September 15, 2006 

Mr. David Staudt 

Centers for Disease Control and Prevention 

Acquisition and Assistance Field Branch 

Post Office Box 18070 

626 Cochrans Mill Road – B-140 

Pittsburgh, PA 15236-0295 

Subject: Contract No. 200-2004-03805, Task Order 1: Review of the NIOSH Site Profile 

for the Pinellas Plant Site, SCA-TR-TASK1-0015 

Dear Mr. Staudt: 

SC&A is pleased to submit to NIOSH and the Advisory Board our draft Review of the NIOSH 

Site Profile for the Pinellas Plant Site. 

If you have any questions or comments on this report, please contact John Mauro at 732-530-

0104. We look forward to discussing this draft report with NIOSH and the Advisory Board. 

Project Manager 

cc: P. Ziemer, PhD, Board Chairperson A. Makhijani, PhD, SC&A 

Advisory Board Members H. Behling, SC&A 

L. Wade, PhD, NIOSH M. Thorne, SC&A 

L. Elliott, NIOSH H. Chmelynski, SC&A 

J. Neton, PhD, NIOSH J. Fitzgerald, Saliant 

S. Hinnefeld, NIOSH J. Lipsztein, SC&A 

L. Homoki-Titus, NIOSH K. Robertson-DeMers, CHP, Saliant 

A. Brand, NIOSH S. Ostrow, PhD, SC&A 

J. Broehm, NIOSH K. Behling, SC&A 

L. Shields, NIOSH T. Bell, Saliant 

Project File (ANIOS/001/15) 

Sincerely, 

John Mauro, PhD, CHP 

1608 SPRING HILL ROAD, SUITE 400 • VIENNA, VIRGINIA • 22182 • 703.893.6600 • FAX 703.821.8236 
Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute of Occupational Safety and Health 

Review of the NIOSH Site Profile for the Pinellas Plant Site 

Contract No. 200-2004-03805 

Task Order No. 1 

SCA-TR-TASK1-0015
 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc.
 

5579 Catholic Church Road 

Jefferson, Maryland 21755
 

September 15, 2006 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted. 
 

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S. Cohen & Associates: Document No. 

SCA-TR-TASK1-0015 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of 

Effective Date: 

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NIOSH Dose Reconstruction Program Revision No. 0 – Draft 

REVIEW OF THE NIOSH SITE PROFILE 

FOR THE PINELLAS PLANT SITE Page 1 of 70 

Task Manager: 

________________________ Date: ___________ 

Charles Phillips 

Supersedes: 

N/A 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 
 

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TABLE OF CONTENTS 

Acronyms and Abbreviations ..........................................................................................................5 

1.0 Executive Summary .............................................................................................................7 

2.0 Scope and Introduction ......................................................................................................14 

2.1 Review Approach...................................................................................................15 

2.2 Report Organization ...............................................................................................15 

3.0 Assessment Criteria and Methods......................................................................................17 

3.1 Objectives ..............................................................................................................17 

3.1.1 Objective 1: Completeness of Data Sources ........................................17 

3.1.2 Objective 2: Technical Accuracy.........................................................17 

3.1.3 Objective 3: Adequacy of Data............................................................18 

3.1.4 Objective 4: Consistency Among Site Profiles ....................................18 

3.1.5 Objective 5: Regulatory Compliance ...................................................18 

3.2 Site Profile Strengths .............................................................................................21 

4.0 Vertical Issues ....................................................................................................................23 

4.1 Finding 1: Reconstruction of Doses in the Absence of Early Health 

Physics, Industrial Hygiene, and Environmental Records .....................................23 

4.2 Finding 2: Potential Doses from Insoluble Metal Tritides Not Sufficiently 

Addressed...............................................................................................................23 

4.3 Finding 3: MDCs and Uncertainties for Plutonium and Bioassay 

Measurements are Inadequately Addressed ...........................................................24 

4.4 Finding 4: Assessment of Personnel Badging Policy During Early Years 

Needs Further Review............................................................................................25 

4.5 Finding 5: Problems with Personnel Dosimetry ...................................................25 

4.6 Finding 6: The Decontamination and Decommission Era of Pinellas 

Operations is Not Sufficiently Addressed..............................................................26 

4.7 Finding 7: Missing Internal Dose Estimation Methods for Unmonitored 

Workers, such as Maintenance and Support Personnel, Not Provided ..................26 

4.8 Finding 8: Potential for Missed Dose for Depleted Uranium ...............................26 

4.9 Finding 9: The TBD Fails to Adequately Define and Assess Occupational 

Medical Exposure ..................................................................................................27 

4.10 Finding 10: Techniques and Protocols Increase Uncertainty of Dose 

Correction Factors listed in the TBD .....................................................................28 

4.11 Finding 11: Frequency and Type of X-ray Exposure is Uncertain .......................28 

4.11.1 Secondary Issues ...................................................................................29 

5.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................33 

5.1 Satisfying the Five Objectives ...............................................................................33 

5.1.1 Objective 1: Completeness of Data Sources ........................................33 

5.1.2 Objective 2: Technical Accuracy.........................................................35 

5.1.3 Objective 3: Adequacy of Data............................................................36 

5.1.4 Objective 4: Consistency among Site Profiles .....................................36 
 

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5.1.5 Objective 5: Regulatory Compliance ...................................................37 

6.0 Usability of Site Profile for Intended Purpose ...................................................................38 

6.1 Ambiguous Dose Reconstruction Direction ..........................................................38 

6.2 Inconsistencies and Editorial Errors in the Site Profiles........................................39 

6.3 Unresolved Policy or Generic Technical Issues ....................................................39 

7.0 References..........................................................................................................................41 

Attachment 1: Technical Documents Considered During the Review .........................................43 

Attachment 2: Site Expert Interview Summary ............................................................................44 

Attachment 3: Key Questions for NIOSH/ORAU Regarding Site Profile Documents ................54 

Attachment 4: NIOSH Responses to SC&A Key Questions ........................................................66 

Attachment 5: Summary of Conference Call on SC&A Questions Provided to NIOSH .............67 

Attachment 6: Overview of NIOSH Recommended Dose Reconstruction Procedures for 

the Pinellas Plant................................................................................................................68 
 

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ACRONYMS AND ABBREVIATIONS 

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

CFR Code of Federal Regulations 

Ci Curie 

D&D Decontamination and Decommissioning 

DCF Dose correction factor 

DOE Department of Energy 

DOL Department of Labor 

DU Depleted uranium 

dpm Disintegrations per Minute 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ES&H Environmental, Safety, and Health Group 

GE General Electric Corporation 

GEND General Electric Aerospace, Neutron Devices 

HHS Health and Human Services 

HTO Tritium Oxide or Tritiated Water 

HVL Half value layer 

ICRP International Commission on Radiological Protection 

KUB Kidney, Ureter, Bladder 

LANL Los Alamos National Laboratory 

LAT Lateral 

LLNL Lawrence Livermore National Laboratory 

LOD Limit of Detection 

μCi Microcurie 

MDA Minimum Detectable Activity 

MDC Minimum Detectable Concentration 

MDL Minimum Detectable Level 

mL milliliter 

mm millimeter 

MeV Million electron volts 

MMSC Martin Marietta Specialty Components, Inc. 
 

 

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mrem Millirem 

NCRP National Council on Radiation Protection and Measurements 

NIOSH National Institute for Occupational Safety and Health 

NTA Eastman Kodak Nuclear Track Film Type A 

NTS Nevada Test Site 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 

OTIB ORAU Technical Information Bulletin 

PA Posterior-Anterior 

PFG Photofluorography 

PoBe Polonium-beryllium 

POC Probability of Causation 

RadCon Radiological Control 

rem Roentgen equivalent man 

RTG Radioisotope Thermoelectric Generator 

SC&A S. Cohen and Associates 

SMT Stable Metal Tritide 

SNL Sandia National Laboratory 

SRS Savannah River Site 

SSD Skin to Surface Distance 

TBD Technical Basis Document 

TIB NIOSH Technical Information Bulletin 

TLD Thermoluminescent Dosimeter 

TTA Tube Transformer Assembly 
 

 

 

 

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1.0 EXECUTIVE SUMMARY 

This report provides the results of an independent audit of the Pinellas technical basis documents 

(TBDs) conducted by S. Cohen and Associates (SC&A, Inc.). The TBDs reviewed make up the 

site profile developed by the National Institutes for Occupational Safety and Health (NIOSH) for 

the Pinellas Plant. This audit was conducted during the period May 2006–August 10, 2006, in 

support of the Advisory Board on Radiation and Worker Health (Advisory Board) in its statutory 

responsibility under the Energy Employees Occupational Illness Compensation Program Act of 

2000 (EEOICPA). This authority includes the conduct of such reviews and advising the 

Secretary of Health and Human Services (HHS) on the “completeness and adequacy” of the 

EEOICPA program. 

The Pinellas Plant was located in central Pinellas County, Florida. The initial mission of the 

Pinellas Plant was to manufacture neutron generators and other components for nuclear weapons. 

