requiring respiratory fittings (this differs from the approach taken for the medical 

occupational TBDs for Los Alamos National Laboratory (LANL) and the Rocky Flats Plant 

(RFP), where both of these categories were explicitly called out and are presumably based on the 

same OTIB-0006 guidance). If these and other medical x-ray categories are to be included in the 

“at-risk” category in Table 3-1, that clarification should be provided for the dose reconstructor in 

this TBD. (This is a minimum recommendation, as it would remain unclear why these categories

should not be explicitly listed consistent with the approach taken for LANL and RFP medical 

exposure frequencies.) 

4.0 OCCUPATIONAL ENVIRONMENTAL DOSE TBD: 

ORAUT-TKBS-0016-4, REVISION 01

SC&A has no comments on this TBD. 

5.0 OCCUPATIONAL INTERNAL DOSE TBD: ORAUT-TKBS-0016-5, 

REVISION 02 

At the request of the Mound Plant Work Group, SC&A prepared and issued (on May 25, 2012) a 

Mound Site Profile Issues Matrix (SC&A 2012a) that contained a tracking list for remaining site 

profile issues stemming from the SEC evaluation report review for Petition SEC-00090. This list 

was based on an assessment of the following: 
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• The NIOSH Evaluation Report dated December 20, 2007 

• The Mound SEC Petition SEC-00090 

• A review of Site Research Database (SRDB) documents

• SC&A’s Site Profile Review (SC&A 2006a) 

• Work Group meetings (as referenced below)

• Joint interviews of April 6, 2010 

• Secure NIOSH/SC&A working sessions held in Germantown, Maryland, June 30, 2009, 

and April 7, 2010 

• Past SEC Issues Matrices and listings developed by SC&A (SC&A 2011, 2012a, and 

2012b) 

NIOSH responded to an earlier SC&A memo report on internal dose adequacy and completeness 

(SC&A 2012b), as well as this matrix list, in a May 29, 2012, set of comments (acknowledging 

in the process some confusion over the status of these “open” issues, i.e., whether they were of 

an SEC or site profile nature) in advance of a June 5, 2012, Mound Plant Work Group meeting 

(NIOSH 2012). These items were discussed as an agenda item during that meeting, and this 

current review reflects that discussion as well. (Note that the issue numbers and titles in the 

discussion below follow the format used in SC&A’s (2012b) site profile matrix listing.) This

particular Work Group exchange stands as the most recent discussion of record regarding 

outstanding Mound site profile issues and their respective status. 

5.1. MATRIX ISSUE #5 (PU-240, 241) 

A remaining action was identified for this SEC matrix item when the Work Group closed it out: 

for NIOSH to confirm a bounding intake for plutonium-241 (Pu-241) for use in the dose 

reconstruction program. (ABRWH 2008a, Work Group (WG) transcripts pp. 147–158; ABRWH 

2008b, WG transcripts, pp. 227–228). During the June 5, 2012, Work Group discussion, NIOSH 

(Jim Neton) agreed that this remained an open item for consideration in the then-upcoming 

Internal Dose TBD revision (ABRWH 2012, WG transcripts, p. 194). SC&A was unable to 

locate consideration of this issue within the revised TBD and suggests further clarification by 

NIOSH of its disposition. 

5.2. MATRIX ISSUE #6 (TRITIDES)

During the Work Group discussion of this SEC issue, NIOSH acknowledged that some 

consideration was needed by dose reconstructors of “intermediate solubility class” tritium 

compounds (ABRWH 2009, WG transcripts, pp. 239–256; NIOSH 2009a). During the 

June 5, 2012, Work Group discussion, NIOSH (Jim Neton) agreed to address the inclusion of 

guidance on intermediate solubility class compounds (such as titanium tritide) in a more formal 

response for the Work Group (ABRWH 2012, WG transcripts, p. 198). SC&A was unable to 

locate any formal NIOSH response on this issue or any specific treatment within the revised 

TBD or in the supporting document, ORAUT-RPRT-0057, Revision 00, A Method for 
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Estimating Stable Metal Tritide Exposures to Tritium Ancillary Workers Based on Swipe Data in 

Rooms SW-8, SW13, SW-150 and R-108 at the Mound Laboratory 1968 to 1989 (Jessen et al. 