Because of its success in the manufacture of neutron generators and the possession of the 

required equipment, facilities, and expertise that could be applied to a variety of specialty 

components, the Department of Energy (DOE) expanded the Pinellas Plant mission to produce 

multiple electronic and support components for other DOE programs. These components 

included thermal and long-life ambient temperature batteries, specialized shock-absorbing foam 

supports, ferroelectric- and glass-ceramic encapsulation materials, and Radioisotope 

Thermoelectric Generators (RTGs). This expansion included relocation of a similar production 

facility from Milwaukee, Wisconsin, to Pinellas during the 1966–1967 timeframe. 

The plant was constructed in 1956 by the General Electric Corporation (GE) for the 

development and production of neutron generators for the nation’s nuclear weapons programs. 

The Atomic Energy Commission (AEC) (predecessor of DOE) purchased the Pinellas Plant 

from GE in 1957, and contracted them to operate the site from its startup in 1957 until May 31, 

1992. In June 1992, Martin Marietta Specialty Components, Inc. (MMSC), took over operation 

of the facility, and served as the managing and operating contractor until the site was shut down 

in September of 1994. As part of the DOE program to promote commercial uses of the site, 

DOE sold most of the Pinellas Plant to the Pinellas County Industry Council on March 17, 

1995. 

Questions have been submitted to NIOSH and its technical support contractor, Oak Ridge 

Associated Universities (ORAU), regarding issues developed during the course of this review. 

As of the date of this draft, no response to those questions has been received by SC&A. Once 

the responses have been received, a conference call will be conducted with NIOSH to clarify and 

resolve any standing issues. The response to the questions and a summary of the conference call 

will be included in the final report for the Pinellas Plant audit. At the current time, it appears that 

it will not be possible to hold a conference call with NIOSH regarding our questions. Hence, this 

draft report is being delivered to NIOSH and the Advisory Board without the benefit of the 

conference call. 

The TBDs were evaluated for their completeness, technical accuracy, adequacy of data, 

compliance with stated objectives, and consistency with other site profiles, as stipulated in the 
 

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SC&A Standard Operating Procedure for Performing Site Profile Reviews (SC&A 2004). As 

“living” documents, TBDs are constantly being revised as new information, experience, or issues 

arise. The complete list of the Pinellas TBDs, as well as supporting documents, that were 

reviewed by SC&A is provided in Attachment 1. 

This review found that the site profile provides an excellent overview of the Plant operations and 

characterizes the primary radiological exposure sources and conditions. The presentation and 

analyses of the available data were generally technically sound. However, the TBDs failed to 

fully address the exposure implications of these and other radiation sources, as well as the 

potential impact of identified deficiencies in historic dosimetry program implementation. A 

particular concern is the lack of material describing the activities at the facility prior to 1980, 

bringing into question the ability to adequately assign appropriate radiation doses during the 

early years at Pinellas. Even though the tritium and plutonium exposures and dosimetry are 

characterized, the implications to dose reconstruction of metal tritides are not adequately 

addressed. Likewise, the “established” radiation dosimetry program is discussed in terms of 

what limits of detection (LOD), minimum detectable activity (MDA), monitoring frequencies, 

and badging policies were the policy and site practice at the time, without qualifying this 

information with past and current information regarding how effectively the dosimetry program 

was actually carried out. 

With respect to sources of radiological exposure, the site profile provides dose characterization 

data for tritium, krypton-85, metal tritides, and plutonium, but does not fully address the 

uncertainties involved with conducting dose estimation. 

It is not clear from the Internal Dosimetry TBD (ORAU-TKBS-0029-5) how dose estimation 

would be performed for maintenance and support workers who were not classified as radiation 

workers and who had access to Pinellas radiological operations. No guidance is provided in this 

TBD with respect to missed dose calculations for unmonitored workers, such as support 

personnel whose actual jobs (contamination spill cleanup, equipment maintenance, janitorial 

functions) could have led to exposures comparable to those of radiation workers, and whose 

access to various Pinellas buildings may have led to a variety of radionuclide exposures over 

their job history. In addition, the TBD gives values for use by dose reconstructors for adjusting 

bioassay data for missed dose, but fails to provide a succinct summary of all the factors. 

The Occupational Medical Dose TBD (ORAUT-TKBS-0029-3) does little to reasonably 

document the variety of medical occupational exposures, and the lack of documentation on the 

type of equipment and the maintenance records does little to assure that a conservative and 

claimant-favorable estimation of dose is possible. This circumstance would suggest the need to 

reconsider a worst-case approach to establishing dose. NIOSH should revisit and update, as 

needed, Sections 3.2 and 3.3 of the TBD. 

Since the primary radionuclide employed at Pinellas was tritium, external dose issues are 

minimized because of the extremely small occupational external doses evolving from plant 

operations. However, there were some minor concerns relative to the treatment of external 

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An overall comment on ORAU-TKBS-0029-4 is that some of the topics covered in the TBD are 

treated in an almost cavalier fashion. An example is the treatment of uncertainty in this 

document. This lack of attention to detail could have been a result of the extremely small 

external doses projected for plant operations. While SC&A would agree with the concept of 

keeping effort and resources for TBD development consistent with the magnitude of the impact 

involved, the effort should be technically sound and reasonably comprehensive. 

Decontamination and decommissioning (D&D) activities at Pinellas are not addressed from the 

standpoint of historic radiation exposure history and dose estimations. While this experience is 

relatively recent (1994–1997) and founded on contemporary radiation protection standards and 

technology, it is also clear that a fundamental shift occurred with this transition regarding 

potential radiation hazards and radiological control philosophy. The site profile is essentially 

silent on any treatment of radiation exposure experience during this period, and for dosimetric 

techniques applied for the bulk of D&D and waste management activities. 

Interviews were conducted with 10 former Pinellas Plant workers whose employment spanned 

the years 1956 to 1995. The purpose of these interviews was to receive first-hand accounts of 

past radiological control and personnel monitoring practices at Pinellas in order to better 

understand how operations were conducted. Interviews were conducted in small groups and oneon-one in St. Petersburg, Florida, on May 27–29, 2006. The interviews sought to solicit only 

unclassified information, as there were a number of operations conducted at Pinellas related to 

weapons components that are considered classified and could not be discussed. 

Interviewees were initially identified from NIOSH’s Worker Outreach meeting minutes. NIOSH 

could not disclose contact information for the workers because of Privacy Act issues; thus SC&A 

identified these former workers via the local telephone directory and contacted them by 

telephone. Through the first few telephone calls, SC&A was able to make contact with the 

leader of the Quarter Century Club, a former employee association that assisted SC&A in 

identifying additional workers. This method of identification of site experts was time-consuming 

and delayed completion of the employee interview portion of the site profile review. 

Workers were briefed on the purpose of the interviews and the Pinellas Plant Site Profile. 

Participants were cautioned to avoid providing classified information during the interviews, and 

were given the opportunity to review the summary interview for accuracy and completeness as a 

safeguard against missing key issues or misinterpreting provided information. Some 

disagreement between site experts arose related to documented policies for radiation protection 

versus actual practice, and for the sake of completeness, both views are presented in the 

summary. 

All interviews have been compiled and summarized in Attachment 2. The information provided 

is not a verbatim documentation, but a summary of information from multiple interviews. 

Individuals have provided this information based on their personal experience, and it is possible 

that these former workers’ recollections and statements may need to be further substantiated. 

However, they stand as critical feedback on the operation of the Pinellas Plant over its operating 

lifetime. The interview notes are provided in that context, and former worker input is similarly 
 

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reflected in our discussion and, with the preceding qualifications in mind, has contributed to our 

findings and observations. 

Issues presented in this report are sorted into the following categories, in accordance with 

SC&A’s review procedures: 

(1) Completeness of Data Sources 

(2) Technical Accuracy 

(3) Adequacy of Data 

(4) Consistency among Site Profiles 

(5) Regulatory Compliance 

Following the introduction and a description of the criteria and methods employed to perform the 

review, the report discusses the strengths of the TBDs, followed by a description of the major 

issues identified during our review. The issues were carefully reviewed with respect to the five 

review criteria. Several of the issues were designated as findings, because they represent 

deficiencies in the TBDs that need to be corrected, and which have the potential to materially 

impact at least some dose reconstructions. 

Finding 1: Reconstruction of Doses in the Absence of Early Health Physics, Industrial 

Hygiene, and Environmental Records 

The absence of pre-1980s records brings into question the ability to adequately assign radiation 

doses during the early years at Pinellas. The improvements in radiological monitoring and 

bioassay methodology, instrumentation, and in health physics, industrial hygiene, and 

environmental control programs, contraindicate the use of 1980s documentation for determining 

radiation doses for the early years of plant operations. The assumptions incorporated into 

ORAU-TKBS-0029-4 and ORAU-TKBS-0029-5, given the absence of firm information, appear 

to be claimant favorable. However, the uncertainties associated with projections without 

documentary evidence may result in missing doses that may not be accounted for by the 

claimant-favorable assumptions indicated in the documents. 

Finding 2: Potential Doses from Insoluble Metal Tritides Not Sufficiently Addressed 

The neutron tube manufacturing process required spray coating the inside of a glass tube with a 

thin metal film, resulting in the formation of insoluble stable metal tritides (SMTs), namely 

ScT2, ErT2, and TiT2. There is no internal documentation indicating that there were adequate 

means of detecting exposures or monitoring SMTs. No guidance is provided for estimating the 

exposure to metal tritides; in fact, Section 5.9.2, Metal Tritide Exposures, is reserved for later 

entry. The practice of destructive testing of neutron generators and the methodology for 

performing the testing make it possible that exposures to metal tritides occurred. Further 

discussion of the potential exposure pathway and doses should be included in ORAUT-TKBS0029-5 when Section 5.9.2 is completed. 
 

 

 

 

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Finding 3: MDCs and Uncertainties for Plutonium and Bioassay Measurements are 

Inadequately Addressed (ORAU-TKBS-0029-5) 

ORAU-TKBS-0029-5 should provide more information about how bioassay sample activity 

concentrations were calculated and the uncertainties associated with these values. NIOSH 

should provide information on the use of the values in Table 5.1 to calculate internal doses. 

The TBD should specifically address the uncertainties and the minimum detectable concentration 

(MDC) of the bioassay measurements, including the parameters of the MDC equation 5-1 on 

page 6, assigned as TREVA (T = count time, R = recovery fraction, E = average detector 

efficiency, V = sample volume (L), and A = the alpha abundance for the radionuclide in 

question. 

Finding 4: Assessment of Personnel Badging Policy during Early Years Needs Further 

Review 

ORAUT-TKBS-0029-6 states the following: 

From 1960 to 1973, U.S. Atomic Energy Commission (AEC) annual exposure 

summary reports indicate that Pinellas had 27.5% of its labor force wearing 

dosimetry (377 of an average yearly labor force of 1,372). During the 1980s, 

while the data are not completely available, from 370 to approximately 400 of 

1,650 to 1,975 workers (approximately 20%) were monitored for radiation dose. 

No documentation was found to show that all employees were monitored at some 

time during Pinellas operations. 

It is important to know who was considered a “radiation worker” and how they were selected for 

badging, as this has dose consequence. The TBD does not clearly address these issues by 

clarifying the basis for how monitoring was conducted, nor which worker categories were 

badged. These issues need to be reviewed and substantiation provided that the maximally 

exposed workers were badged, and that there is a means to estimate radiation dose to 

unmonitored support workers with access to production areas. 

Finding 5: Problems with Personnel Dosimetry 

Section 6.2.2 of ORAUT-TKBS-0029-6 states the following: 

This analysis was unable to locate specific designs of the film dosimeters used for 

approximately the first 20 years (1957 to 1974) at the Pinellas Plant, and there is 

limited documentation that indicates there was an early relationship with 

Nuclear-Chicago (GEND 2004a). 

Table 6-5 on page 16 of ORAUT-TKBS-0029-6 assigns a missed dose of 0.24 rem for betaphotons (monthly) for badges used during this time period. This assignment of missing dose 

evidently assumes that the badges used during this time period were equivalent to those provided 
 

 

 

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by Nuclear-Chicago. Additional discussion is needed on the uncertainty associated with the 

assumed missing dose, given that the origin of the dosimetry is not clearly established. 

Finding 6: The Decontamination and Decommission Era of Pinellas Operations is not 

Sufficiently Addressed 

Monitoring practices, particularly internal dosimetry, are not specified in the TBD for the D&D 

period (1995–1997) at the Pinellas Plant. A number of questions present themselves that are not 

addressed by the existing Pinellas Plant Site Profile. What specific external and internal 

monitoring program was established for D&D operations, and how effectively was it 

implemented? With the use of first-, second-, and third-tier subcontractors, to what extent were 

these workers “captured” in the site’s dosimetry program, and were their records maintained? 

How would the co-worker dose model be applied for unmonitored workers located adjacent to 

D&D operations; was resuspension of radioactive particulates an onsite issue during D&D? 

Finding 7: Missing Internal Dose Estimation Methods for Unmonitored Workers, such as 

Maintenance and Support Personnel, Not Provided 

It is not clear from the Internal Dosimetry TBD (ORAUT-TKBS-0029-5) how dose estimation 

would be performed for maintenance and support workers who were not classified as radiation 

workers, and who had access to Pinellas Plant radiological operations. Section 5.9.1 of ORAUTTKBS-0029-5 contains the statement, “All HTO and Plutonium potentially exposed workers have 

likely been monitored.” The basis for this statement needs justification, particularly in light of the 

fact that tritium use and contamination was common in many Pinellas areas that may have been 

accessable to maintenance and, possibly, administrative personnel. However, no guidance is 

provided in this TBD with respect to missed dose calculations for unmonitored workers in the 

category of support personnel, whose actual jobs (contamination spill cleanup, equipment 

maintenance, and janitorial functions) and access to various Pinellas buildings may have led to 

radionuclide exposures over their job history. It is also not clear how the designation of 

“radiological worker” was historically defined at Pinellas, and how workers were selected on this 

basis for bioassay for various operations. 

Finding 8: Potential for Missed Dose for Depleted Uranium 

ORAUT-TKBS-0029-2, Section 2.3.2 contains a discussion of depleted uranium (DU), including 

the following statement: 

The depleted uranium metal was fully contained inside the storage flask, and no 

information could be found to indicate that depleted uranium metal was released 

during plant operations (Ward, p. 12). 

Interviews with a former employee raised the possibility of loose DU contamination in an area of 

Building 100. There were no bioassay programs in place to determine internal dose from 

exposure to DU, thus DU internal exposure could represent a significant source of unmonitored 

exposure. There is minimal information in ORAUT-TKBS-0029-2 on the production of the 
 

 

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tritium beds, so it is not possible to discern if the process involves operations that could lead to 

internal exposures. Further discussion of the DU-related process is in order. 

Finding 9: The TBD Fails to Adequately Define and Assess Occupational Medical 

Exposure 

The current guidelines, as presented in Kathren and Shockley (2005), go a long way in assuring 

that all occupational medical exposures are reasonably included in determining the overall dose 

estimations for claimants. Unfortunately, the interpretation, to date, by the contractor, ORAU, 

has not been applied conservatively to be claimant favorable. The Occupational Medical Dose 

TBD (Demopoulos 2006) assumes an interpretation that also has been considered and applied at 

other sites, such as the Mound Plant and Los Alamos National Laboratory (LANL), and 

Paducah. To this extent, the assumption that medical procedures are limited to only one preemployment chest x-ray and chest x-rays that are part of routine physical exams may 

substantially underestimate worker medical exposure when evaluating occupational medical 

exposure. 

Finding 10: Techniques and Protocols Increase Uncertainty of Dose Correction Factors 

Listed in the TBD 

Section 3.2 of the Occupational Medical Dose TBD fails to adequately describe all the 

information upon which to establish beam quality for x-ray units in use from 1957–1997. 

The TBD is also deficient in that little documentation exists to validate x-ray protocols, 

equipment maintenance, and upkeep records prior to 1972. 

Finding 11: Frequency and Type of X-ray Exposure is Uncertain 

The Occupational Medical Dose TBD relies on a very limited review of archived medical 

records to establish frequency assumptions. The assumption of one chest radiograph (PosteriorAnterior view) every 3 to 5 years is not reasonably conservative, in that workers could 

essentially request an x-ray, or be subject to special screening exams. In addition, Section 3.2 of 

the Occupational Medical Dose TBD does not provide documentation or references to support 

the assumption that only a limited group of workers received x-ray exams more frequently than 

every 5 years after 1974. 

In addition, Section 3.2 of the TBD states that photofluorography (PFG) units, although 

generally available up to the late 1950s at most DOE sites, were not documented as being used at 

the Pinellas Plant. The undocumented absence of PFG units at Pinellas clearly has significant 

dose implications to workers who may have been given much higher doses from PFG units. 
 

 

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2.0 SCOPE AND INTRODUCTION 

Under the Energy Employees Occupational Illness Compensation Program Act of 2000 

(EEOICPA) and Federal regulations defined in Title 42, Part 82, Methods for Radiation Dose 

Reconstruction Under the Energy Employees Occupational Illness Compensation Program, of 

the Code of Federal Regulations (42 CFR 82), the Advisory Board on Radiation and Worker 

Health (Advisory Board) is mandated to conduct an independent review of the methods and 

procedures used by the National Institute for Occupational Safety and Health (NIOSH) and its 

contractors for dose reconstruction. As a contractor to the Advisory Board, S. Cohen and 

Associates (SC&A, Inc.) has been charged under Task 1 to support the Advisory Board in this 

effort by independently evaluating a select number of site profiles that correspond to specific 

facilities at which energy employees worked and were exposed to ionizing radiation. 

This report provides a review of the following six technical basis documents (TBDs) related to 

historical occupational exposures at Pinellas Site: 

• 	 ORAUT-TKBS-0029-1, Technical Basis Document for Pinellas Plant – Introduction, 

Rev. 00 (Notich 2005) 

• 	 ORAUT-TKBS-0029-2, Technical Basis Document for Pinellas Plant – Site Description, 

Rev. 00 (Orr 2005) 

• 	 ORAUT-TKBS-0029-3, Technical Basis Document for Pinellas Plant – Occupational 

Medical Dose, Rev. 00 PC-1 (Demopoulos 2006) 

• 	 ORAUT-TKBS-0029-4, Technical Basis Document for Pinellas Plant – Occupational 

Environmental Dose, Rev. 00 (Gorden and Mobasheran 2005) 

• 	 ORAUT-TKBS-0029-5, Technical Basis Document for Pinellas Plant – Occupational 

Internal Dose, Rev 00 (Demopoulos 2005) 

• 	 ORAUT-TKBS-0029-6, Technical Basis Document for Pinellas Plant – Occupational 

External Dosimetry, Rev. 00 (Palmrose et al. 2005) 

A complete list of documents reviewed for this audit, including the above, is provided in 

Attachment 1. 