2013). SC&A suggests further clarification of NIOSH’s position on this item.

5.3. MATRIX ISSUE #9 (HIGH-FIRED PU-238) 

In Work Group discussions, as reflected in the Mound SEC issues matrix (SC&A 2011), NIOSH 

was to provide “additional review and a commitment to make dose reconstructors aware of 

available solubility-based excretion models (i.e., Type J); the Work Group closed this issue as an 

SEC issue.” The remaining action noted in the matrix was that NIOSH was to complete its 

review and add a “Type L” excretion model to those already available to dose reconstructors. In 

the June 5, 2012, Work Group discussions, NIOSH (Jim Neton) acknowledged the commitment 

and indicated that it would consider how to include some consideration of a “Type L” model in 

the then-upcoming TBD revision (ABRWH 2012, WG transcripts, p. 200). SC&A, in its review 

of the TBD revision, found NIOSH referenced a Type L model as follows: 

The type L model developed from Mound site data is unlikely to be typical of 

Mound site exposures to 238Pu, but each potential exposure should be evaluated 

for applicability of this model. Type L is modeled using specific IMBA input 

parameters in Table 5-15 later in this document. [ORAUT 2013d]

SC&A recommends closure of this site profile item.

5.4. MATRIX ISSUES #11, 12, AND 13 (INTERNAL DOSIMETRY DATA 

COMPLETENESS)

5.4.1. Uncertainties and Low Recovery for Polonium Bioassay Procedures

This issue was raised originally in SC&A’s white paper, Mound Internal Dosimetry Data 

Completeness (SC&A 2009a), in Section 3.1, as it pertained to “questionable effectiveness of 

early radiobioassay at Mound.” The Work Group saw a need for more treatment of this specific 

Mound bioassay limitation. Illustrative of questionable effectiveness are the low recovery for 

polonium urinalysis (an average of about 10%) and reduced recoveries in samples with higher 

activities. While the broader issue of early Mound radiobioassay limitations was addressed in 

various NIOSH responses, this specific question apparently was not. In the June 5, 2012, Work 

Group meeting, NIOSH (Jim Neton) agreed that it could be readily addressed (ABRWH 2012: 

WG transcripts, p. 204). 

The revised Occupational Internal Dose TBD includes the following discussion in Attachment B, 

“Uncertainty Assessment” (ORAUT 2013d, page 59): 

Uncertainties associated with analytical procedures Mound used throughout the 

history of bioassay measurements are significant. Early analytical procedures 

resulted in large errors and MDAs in relation to required regulatory dose limits. 

Reductions in regulated body burdens for 210Po required modifications to 

improve analytical sensitivities. Positive bioassay detections would therefore 
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correspond to significant worker dose commitments at the lower end of detection 

in urine for some radionuclides. 

Systematic errors occurred in analytical procedures in the early years due 

primarily to ineffective plating techniques and low recoveries. Low recoveries 

were due largely to colloidal plating of metabolized 238,239Pu and 210Po from 

raw urine onto sample containers. Polonium-210 recovery in the early years 

before sample acidification could have resulted in an order of magnitude 

correction for 210Po urinalysis results.

SC&A recommends closure of this site profile item, with clarification as to whether these 

limitations are reflected in dose reconstruction workbooks and guidance. 

5.4.2. Other Radionuclide Data (SC&A Data Comparison)

This issue was raised originally in SC&A’s white paper, Mound Internal Dosimetry Data 

Completeness (SC&A 2009a), in Section 3.6. In its May 2012 response (NIOSH 2012), NIOSH 

noted that it had “responded in detail to these concerns in its November, 2009 report, NIOSH 

Evaluation of Data Adequacy and Completeness Issus at the Mound Laboratory

(NIOSH 2009b), and again in its August 2011 report, NIOSH Evaluation of Data Adequacy and 

Completeness Issues at the Mound Laboratory (NIOSH 2011). During the June 5, 2012, Work 

Group meeting (ABRWH 2012, WG transcripts, p. 205), SC&A acknowledged NIOSH’s 

responsiveness to two of the sub-issues regarding “~95% of data found for selected individuals 

was collected in 1990 and later...Pre-1990 results included uranium, thorium, and curium” and 

“Majority of pre-1990 results not available in MESH” and recommends that the Work Group 

close these sub-issues. For the other issues—recognizing that data comparison is rendered 

difficult due to units and radionuclides not always matching and that volume corrections were 

not possible in many cases—SC&A views these as enhancements, for clarity sake, that NIOSH 

can consider for future TBD revisions. Overall, SC&A recommends closure of this site profile 

item.

5.4.3. Secondary/Other Radionuclide Data (MJW Evaluation) 

In SC&A’s Mound Internal Dosimetry Data Quality Assurance (April 2009b), a review was 

conducted of the previous data analysis completed during the pre-1989 dose reconstruction effort 

by MJW Corporation Inc. NIOSH used this review, coupled with the History of the Mound 

Bioassay Program (Meyer 1992), as the basis for demonstrating the level of quality in the 

Mound bioassay program and data. SC&A found that for “other” radionuclides, “the scarceness 

of data infers that these analyses were not performed routinely and often enough to generate 

much quality assurance data,” an issue for which similar concerns were raised by MJW in its 

pre-1989 review. Those concerns included the following: 

Many difficulties were encountered in attempting to interpret the available 

bioassay records and reports of the other radionuclides. Some of the results were 

not associated with a name, social security number (SSN), or health physics 
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number (HPNO). Often times there not units associated with a result. 

[MJW 2002, Appendix C]

MJW further found that, 

The intake and dose assessments for “other” radionuclides done during the 

project based on limited, and on occasion conflicting, information. In some cases, 

it appears that the same bioassay results were repeatedly reported for two, or 

sometimes three, different radionuclides. [MJW 2002, Appendix C]

These and other quality assurance issues cited in MJW’s pre-1989 report were addressed in 

NIOSH’s response #12 of its August 2011 paper, NIOSH Evaluation of Data Adequacy and 

Completeness Issues at the Mound Laboratory (NIOSH 2011). To summarize, NIOSH disputed 

SC&A’s characterization of the MJW assessment, noting that the MJW report referred to these 

“other” radionuclides as “relatively minor players in the Mound facility operations,” that 369 

dose assessments for these “other” radionuclides actually had been performed, and that the 

“other” radionuclides were part of small, episodic programs involving laboratory research 

involving relatively few workers. In toto, NIOSH agrees that “other” radionuclides should not be 

ignored but asserts that the scale of exposure potential is very small for affected workers.

During the June 5, 2012, Work Group meeting, NIOSH (Jim Neton) agreed that any remaining 

questions about the MJW findings for “other” radionuclides should be addressed in the context 

of the TBD (ABRWH 2012, WG transcripts, p. 209). 

SC&A agrees with NIOSH’s 2011 conclusion (NIOSH 2011) that the scale of workers affected 

is relatively small, given the research context of this laboratory work, but continues to contend 

that NIOSH needs to reconcile these original MJW quality findings for “other” radionuclides 

with how it is approaching dose reconstruction for them in the Occupational Internal Dose TBD. 

Although the number of workers was small relative to tritium and plutonium production 

operations, research was a prime mission of Mound and needs to be addressed accordingly in 

terms of the adequacy of bioassay data being used in reconstructing doses for those workers. If 

they are not to be ignored in the dose reconstruction program for Mound, how are such doses 

being assigned?