SC&A, in support of the Advisory Board, has critically evaluated the Pinellas Plant TBDs for the 

following: 

• 	 Determine the completeness of the information gathered by NIOSH in behalf of the site 

profile, with a view to assessing its adequacy and accuracy in supporting individual dose 

reconstructions 

• 	 Assess the technical merit of the data/information 

• 	 Assess NIOSH’s use of the data in dose reconstructions 
 

 

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SC&A’s review of the six TBDs focuses on the quality and completeness of the data that 

characterize the facility and its operations, and the use of these data in dose reconstruction. The 

review was conducted in accordance with SC&A Standard Operating Procedure for Performing 

Site Profile Reviews (SC&A 2004), which was approved by the Advisory Board. 

The review is directed at “sampling” the site profile analyses and data for validation purposes. 

The review does not provide a rigorous quality control process, whereby actual analyses and 

calculations are duplicated or verified. The scope and depth of the review are focused on aspects 

or parameters of the site profile that would be particularly influential in deriving dose 

reconstructions, bridging uncertainties, or correcting technical inaccuracies. 

The six TBDs serve as site-specific guidance documents used in support of dose reconstructions. 

These site profiles provide the health physicists who conduct dose reconstructions on behalf of 

NIOSH with consistent general information and specifications to support their individual dose 

reconstructions. This report was prepared by SC&A to provide the Advisory Board with an 

evaluation of the degree to which the TBDs can support dose reconstruction decisions. The 

criteria for evaluation include whether the TBDs provide a basis for scientifically supportable 

dose reconstructions in a manner that is adequate, complete, efficient, and claimant favorable. 

Specifically, these criteria were viewed from the position of whether dose reconstructions based 

on the TBDs would provide for robust compensation decisions. 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and determine the level of exposure a worker received in that 

environment through time. The hierarchy of data used for developing dose reconstruction 

methodologies is dosimeter readings and bioassay data, co-worker data and workplace 

monitoring data, and process description information or source-term data. 

2.1 REVIEW APPROACH 

SC&A’s review of the TBDs and supporting documentation concentrated on determining the 

completeness of data collected by NIOSH, the adequacy of existing Pinellas personnel and 

environmental monitoring data, and the evaluation of key dose reconstruction assumptions. 

2.2 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board, this report is organized into 

the following sections: 

(1) Executive Summary 

(2) Scope and Introduction 

(3) Assessment Criteria and Method 

(4) Site Profile Strengths 

(5) Vertical Issues 

(6) Overall Adequacy of the Pinellas Site Profile as a Basis for Dose Reconstruction 
 

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Based on the issues raised in each of these sections, SC&A prepared a list of findings, which is 

found in the Executive Summary. Issues are designated as findings if SC&A believes that they 

represent deficiencies in the TBD that need to be corrected, and which have the potential to have 

a material impact on at least some dose reconstructions. Issues can also be designated as 

secondary issues if they simply raise questions, which, if addressed, would further improve the 

TBDs and may possibly reveal deficiencies that will need to be addressed in future revisions of 

the TBDs. 

Many of the issues that surfaced in the report correspond to more than one of the major 

objectives (i.e., strengths, completeness of data, technical accuracy, consistency among site 

profiles, and regulatory compliance). Section 6.0 provides a list of the issues in summary form, 

and to which objective the particular issue applies. 

In many ways, the TBDs were successful in addressing a series of technical challenges. In other 

areas, the TBDs exhibit shortcomings that may influence some dose reconstructions in a 

substantial manner. 
 

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3.0 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profiles that is used in the 

individual dose reconstruction process. These documents are reviewed for their completeness, 

technical accuracy, adequacy of data, consistency with other site profiles, and compliance with 

the stated objectives, as defined in SC&A Standard Operating Procedure for Performing Site 

Profile Reviews (SC&A 2004). This review is specific to the Pinellas Plant Site Profile, 

supporting technical information bulletins (TIBs), and dose reconstruction workbooks; however, 

items identified in this report may be applied to other facilities, especially facilities with similar 

source terms and exposure conditions. The review identifies a number of issues, and discusses 

the degree to which the site profile fulfills the review objectives delineated in SC&A’s site 

profile review procedure. 

3.1 OBJECTIVES 

SC&A reviewed the site profile with respect to the degree to which technically sound judgments 

or assumptions are employed. In addition, the review identifies assumptions by NIOSH that give 

the benefit of the doubt to the claimant. 

3.1.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The two elements examined under this objective include (1) determining if the site 

profile made use of available data considered relevant and significant to the dose reconstruction, 

and (2) investigating whether other relevant/significant sources are available, but were not used 

in the development of the site profile. For example, if data are available in site technical reports 

or other available site documents for particular processes, and if the TBDs have not taken into 

consideration these data where it should have, this would constitute a completeness-of-data issue. 

The Oak Ridge Associated Universities (ORAU) site profile document database, including the 

referenced sources in the TBDs, was evaluated to determine the relevance of the data collected 

by NIOSH to the development of the site profile. Additionally, SC&A evaluated records 

publicly available relating to the Pinellas Plant and records provided by site experts. 

3.1.2 Objective 2: Technical Accuracy 

SC&A reviewed the site profile with respect to Objective 2, which requires SC&A to perform a 

critical assessment of the methods used in the site profile to develop technically defensible 

guidance or instruction, including evaluating field characterization data, source term data, 

technical reports, standards and guidance documents, and literature related to processes that 

occurred at the Pinellas Plant. The goal of this objective is to first analyze the data according to 

sound scientific principles, and then to evaluate this information in the context of compensation. 

If, for example, SC&A found that the technical approach used by NIOSH was not scientifically 

sound or claimant favorable, this would constitute a technical accuracy issue. 
 

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3.1.3 Objective 3: Adequacy of Data 

SC&A reviewed the site profile with respect to Objective 3, which requires SC&A to determine 

whether the data and guidance presented in the site profile are sufficiently detailed and complete 

to conduct dose reconstruction, and whether a defensible approach has been developed in the 

absence of data. In addition, this objective requires SC&A to assess the credibility of the data 

used for dose reconstruction. The adequacy of the data identifies gaps in the facility data that 

may influence the outcome of the dose reconstruction process. For example, if a site did not 

monitor all workers exposed to neutrons who should have been monitored, this would be 

considered a gap and, thus, an inadequacy in the data. 

3.1.4 Objective 4: Consistency Among Site Profiles 

SC&A reviewed the site profile with respect to Objective 4, which requires SC&A to identify 

common elements within site profiles completed or reviewed to date, as appropriate. In order to 

accomplish this objective, the Pinellas Plant TBD was compared with the Mound and Savannah 

River Site (SRS) site profiles. In particular, this dealt with how each site handled and is handling 

dose reconstruction for workers exposed to plutonium, stable metal tritides, and tritium. 

3.1.5 Objective 5: Regulatory Compliance 

SC&A reviewed the site profile with respect to Objective 5, which requires SC&A to evaluate 

the degree to which the site profile complies with stated policy and directives contained in 

42 CFR 82. In addition, SC&A evaluated the TBD for adherence to general quality assurance 

policies and procedures utilized for the performance of dose reconstructions. 

In order to place the above objectives into the proper context as they pertain to the site profile, it 

is important to briefly review key elements of the dose reconstruction process, as specified in 

42 CFR 82. Federal regulations specify that a dose reconstruction can be broadly placed into one 

of three discrete categories. These three categories differ greatly in terms of their dependence on 

and the completeness of available dose data, as well as on the accuracy/uncertainty of data. 

Category 1: Least challenged by any deficiencies in available dose/monitoring data are dose 

reconstructions for which even a partial assessment (or minimized dose(s)) corresponds to a 

probability of causation (POC) value in excess of 50%, and assures compensability to the 

claimant. Such partial/incomplete dose reconstructions with a POC greater than 50% may, in 

some cases, involve only a limited amount of external or internal data. In extreme cases, even a 

total absence of a positive measurement may suffice for an assigned organ dose that results in a 

POC greater than 50%. For this reason, dose reconstructions in behalf of this category may only 

be marginally affected by incomplete/missing data or uncertainty of the measurements. In fact, 

regulatory guidelines recommend the use of a partial/incomplete dose reconstruction, the 

minimization of dose, and the exclusion of uncertainty for reasons of process efficiency, as long 

as this limited effort produces a POC of greater than or equal to 50%. 
 

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Category 2: A second category of dose reconstruction is defined by Federal guidance, which 

recommends the use of “worst-case” assumptions. The purpose of worst-case assumptions in 

dose reconstruction is to derive maximal or highly improbable dose assignments. For example, a 

worst-case assumption may place a worker at a given work location 24 hours per day and 

365 days per year. The use of such maximized (or upper-bound) values, however, is limited to 

those instances where the resultant maximized doses yield POC values below 50%, which are 

not compensated. For this second category, the dose reconstructor needs only to ensure that all 

potential internal and external exposure pathways have been considered. 