5.4.4. Tritium Logbooks Missing for 1976 and 1977 

Based on NIOSH findings, SC&A confirmed that tritium logbooks (but not corresponding 

tritium reported dose in Mound Environmental Safety and Health (MESH)) were missing for 

certain years. SC&A noted, at the June 5, 2012, Work Group meeting, that its originally reported 

years were in error; the periods for which logbooks are missing are September 1, 1972, through 

December 31, 1972; and for January 1, 1975, through December 31, 1976. (ABRWH 2012, WG 

transcripts, p. 172). At that work group meeting, SC&A observed that the then-proposed NIOSH 

model for bounding tritide dose based on entries in these logbooks could not be accomplished for 

those years. In response, NIOSH (Jim Neton) indicated that his office was moving forward on an 

83.14 petition process for defining an SEC class for those time periods (ABRWH 2012, WG 

transcripts, pp. 172–173). SC&A has confirmed that Petition SEC-00207 was filed, 
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recommended by the Advisory Board, and formally designated on January 17, 2013, rendering 

this issue moot. SC&A recommends closure of this site profile item. 

5.4.5. Tritium Bioassay Data Adequacy 

SC&A originally raised this concern in its 2009 report, Mound Internal Dosimetry Data 

Adequacy (SC&A 2009c), and further elaborated it in another 2009 report, Response to Modeling 

of Intakes for Special Tritium Compounds (SC&A 2009d). In these reports, SC&A raised the 

concern that the algorithm used to determine early tritium dose was adopted from a LANL

procedure based on estimating whole-body dose from tritium in water. This procedure, as 

applied at Mound through 1981, indicates that all annual tritium dose is based on tritiated water 

vapor (HTO) and that other tritium compounds were not considered, although it clear that such 

compounds as special tritium compounds and organically bound tritium were present. In its May 

2012 response to SC&A’s draft site profile matrix (NIOSH 2012), NIOSH noted that it had 

obtained tritium bioassay logbooks (with the exception of the time periods noted in Section 5.4.4 

above) and had access to the requisite raw data from which tritium dose reconstruction could be 

performed.

NIOSH has addressed the question of tritium compounds other than HTO before 1982 in its 

bounding methodology for special tritium compounds (tritides) that was conceptually proposed 

in Responses to Action Items Introduced During the Mound Work Group Meeting of June 5, 

2012 (Chew et. al., 2012), and formally issued as A Method for Estimating Stable Metal Tritide 

Exposures to Tritium Ancillary Workers Based on Swipe Data in Rooms SW-8, SW13, SW-150 

and R-108 at the Mound Laboratory 1968 to 1989 (Jessen et al. 2013). The successive treatment 

of this issue over several years, culminating in available tritium logbooks being obtained for 

purposes of accessing original tritium bioassay data (coupled with an 83.14 SEC class being 

defined for time periods lacking such logbooks) and the development of a bounding method for 

special tritium compounds, addresses SC&A’s original concern. SC&A recommends closure of 

this site profile item. 

5.4.6. Plutonium Data Comparison 

In its 2009 report, Mound Internal Dosimetry Data Completeness,” SC&A (2009a) found that, of 

the total records used in the comparison of MESH data versus bioassay card data, about 15% did 

not have bioassay card data, with alternate sources of hardcopy records available in only some of 

the cases. Approximately 3% of the MESH and individual exposure files did not have data that 

were listed in the logsheets. This concern stems from the reliance of the U.S. Department of 

Energy’s (DOE’s) electronic records for Mound on MESH printouts.

Based on further sampling of 25 former Mound employees for internal data completeness, 

SC&A recommended to the Work Group that further validation be performed by NIOSH on the 

completeness of bioassay records for dose reconstruction. In the context of what has become 

known as verification and validation (V&V) of records databases, this has typically involved 

some degree of records sampling and comparison (e.g., electronic versus hardcopy) for internal 

and external dose. It is not clear to what extent such V&V was completed for Mound in the 

course of the SEC evaluation. SC&A recommends that the Work Group request that NIOSH 
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provide a summary of how it conducted such validation of Mound’s internal and external dose 

databases.

5.4.7. Polonium Data Comparison 

In its 2009 report, Mound Internal Dosimetry Data Completeness, SC&A (2009a) found that 

about 3% of the total records had no bioassay card data and about 2% had no data in the 

electronic POLON_DATA file, itself. As noted in the SC&A report: 

Where the bioassay card and PORECON database results were both available, 

~99 % of the electronic data was consistent with the data on the bioassay card. Of 

the total records, ~3% of the records had no bioassay card data and ~2% had no 

data in POLON_DATA. Where the bioassay card and PORECON results were 

both available, ~99% of the electronic data was consistent with the data on the 

bioassay card. Of the total records, ~3% of the records had no bioassay card data 

and ~12% had no data in PORECON. There were individuals with data in 

PORECON that were not found in POLON_DATA and vice versa. In other cases, 

only partial records were available in the electronic and/or hardcopy data 

source.

As recommended in Section 5.4.6 above, the Work Group should request that NIOSH provide a 

summary of how it conducted a validation of Mound’s internal and external dose databases. 

5.4.8. Fecal Bioassay Data 

In its 2009 report, Mound Internal Dosimetry Data Completeness, SC&A (2009a) found that 

there are relatively few fecal results in the plutonium urinalysis bioassay results database 

(PURECON) (i.e., total of 29 fecal samples for 12 individuals for the entire Mound worker 

population) and that there is poor overlap of data with corresponding logbooks for the same time 

periods. A majority of the data found in the logbooks were not found in the individual exposure 

files. As many of these samples were likely collected as a result of an incident or suspected 

plutonium exposure, the data can be critical to best-estimate dose reconstruction.

When SC&A mentioned this data completeness concern during the June 5, 2012, Work Group 

meeting, NIOSH pointed out that it does not intend to make use of the fecal sampling records, 

rendering moot the incompleteness of these records (ABRWH 2012, WG transcripts, p. 214). 

SC&A recommends that the Work Group request confirmation from NIOSH that Mound fecal 

data have no use in dose reconstruction. 

5.4.9. Tritium (HTO) Data Comparison 

In its 2009 report, Mound Internal Dosimetry Data Completeness, SC&A (2009a) found that, for 

25 individuals sampled for internal dose completeness validation, approximately 4,900 tritium 

bioassay results were located in the HP_TRITIUM database ranging from October 1981 to July 

2003. Log bioassay values for limited, specific time periods were located at the time in the 

SRDB. One issue noted at the time was that some individuals (of the 25 sampled) had tritium 

bioassay data prior to 1982, yet there was no tritium dose listed in MESH for the years in 
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question. The extent of this discrepancy was not known because a comprehensive V&V had not 

been performed. During the June 5, 2012, Work Group meeting, NIOSH (Jim Neton) noted that, 

with an electronic reproduction of the entire available set of tritium logbooks, such a comparison 

would be feasible (ABRWH 2012, WG transcripts, p. 214). 

As for the findings in Sections 5.4.6 and 5.4.7 above, SC&A recommends that the Work Group 

request that NIOSH provide a summary of how it conducted a validation of Mound’s internal 

and external dose databases in this context.

5.4.10. Thorium Bioassay Data

In its 2009 report, Mound Internal Dosimetry Data Adequacy, SC&A (2009c) concluded the 

following: 

In summary, the limited amount of data and the shortcomings associated with 

data interpretation remains for thorium beyond the established SEC period 

ending on February 29, 1959. Although urinalysis data exist for thorium prior to 

1970, procedures on how these samples were analyzed and interpreted are not 

available. The data infers that at least a portion of the thorium analysis was 

analyzed by the radium extraction and differential counting method to measure 

the radium daughter of the thorium. If this is the case, then, as noted by MJW, 

there are a lot of questionable assumptions that need to be made is using an 

excreted daughter to estimate the intake of a parent...the lack of bioassay 

procedure information can make the derivation of the MDA or MDC, which forms 

the basis for NIOSH’s proposed method of assigning missed doses, difficult. 

An additional concern is the potential for Class YY insoluble thorium being handled at Mound. 