The obvious benefit of worst-case assumptions and the use of maximized doses in dose 

reconstruction is efficiency. Efficiency is achieved by the fact that maximized doses avoid the 

need for precise data and eliminates consideration for the uncertainty of the dose. Lastly, the use 

of bounding values in dose reconstruction minimizes any controversy regarding the decision not 

to compensate a claim. 

Although simplistic in design, to satisfy this type of a dose reconstruction, the TBD must, at a 

minimum, provide information and data that clearly identify (1) all potential radionuclides, 

(2) all potential modes of exposure, and (3) upper limits for each contaminant and mode of 

exposure. Thus, for external exposures, maximum dose rates must be identified in time and 

space that correspond to a worker’s employment period, work locations, and job assignments. 

Similarly, in order to maximize internal exposures, the highest air concentrations and surface 

contaminations must be identified. 

Category 3: The most complex and challenging dose reconstructions consist of claims where 

the case cannot be dealt with by one of the two categories above. For instance, when a minimum 

dose estimate does not result in compensation, a next step is required to make a more complete 

estimate. Or when a worst-case dose estimate that has assumptions that may be physically 

implausible results in a POC greater than 50%, a more refined analysis is required. A more 

refined estimate may be required either to deny or to compensate. In such dose reconstructions, 

which may be represented as “reasonable,” NIOSH has committed to resolve uncertainties in 

favor of the claimant. According to 42 CFR 82, NIOSH interprets “reasonable estimates” of 

radiation dose to mean the following: 

. . . estimates calculated using a substantial basis of fact and the application of 

science-based, logical assumptions to supplement or interpret the factual basis. 

Claimants will in no case be harmed by any level of uncertainty involved in 

their claims, since assumptions applied by NIOSH will consistently give the 

benefit of the doubt to claimants. [Emphasis added.] 

In order to achieve the five objectives described above, SC&A reviewed each of the six TBDs 

and their supplemental attachments giving due consideration to the three categories of dose 

reconstructions that the site profiles are intended to support. The six Pinellas Plant TBDs 

generally provide well-organized and user-friendly information for the dose reconstructor when 

adequate data were available to do that comprehensively. 
 

 

 

 

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ORAUT-TKBS-0029-1, Rev. 00, Technical Basis Document for Pinellas Plant – Introduction 

(Notich 2005), explains the purpose and the scope of the site profile. SC&A was attentive to this 

section, because it explains the role of each TBD in support of the dose reconstruction process. 

During the course of its review, SC&A was cognizant of the fact that the site profile is not 

required by the EEOICPA or by 42 CFR 82, which implements the statute. Site profiles were 

developed by NIOSH as a resource to the dose reconstructors for identifying site-specific 

practices, parameter values, and factors that are relevant to dose reconstruction. Based on 

information provided by NIOSH personnel, SC&A understands that site profiles are living 

documents that are revised, refined, and supplemented with TIBs as required to help dose 

reconstructors. Site profiles are not intended to be prescriptive or necessarily complete in terms 

of addressing every possible issue that may be relevant to a given dose reconstruction. Hence, 

the introduction helps in framing the scope of the site profile. As will be discussed later in this 

report, NIOSH may want to include additional qualifying information in the introduction to this 

and other site profiles describing the dose reconstruction issues that are not explicitly addressed 

by a given site profile. 

ORAUT-TKBS-0029-2, Rev. 00, Technical Basis Document for Pinellas Plant – Site 

Description (Orr 2005), is an extremely important document, because it provides a description of 

the facilities, processes, and historical information that serve as the underpinning for subsequent 

Pinellas Plant TBDs. 

ORAUT-TKBS-0029-3, Rev. 00, Technical Basis Document for Pinellas Plant – Occupational 

Medical Dose (Demopoulos 2006), provides an overview of the sources, types of exposure, and 

the frequency of exams that workers potentially received. 

ORAUT-TKBS-0029-4, Rev. 00, Technical Basis Document for Pinellas Plant – Occupational 

Environmental Dose (Gorden and Mobasheran 2005), provides background information and 

guidance to dose reconstructors for reconstructing the doses to unmonitored workers outside of 

the facilities at the site who may have been exposed to routine and episodic airborne emissions 

from these facilities. 

ORAUT-TKBS-0029-5, Rev. 00, Technical Basis Document for Pinellas Plant – Occupational 

Internal Dose (Demopoulos 2005), presents background information and guidance to dose 

reconstructors for deriving occupational internal doses to workers. 

ORAUT-TKBS-0029-6, Rev. 00, Technical Basis Document for Pinellas Plant – Occupational 

External Dose (Palmrose et al. 2005), presents background information and guidance to dose 

reconstructors for deriving occupational external doses to workers. 

In accordance with SC&A’s site profile review procedures, SC&A performed an initial review of 

the six TBDs and their supporting documentation. SC&A then submitted questions to NIOSH 

with regard to assumptions and methodologies used in the site profile. These questions are 

provided in Attachment 3. Responses to those questions have not been received at the time of 

writing of this draft review. 
 

 

 

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After the Advisory Board and NIOSH have an opportunity to review this draft, SC&A plans to 

meet with representatives of the Advisory Board and NIOSH to discuss our findings. Following 

these meetings, the draft may be revised, depending on direction we receive from the Advisory 

Board. We anticipate that, in accordance with the procedures followed during previous site 

profile reviews, the draft report and any subsequent revisions will be published on the NIOSH 

Web site. This last step in the review cycle completes SC&A’s role in the review process, unless 

the Advisory Board requests SC&A to participate in additional discussions regarding the 

closeout of issues, or if NIOSH issues revisions to the TBDs or additional TIBs, and the 

Advisory Board requests SC&A to review these documents. 

Finally, it is important to note that SC&A’s review of the six TBDs is not exhaustive. These are 

large, complex documents, and SC&A used its judgment in selecting those issues that we believe 

are important with respect to dose reconstruction. 

3.2 SITE PROFILE STRENGTHS 

In developing a TBD, the assumptions used must be fair, consistent, and scientifically robust, 

and uncertainties and inadequacies in source data must be explicitly addressed. The 

development of the TBD must also consider efficiency in the process of analyzing individual 

exposure histories, so that claims can be processed in a timely manner. With this perspective in 

mind, we identified a number of strengths in the Pinellas Plant TBDs. These strengths are 

described in the following sections. 

(1) The Site Description TBD, ORAUT-TKBS-0029-2 (Orr 2005), effectively summarizes 

the radionuclides handled and room locations where work was done at the Pinellas Plant 

(Tables 2-1 and 2-2, page 9). Likewise, radiation-producing equipment is succinctly 

listed in Table 2-5, page 22. The listing of unusual events with the quantities of 

radionuclides released (Table 2-4, page 18) was useful in the review process and for dose 

reconstructors. 

(2) The TBDs’ use of personnel monitoring data and environmental monitoring data to 

determine dose is consistent with the requirements outlined in 42 CFR 82, as follows: 

• 	 Where in-vitro analyses are available, this information is provided for use in 

determination of internal dose. 

• 	 Where routine beta/gamma and neutron dosimeters are available and adequate, this 

information is provided for use in determination of external exposure. 

• 	 Where environmental measurements are available, these data are used as the basis for 

environmental dose. 

NIOSH has effectively complied with the hierarchy of data required under 

42 CFR Part 82 and its implementation guides for monitored workers. 
 

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(3) There are several useful summary tables in ORAUT-TKBS-0029-6 (Palmrose et al. 

2005). Table 6-11 provides a helpful summary of photon dosimetry over the operating 

period, and the recommended missed dose by facility and location. Table 6-12 gives the 

same information for missed neutron dose. 

(4) In general, the TBDs describe in sufficient detail the historical site operations, sources of 

radiation dose, potential missing and unmonitored dose, and dose reconstruction 

guidance. The level of information provided appears to be consistent with the supporting 

documents reviewed and the magnitude of the potential doses associated with plant 

operations. There are omissions from each of the six TBDs and additional information 

and considerations that should be included in revisions of the documents. These 

shortcomings are detailed in Section 4.0. 
 

 

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4.0 VERTICAL ISSUES 

SC&A has developed a list of key issues regarding the Pinellas Plant Profile. These issues relate 

to each of the five objectives defined in SC&A 2004. Some issues are related to a particular 

objective, while others cover several objectives. Many of the issues raised below are applicable 

to other Department of Energy (DOE) and Atomic Weapons Employer (AWE) sites, and should 

be considered in the preparation and revision of other site profiles. 

4.1 FINDING 1: RECONSTRUCTION OF DOSES IN THE ABSENCE OF EARLY 

HEALTH PHYSICS, INDUSTRIAL HYGIENE, AND ENVIRONMENTAL 

RECORDS 

The absence of pre-1980s records brings into question the ability to adequately assign radiation 

doses during the early years at Pinellas. The improvements in radiological monitoring and 

bioassay methodology, instrumentation, and in health physics, industrial hygiene, and 

environmental control programs contraindicate the use of 1980s documentation for determining 

radiation doses for the early years of plant operations. The assumptions incorporated into 

ORAU-TKBS-0029-4 and ORAU-TKBS-0029-5, given the absence of firm information, appear 

to be claimant favorable. However, the uncertainties associated with projections without 

documentary evidence may result in missing doses that may not be accounted for by the 

claimant-favorable assumptions indicated in the documents. 

It appears that only documents available at Atlanta National Archives were considered in 

development of the Pinellas Plant TBDs. SC&A has some evidence that some of the more 

important early documents may be located at other DOE sites, and is currently working with 

NIOSH and the relevant sites to obtain them. Should we obtain these records and they present 

information significantly variant from that assumed in the TBDs, revision of some or all the 

TBDs might be in order. 

4.2 FINDING 2: POTENTIAL DOSES FROM INSOLUBLE METAL TRITIDES 

NOT SUFFICIENTLY ADDRESSED 

The neutron tube manufacturing process required spray coating the inside of a glass tube with a 

thin metal film, resulting in the formation of insoluble stable metal tritides (SMTs), namely ScT2, 

ErT2, and TiT2. There is no internal documentation indicating that there were adequate means of 

detecting exposures or monitoring SMTs. Powders were normally contained within vacuum 

systems and metal systems that generally remained intact; however, documented incidents 

involving some of these materials occurred. ORAUT-TKBS-0029-5 states, “Besides incidents, 

metal tritide intakes could have occurred from any of the process areas for HTO processing.” A 

review of the incidents listed in the above document (Table 5-10, page 24) clearly indicates the 

potential for metal tritide contamination and personnel exposure, even though no measurements 

were made. No guidance is provided for estimating the exposure to metal tritides; in fact, 

Section 5.9.2, Metal Tritide Exposures, is reserved for later entry. The practice of destructive 

testing of neutron generators and the methodology for performing the testing make it possible 
 

 

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that exposures to metal tritides occurred. Further discussion of the potential exposure pathway 

and doses should be included in ORAUT-TKBS-0029-5 when Section 5.9.2 is completed. 

ORAUT-TKBS-0029-5 states that the dose reconstructor should consider TiT2 as type M. With 

no National Council on Radiation Protection and Measurements (NCRP)- or International 

Commission on Radiological Protection (ICRP)-accepted dose model for metal tritides, NIOSH 

has not provided a sufficient technical basis for its assumed solubility designation. No 

recommendation for clearance class is provided for the other two possible metal tritides; ScT2 and 

ErT2. 

4.3 FINDING 3: MDCS AND UNCERTAINTIES FOR PLUTONIUM AND 

BIOASSAY MEASUREMENTS ARE INADEQUATELY ADDRESSED 

ORAU-TKBS-0029-5 should provide more information about how bioassay sample activity 

concentrations were calculated and the uncertainties associated with these values. NIOSH 

should provide information on the use of the values in Table 5.1 to calculate internal doses. 

Page 17 of the TBD states the following: 

Uncertainties or errors for plutonium bioassay measurements or the actual 

bioassay results themselves were usually not stated in the personnel records or 

database. MDCs were calculated based upon a 95% confidence level and 

samples were counted to a 2-sigma error as indicated in Pinellas procedures 

(Weaver). Note there were no verified positive bioassay results or known Pu 

contamination incidents. 

There are several factors that may influence the uncertainties and the minimum detectable 

concentration (MDC) of the bioassay measurements. The parameters of the MDC equation 5-1 

on page 6, assigned as TREVA (T = count time, R = recovery fraction, E = average detector 

efficiency, V = sample volume (L), and A = the alpha abundance for the radionuclide in 

question), have an important influence on the MDC value. The recovery is strongly dependent 

on the several factors related to the analysis of each sample, such as digestion of organic material 

of the sample, composition of the samples, reagents, and care in the preparation of the sample. 

The volume of the urine samples may not be correspondent to the 24-hour excretion rate. 

The average MDC value is an important parameter for the calculation of the missed dose, mainly 

because for plutonium, the frequency of the routine bioassay program was annual. According to 

data presented on Table 5-1 (page 9), in 1980, the average MDC value for Pu-238 is 

6.23E-11 uCi/mL and the maximum MDC value is 3.17E-10 uCi/mL; and the average MDC 

value for Pu-239 is 3.41E-11 uCi/mL and the maximum MDC value is 1.90E-10 uCi/mL. There 

is a factor of 5 between the average MDC value and the maximum value. 
 

 

 

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4.4 FINDING 4: ASSESSMENT OF PERSONNEL BADGING POLICY DURING 

EARLY YEARS NEEDS FURTHER REVIEW 

ORAUT-TKBS-0029-6 states the following: 

From 1960 to 1973, U.S. Atomic Energy Commission (AEC) annual exposure 

summary reports indicate that Pinellas had 27.5% of its labor force wearing 

dosimetry (377 of an average yearly labor force of 1,372). During the 1980s, 

while the data are not completely available, from 370 to approximately 400 of 

1,650 to 1,975 workers (approximately 20%) were monitored for radiation dose. 

No documentation was found to show that all employees were monitored at some 

time during Pinellas operations. 

It is important to know who was considered a “radiation worker” and how they were selected for 

badging, as this has dose consequence. In that era, radiation hazards were not well recognized 

during that time period. This resulted in some workers not being monitored during a period 

when not all radiation hazards were recognized. The TBD does not clearly address these issues 

by clarifying the basis for how monitoring was conducted, nor which worker categories were 

badged. These issues need to be reviewed and substantiation provided that the maximally 

exposed workers were badged, and that there is a means to estimate radiation dose to 

unmonitored support workers with access to production areas. Additionally, since many Pinellas 

records on facility monitoring, safety evaluations, investigations, etc., prior to 1980 are not 

available, the determination of the adequacy of badging assignment and allocation of 

unmonitored dose will be complicated. The impact of this absence of early information should 

be addressed. 

4.5 FINDING 5: PROBLEMS WITH PERSONNEL DOSIMETRY 

Section 6.2.2 of ORAUT-TKBS-0029-6 states the following: 

This analysis was unable to locate specific designs of the film dosimeters used for 

approximately the first 20 years (1957 to 1974) at the Pinellas Plant, and there is 

limited documentation that indicates there was an early relationship with 

Nuclear-Chicago (GEND 2004a). 

Table 6-5 on page 16 of ORAUT-TKBS-0029-6 assigns a missed dose of 0.24 rem for betaphotons (monthly) for badges used during this time period. This assignment of missing dose 

evidently assumes that the badges used during this time period were equivalent to those provided 

by Nuclear-Chicago. Additional discussion is needed on the uncertainty associated with the 

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4.6 FINDING 6: THE DECONTAMINATION AND DECOMMISSION ERA OF 

PINELLAS OPERATIONS IS NOT SUFFICIENTLY ADDRESSED 

Monitoring practices, particularly internal dosimetry, are not specified in the TBD for the D&D 

period (1995–1997) at the Pinellas Plant. A number of questions present themselves that are not 

addressed by the existing Pinellas Plant Site Profile. What specific external and internal 

monitoring program was established for D&D operations, and how effectively was it 

implemented? With the use of first-, second-, and third-tier subcontractors, to what extent were 

these workers “captured” in the site’s dosimetry program, and were their records maintained? 

How would the co-worker dose model be applied for unmonitored workers located adjacent to 

D&D operations; was resuspension of radioactive particulates an onsite issue during D&D? 

Buildings at Pinellas were designed and constructed to provide ventilation systems, fumehoods, 

and gloveboxes to minimize inhalation uptakes by workers. As demolition workers began to 

remove walls and dividers, and to remove these contaminated fumehoods, gloveboxes, and 

ventilation systems, these engineering controls were breached and no longer became effective in 

minimizing inhalation uptakes. Contamination within the ventilation ductwork would have been 

an additional source of uptakes. Not always being aware of the presence of radionuclides in 

specific demolition areas and/or researcher-handling areas made it difficult to adequately 

prevent, monitor, and detect uptakes of these radionuclides. 

4.7 FINDING 7: MISSING INTERNAL DOSE ESTIMATION METHODS FOR 

UNMONITORED WORKERS, SUCH AS MAINTENANCE AND SUPPORT 

PERSONNEL, NOT PROVIDED 

It is not clear from the Internal Dosimetry TBD (ORAUT-TKBS-0029-5) how dose estimation 

would be performed for maintenance and support workers who were not classified as radiation 

workers and who had access to Pinellas Plant radiological operations. Section 5.9.1 of ORAUTTKBS-0029-5 contains the statement, “All HTO and Plutonium potentially exposed workers have 

likely been monitored.” The basis for this statement needs justification, particularly in light of the 

fact that tritium use and contamination was common in many Pinellas Plant areas that may have 

been accessable to maintenance and, possibly, administrative personnel. However, no guidance 

is provided in this TBD with respect to missed dose calculations for unmonitored workers in the 

category of support personnel, whose actual jobs (contamination spill cleanup, equipment 

maintenance, and janitorial functions) and access to various Pinellas buildings may have led to 

radionuclide exposures over their job history. It is also not clear how the designation of 

“radiological worker” was historically defined at Pinellas, and how workers were selected on this 

basis for bioassay for various operations. 