In 1996–1997, a particle sizing and solubility (chemical form) study was performed at Mound by 

James and Weaver (1997). While the studies were performed in a limited area of the laboratory, 

information was collected that “for Th-228 and Th-232 samples analyzed to date, it is apparent 

that approximately 100% of the radionuclide is in the very insoluble class YY form in the 

sampled contamination” (this study was performed during decontamination and 

decommissioning (D&D)). With these results and other indications, SC&A found that there were 

significant uncertainties introduced during modeling of thorium dose because of the absence of 

information on the age and chemical solubility of thorium. In its 2009 report, SC&A 

recommended further consideration be given to the impact of the assessment of highly insoluble 

thorium (i.e., Class YY) identified at Mound (SC&A 2009c).

After the 2009 and 2010 SC&A data adequacy and completeness reports, NIOSH and SC&A 

exchanged white papers on the thorium issue (Ulsh and Stewart 2012; SC&A 2012c). 

During the June 5, 2012, Work Group discussion of this topic, these two white papers were 

discussed and the Work Group agreed that, while reliance needs to be place on Mound’s historic 

bioassay program administration, there was no evidence that the program had not been 

adequately administered (ABRWH 2012, WG transcripts, pp. 159–171). The Work Group 

subsequently closed all but the question of Class YY solubility, an issue that NIOSH (Jim Neton) 
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believed had been addressed in terms of dose reconstruction methodology at other DOE sites 

being reviewed; this was to be confirmed and a consistent approach for handling highly insoluble 

thorium applied to Mound (ABRWH 2012, WG transcripts, p. 216). SC&A recommends that the 

Work Group confirm that NIOSH has addressed this question at other DOE sites and whether 

such an approach has been made available for Mound dose reconstructors. 
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6.0 REFERENCES

ABRWH 2008a. Advisory Board on Radiation and Worker Health, Mound Work Group 

meeting, April 1, 2008, transcripts (pp. 147–158).

ABRWH 2008b. Advisory Board on Radiation and Worker Health, Mound Work Group 

meeting, July 14, 2008, transcripts (pp. 227–228).

ABRWH 2009. Advisory Board on Radiation and Worker Health, Mound Work Group meeting, 

May 27, 2009, transcripts (pp. 239–256).

ABRWH 2012. Advisory Board on Radiation and Worker Health, Mound Work Group meeting, 

June 5, 2012.

Chew et al. 2012. Mel Chew, Billy Smith, and Bryce Rich, Responses to Action Items Introduced 

During the Mound Work Group Meeting of June 5, 2012, ORAUT white paper. August 22, 2012.

James and Weaver 1997. W.R. James and R.P. Weaver, Mound Particle Size and Chemical 

Form/Solubility Study, Mound Applied Technologies. September 30, 1997.

Jessen et al. 2013. Karin A. Jessen, Samuel L.T. Chu, Robert L. Morris, Leo G. Faust, Melton H. 

Chew, Eugene W. Potter, and Billy Smith, A Method for Estimating Stable Metal Tritide 

Exposures to Tritium Ancillary Workers Based on Swipe Data in Rooms SW-8, SW13, SW-150 

and R-108 at the Mound Laboratory 1968 to 1989, ORAUT-RPRT-0057, Revision 00. March 7, 

2013.

Kathren and Shockey 2005. R. Kathren and V.E. Shockley, Technical Information Bulletin: 

Dose Reconstruction from Occupationally Related Diagnostic X-ray Procedures, ORAUTOTIB-0006, Revision 03, Oak Ridge Associated Universities, Oak Ridge, Tennessee. December 

21, 2005.

Meyer 1992. H.E. Meyer, History of Mound Bioassay Programs, Volume 1, MLM-MV-93-93-

0003, EG&G Mound Applied Technologies, Mound Facility, Miamisburg, Ohio. September

1992. [SRDB Ref ID: 1962]

MJW 2002. Pre-1989 Dose Assessment Project Phase I and II Final Reports, MJW Corporation, 

Inc. April and June 2002.

NIOSH 2007. SEC Petition Evaluation Report, Petition SEC-00090, Mound Plant, National 

Institute for Occupational Safety and Health, Office of Compensation Analysis and Support, 

Cincinnati, Ohio. December 20, 2007.