4.8 FINDING 8: POTENTIAL FOR MISSED DOSE FOR DEPLETED URANIUM 

ORAUT-TKBS-0029-2, Section 2.3.2, contains a discussion of depleted uranium (DU), 

including the following statement: 
 

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The depleted uranium metal was fully contained inside the storage flask, and no 

information could be found to indicate that depleted uranium metal was released 

during plant operations (Ward, p. 12). 

Interviews with a former employee raised the possibility of loose DU contamination in an area 

of Building 100. There were no bioassay programs in place to determine internal dose from 

exposure to DU, thus DU internal exposure could represent a significant source of unmonitored 

exposure. There is minimal information in ORAUT-TKBS-0029-2 on the production of the 

tritium beds, so it is not possible to discern if the process involves operations that could lead to 

internal exposures. Further discussion of the DU-related process is in order. 

4.9 FINDING 9: THE TBD FAILS TO ADEQUATELY DEFINE AND ASSESS 

OCCUPATIONAL MEDICAL EXPOSURE 

The current guidelines, as presented in Kathren and Shockley (2005), go a long way in assuring 

that all occupational medical exposures are reasonably included in determining the overall dose 

estimations for claimants. Unfortunately, the interpretation to date by the contractor, ORAU, has 

not been applied conservatively to be claimant favorable. The Occupational Medical Dose TBD 

(Demopoulos 2006) assumes an interpretation, which also has been considered and applied at 

other sites, such as the Mound Plant and Los Alamos National Laboratory (LANL), and 

Paducah. To this extent, the assumption that medical procedures are limited to only one preemployment chest x-ray and chest x-rays that are part of routine physical exams, may 

substantially underestimate worker medical exposure when evaluating occupational medical 

exposure. 

In more recent documentation (OTIB-0006, Revision 3 (Kathren and Shockley 2005)), it is 

concluded that other examinations should be included, such as special screening exams (e.g., 

respiratory protection, beryllium workers, asbestos workers, etc.) and termination exams. The 

Occupational Medical Dose TBD does not recognize this change from the previous Revision 2 of 

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

and asbestos workers, and food handlers are accomplished as part of the routine physicals. This 

is not documented in the TBD. Another factor not discussed in the TBD is the potential and 

impact of x-ray procedures utilized by medical authorities to do special screenings that are 

performed outside the frequency suggested in the TBD. 

The TBD (Demopoulos 2006) makes the conclusion that chest examinations are often quite 

limited after 1974, after which Kidney, Ureter, Bladder tests (KUBs) were no longer taken in 

addition to chest x-rays. It is suggested the policy was every 5 years before age 40, and every 

3 years after age 40, but nothing is documented. To the contrary, there is ample evidence that 

chest x-rays were often provided on a voluntary basis to nearly all workers, usually on an annual 

basis. The majority of workers had chest x-rays as a routine at DOE sites until the mid-1980s, 

when Federal guidelines warning against routine screening were first being enforced. 

After discussion with NIOSH personnel, it was their decision to limit occupational medical 

exposure to those chest exams described above, and to include all other exposure as part of 
 

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worker background. SC&A believes such an interpretation is not claimant favorable to those 

most at risk. Our concern is that specified “high-risk” workers, those most likely exposed to 

radiation and beryllium, would be at risk of having an incomplete dose assessment if not all 

radiation associated with medical screening for job-related activities were included. Since all 

radiation provides some risk, and arguably, is cumulative, workers warrant consideration of all 

forms of work-related x-ray exposure to be claimant favorable. SC&A believes 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 the OTIB 

(Kathren and Shockley 2005). 

4.10 FINDING 10: TECHNIQUES AND PROTOCOLS INCREASE UNCERTAINTY 

OF DOSE CORRECTION FACTORS LISTED IN THE TBD 

Section 3.2 of the TBD fails to adequately describe all the information upon which to establish 

beam quality for x-ray units in use from 1957–1997. In 1972, the site documented installation of 

a single phase GE 225 unit. There is only limited documentation to show that the GE 225 unit, 

in use from 1972 through 1997, had added filtration, approximately 3.5 mm of Al, as first 

measured by the Pinellas Health Department in 1972. In the absence of definitive tube output 

measurements, the TBD directs the use of default values and dose correction factors (DCFs) 

derived from ICRP Report No. 34 (ICRP 1982). These values are then applied to determine 

organ doses using Tables A.2 through A.8 of ICRP (1982). An issue of concern is that the DCFs 

are derived using a default half value layer (HVL) of 2.5 mm Al for Type 1 units in use from 

1946–1980. 

The Occupational Medical Dose TBD (Demopoulos 2006) provides little documentation to 

support the assumed techniques and protocols applied to calculate the dose, which is mainly 

derived from NCRP Report 102. The TBD states that a Posterior-Anterior (PA) chest x-ray was 

typically the only view. An undocumented assumption in the TBD is that exams required only a 

PA view. SC&A has inquired whether definitive protocol existed to validate that chest exams 

included PA views and Lateral (LAT) views only on a limited basis after 1974. NIOSH has 

acknowledged in other TBD reviews that the lack of verifiable protocols is a generic problem at 

many sites, has planned to search all available records, and will include pertinent records and 

references in any future revision of this section of the TBD. 

The Occupational Medical Dose TBD is also deficient in that little documentation exists to 

validate x-ray protocols, equipment maintenance, and upkeep of records prior to 1972. 

4.11 FINDING 11: FREQUENCY AND TYPE OF X-RAY EXPOSURE IS 

UNCERTAIN 

The Occupational Medical Dose TBD relies on a very limited review of archived medical 

records to establish frequency assumptions. The assumption of one chest radiograph (PA) every 

3–5 years is not reasonably conservative, in that workers could essentially request an x-ray, or be 

subject to special screening exams. The frequency of screenings and number and type of 

workers receiving x-rays does vary from site to site. 
 

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Section 3.2 of the Occupational Medical Dose TBD does not provide any documentation or 

references to support the assumption that only a limited group of workers received x-ray exams 

more frequently than every 5 years after 1974. To the contrary, up until about 1985, most DOE 

sites performed chest x-rays almost on a voluntary basis. DOE medical program reviews 

documented during the early 1990s showed many sites still used chest radiography as a general 

screening exam. Most workers accepted chest x-rays, even though the job did not require it. 

Also, the assumption that workers in special exposure categories, such as beryllium workers, 

were given chest x-rays only as part of their routine physical is not well documented and not 

consistent with special screening guidelines. The TBD applies no conservative assumption to 

cover such exams. 

Section 3.2 of the Occupational Medical Dose TBD states that photofluorography (PFG) units, 

although generally available up to the late 1950s at most DOE sites, were not documented as 

being used at the Pinellas Plant. The undocumented absence of PFG units at Pinellas clearly has 

significant dose implications to workers who may have been given much higher doses from PFG 

units. The PFG unit provides a dose to the worker greater by a factor of 5–6 than that delivered 

by conventional radiography. The TBD does not provide documentation for the types of 

equipment in use at Pinellas prior to 1972. SC&A believes it is not claimant favorable to instruct 

dose assessors to assume only PFG-unit use from 1957–1960. To be fully claimant favorable, it 

would be appropriate to instruct dose assessors to use an annual dose of 3.0 rem per year for 

chest radiographs, in accordance with guidelines set forth (Kathren and Shockley 2005), until the 

review of medical records evidenced no further use of a PFG unit at Pinellas. 

4.11.1 Secondary Issues 

Secondary Issue 1: Additional Factors Contribute to Uncertainties Related to 

Occupational Medical Exposures 

The Occupational Medical Dose TBD does not consider dose impacts due to less than optimal 

use of technology, such as using screens, grids, or bucky systems. The TBD does not consider 

these elements as potential contributions to uncertainty. 

The TBD does consider the potential contribution to dose that may have resulted in less than 

optimal use of collimation at least prior to 1972, as stated in Section 3.3.2 of the TBD. 

Unresolved is the concern that the DCFs are derived from ICRP (1982), and therefore are not 

comparable, in terms of beam quality, which varies from unit to unit. These factors can 

contribute greatly to the dose to the chest and other organs; for the unit in other TBDs in 

operation prior to 1997, little or no documentation exists. NIOSH has indicated in other TBDs 

that it will continue to search for other available records to better define equipment use and beam 

quality, and include it as appropriate in an updated version of the TBD. 

Uncertainty is defined in the TBD as being due to measurement error and variation in 

kilovoltage, tube current, timers, and the skin-to-surface distance (SSD). This approach is quite 

similar to the uncertainty analyses documented in other DOE site profiles. The conclusion in this 

TBD and others is that dose reconstructors for exposure prior to 1997 should use an uncertainty 
 

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factor of +30%. SC&A believes the uncertainty correction factor of 2.0 being applied at other 

sites is more appropriate for use. 

SC&A agrees that the TBD conservatively estimates these essential aspects of an uncertainty 

review. Unresolved is the contribution to uncertainty in dose, due to other errors introduced by 

lack of quality controls in processing equipment and lack of adherence to established Standard 

Operating Procedures. A reasonable estimate of these contributions to uncertainty would be an 

evaluation of retake rates per examination type. NIOSH should revisit the potential for 

significant retake rates and evaluate its potential effect on dose as part of future revisions of this 

TBD, especially as it relates to prior to 1972. 