NIOSH 2009a. NIOSH Evaluation of Special Tritium Compound Dose-Reconstruction Issues at 

the Mound Laboratory, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. October 2009.
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NIOSH 2009b. NIOSH Evaluation of Data Adequacy and Completeness Issues at the Mound 

Laboratory, National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio. November 2009.

NIOSH 2011. NIOSH Evaluation of Data Adequacy and Completeness Issues at the Mound 

Laboratory, Brant Ulsh, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. August 2011.

NIOSH 2012. NIOSH Response to SC&A’s January 12, 2012 Memo Report on Adequacy and 

Completeness of Mound Internal Dosimetry, National Institute for Occupational Safety and 

Health, Office of Compensation Analysis and Support, Cincinnati, Ohio. May 29, 2012.

ORAUT 2004a. Technical Basis Document for the Mound Site – Site Description, ORAUTTKBS-0016-2, Revision 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

March 30, 2004.

ORAUT 2004b. Technical Basis Document for the Mound Site – Occupational External Dose, 

ORAUT-TKBS-0016-6, Revision 00, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. August 11, 2004.

ORAUT 2006. Technical Basis Document for the Pantex Plant – Occupational Medical Dose, 

ORAUT-TKBS-0016-3, Revision 01, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. March 31, 2006.

ORAUT 2013a. Technical Basis Document for the Mound Site – Site Description, ORAUTTKBS-0016-2, Revision 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 1, 

2013.

ORAUT 2013b. Technical Basis Document for the Mound Site – Occupational Medical Dose, 

ORAUT-TKBS-0016-3, Revision 02, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. March 14, 2013.

ORAUT 2013c. Technical Basis Document for the Mound Site – Occupational Environmental 

Dose, ORAUT-TKBS-0016-4, Revision 01, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. February 7, 2013.

ORAUT 2013d. Technical Basis Document for the Mound Site – Occupational Internal Dose, 

ORAUT-TKBS-0016-5, Revision 02, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. April 18, 2013.

SC&A 2006a. Review of the NIOSH Site Profile for the Mound Laboratory Site, S. Cohen and 

Associates, Inc., Vienna, Virginia. July 16, 2006.

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Inc., Vienna, Virginia. July 16, 2006.
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SC&A 2009a. Mound Internal Dosimetry Data Completeness [Preliminary Draft for the Mound

Plant Work Group Review], S. Cohen and Associates, Inc., Vienna, Virginia. April 2009.

SC&A 2009b. Mound Internal Dosimetry Data Quality Assurance [Preliminary Draft for the 

Mound Plant Work Group Review], S. Cohen and Associates, Inc., Vienna, Virginia. April 2009.

SC&A 2009c. Mound Internal Dosimetry Data Adequacy [Preliminary Draft for the Mound 

Plant Work Group Review], S. Cohen and Associates, Inc., Vienna, Virginia. April 2009.

SC&A 2009d. Response to Modeling of Intakes for Special Tritium Compounds [Preliminary 

Draft for the Mound Working Group Review], Revision 0, S. Cohen and Associates, Inc., 

Vienna, Virginia. April 2009.

SC&A 2011. Mound SEC Issues Matrix – for SEC Petition SEC-0009, S. Cohen and Associates, 

Inc., Vienna, Virginia. November 2, 2011.

SC&A 2012a. Mound Work Group – Site Profile Issues Stemming from SEC Review (2008–

2012), S. Cohen and Associates, Inc., Vienna, Virginia. May 25, 2012.

SC&A 2012b. Adequacy and Completeness of Mound Internal Dosimetry – Work Group Issues,

memorandum from Joseph Fitzgerald, SC&A, to Mound Work Group, January 12, 2012.

SC&A 2012c. Ron Buchanan, SC&A’S Evaluation of NIOSH’s April 2012 Mound Laboratory 

Th-232 White Paper, S. Cohen and Associates, Inc., Vienna, Virginia. May 2012.

Ulsh and Stewart 2012. B.A. Ulsh and D.N. Stewart, Retrospective Dose Reconstruction for 

Thorium-232 Activities at the Mound Laboratory, National Institute for Occupational Safety and 

Health. April 2012.