The Occupational Medical Dose TBD does not show that Pinellas applied dose minimization 

principles to reduce medical exposures. The document also does not assess or consider the likely 

exposure to workers who are referred to offsite medical facilities for follow-up. The TBD states 

that review of selected medical records and files did not reasonably show or match expected 

x-ray exam frequency and type of exam, as shown in Table 3.1.1. Little evidence exists to 

document the number of x-ray exams provided to the average worker, or for special exposure 

needs. 

Secondary Issue 2: Inadequate Descriptions for Certain Plant Operations 

The Site Description TBD, ORAUT-TKBS-0029-2, provides information on Plant operations as 

they relate to understanding the source and relative magnitude of radionuclide doses. The 

information is sufficiently complete in the case of operations involving tritium, krypton, and 

plutonium. The TBD inadequately describes operations involving Ni-63, C-14, and, particularly, 

DU and metal tritides. The TBD should be revised to provide the reader with a greater 

understanding of processes utilizing the indicated nuclides. 

Secondary Issue 3: Perimeter Tritium Monitoring Stations 

Tritium air monitoring stations were operated on the perimeter of the site for a major part of the 

plant operating history. Up to six samplers were continuously operated and collected samples 

for determining tritium gas and oxide airborne concentrations. The existence of these stations is 

not mentioned in ORAU-TKBS-0029-4. This is a missed opportunity to verify the modeling 

results by comparing them to measured values. 

Secondary Issue 4: Inadequacy of ORAU-TKBS-0029-4, Section 4.4 – Uncertainty 

This section is inadequate and needs to be reworked to more adequately address the topic it is 

intended to discuss, i.e., uncertainty. The discussion in this section centers on factors that affect 

the quantity of dose calculated, and not the uncertainty associated with estimates. While it may 

not be possible to quantify the uncertainty of estimated doses, a more relevant discussion on the 

relative magnitude and factors affecting uncertainty is needed. 
 

 

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Secondary Issue 5: Rejection of Plutonium Bioassay Results Based on Plutonium-238-toPlutonium-239 Ratios, and Non-detectable Plutonium-239 

In ORAU-TKBS-0029-5, two conditions for rejection of a positive Pu bioassay result as follows: 

The ratio of 238Pu to 239Pu in a bioassay sample must be about 5:1 (±20%) or 

238Pu is detected while 239Pu is not detectable. 

The meaning of “(±20%)” in this statement is not clear. Does it mean the range of ratios to be 

rejected is from 4 to 6? This inclusion needs further explanation. 

The application of these criteria to Pu bioassay results for the 3 years discussed in the TBD 

(1988, 1989, and 1990) was responsible for approximately 30% of the samples being designated 

as non-positive. The high degree of uncertainty associated with alpha spectrometry results at the 

levels of Pu-238 expected in bioassay samples makes the use of such a ratio as a reason for 

rejecting a positive Pu-238 questionable. 

These results should be reviewed on an individual basis in that the use of this criterion, because 

of the relatively large uncertainties associated with values near the detection limits for Pu, could 

result in the rejection of positive Pu-238 results. At a minimum, this would have prevented an 

investigation into the circumstances that could have led to the positive result. 

Secondary Issue 6: Plutonium Solubility 

In ORAUT-TKBS-0029-5, page 16, the following statement is made: 

ICRP Publication 68 lists plutonium oxides as absorption type S (ICRP 1995, p. 83). A 

discussion of absorption type for plutonium oxides in ICRP 71 indicates that bioassay 

data from accidentally exposed workers to 238PuO2 could have been closer to type M 

(ICRP 1996, p. 329). 

Page 329 of ICRP 71 (ICRP 1996) also states that plutonium can have different lung clearance 

characteristics when inhaled as mixed metal oxide. The extent of increased dissolution/clearance 

depends on the metal and the relative proportions of plutonium to metal. Since there is an 

uncertainty on the definition of the solubility rates for Pu-238, and there is no clear definition of 

the solubility of the handled compound, the selection of the type of compound for dose 

reconstruction should be the one that is more claimant favorable. For some scenarios, the 

selection of Type M compound is not the claimant-favorable approach. 

Secondary Issue 7: Assumptions Relative to Unmonitored Workers 

ORAUT-TKBS-0029-6, Section 6.4.1, contains the following statement: 

The analysis assumed that unmonitored (i.e., nonradiation) workers did not receive 

a significant dose compared to monitored workers; therefore, assigning a photon 
 

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dose distribution for each year based on the dose received by monitored workers 

would ensure a claimant-favorable estimate of any unmonitored worker dose. 

Based on the review of the available dosimetry data, employees with any 

significant potential for external dose exposure appear to have been routinely 

monitored, as evidenced by the large number of monitored individuals that 

routinely had doses below the reporting levels. Therefore, it is reasonable to 

assume that unmonitored workers received less dose than monitored workers at 

the Pinellas Plant. 

The fact that a large number of monitored individuals routinely had doses below reporting 

levels may give some level of comfort that workers with a significant potential for external 

dose were adequately monitored, but it is not proof. Neither does it lead to the automatic 

conclusion that unmonitored workers received less dose than monitored workers. These 

assumptions may be true, but can only be verified if there is reasonable certainty that 

unmonitored workers were not subjected to different exposure potential or conditions than 

monitored workers. For example, unmonitored maintenance and janitorial personnel could be 

exposed during routine maintenance, waste removal, and cleaning operations to levels that 

exceeded those of operational personnel. 

Secondary Issue 8: Assumptions Relative to Minimum Detectable Level Adjustments to 

Dosimetry for Missed Dose 

In Section 6.4.1.1, ORAUT-TKBS-0029-6, the following statement is made: 

Missed dose is primarily estimated on dosimeter results n (the number of zero or 

< MDL values) multiplied by MDL/2. The MDL is particularly important during 

the early years of operation, when MDLs were probably higher and the dosimeter 

exchange rate was monthly rather than quarterly. One option to estimate a 

claimant-favorable maximum potential dose is to multiply the MDL by the number 

of zero dose results. This will provide an estimate of the maximum missed dose to 

the worker. The following sections consider missed photon dose for dosimeter 

results less than the MDL according to facility or location, dosimeter type, year, 

and energy range. 

It is not clear from this discussion which approach was taken to adjusting dosimeter results in 

the analyses and Table 6-11, following this statement. A definitive statement indicating the 

selected approach should be made in this TBD. 
 

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5.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for a “vertical” assessment of a site profile for purposes of evaluation 

of specific issues of adequacy and completeness, as well as a “horizontal” assessment pertaining 

to how the profile satisfies its intended purpose and scope. This section addresses the latter 

objective in a summary manner by evaluation of (1) how, and to what extent, the site profile 

satisfies the five objectives defined by the Advisory Board for ascertaining adequacy; (2) the 

usability of the site profile for its intended purpose, i.e., to provide a generalized technical 

resource for the dose reconstructor when individual dose records are unavailable; and (3) generic 

technical or policy issues that transcend any single site profile that need to be addressed by the 

Advisory Board and NIOSH. 

5.1 SATISFYING THE FIVE OBJECTIVES 

The SC&A review procedures, as approved by the Advisory Board, require that each site profile 

be evaluated against five measures of adequacy—completeness of data sources, technical 

accuracy, adequacy of data, site profile consistency, and regulatory compliance. The SC&A 

review found that the NIOSH site profile (and its constituent TBDs) for the Pinellas Plant 

represent an adequate accounting of the “core” tritium, krypton-85, and plutonium-handling 

operations, environmental dose, and dosimetry history of the Pinellas site, but falls short in fully 

characterizing a number of key underlying issues that are fundamental to guiding dose 

reconstruction. Section 6.0 summarizes the key issues. Detailed evaluation of these issues is 

provided elsewhere in the report. 

5.1.1 Objective 1: Completeness of Data Sources 

The breadth of data sources used as a basis for the Pinellas Plant Site Profile is evident in the 

number of reports available in the Site Profile Research Database, as well as the number of 

reports cited in the site profile references. The ORAU team’s use of the available sources 

indicates an understanding of site operations, radionuclide usage, and personnel monitoring data. 

However, there are additional sources of data that have not been fully reviewed, because they 

were not available in the Atlanta National Archives, the apparent sole source of data used in the 

TBD developments. This missing information is from the pre-1980 era. There is a belief, based 

on employee interviews, that some of this early data may be available at other DOE sites. As of 

the date of this writing, SC&A’s attempts to obtain early data have not met with success. 

Additionally, it is unclear to what depth the classified records have been reviewed. 

When the Pinellas Plant closed, the records from the plant became the responsibility of the 

Department of Energy’s Albuquerque Office. After reviewing the documents on the NIOSH’s 

O-drive, SC&A began communications with DOE to determine whether additional 

documentation existed about the operations at Pinellas. DOE-Albuquerque indicated all Pinellas 

records were sent to the Federal Records Repository in Atlanta. Subsequently, a list of the 

records held in Atlanta was provided to SC&A for review. In general, our review of the records 

descriptions suggested an absence of early records, from site inception to the mid-1980s. 
 

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Furthermore, inquiries were made with regard to the early Pinellas records with DOEAlbuquerque. DOE-Albuquerque continued to refer SC&A back to Atlanta, although we 

indicated to them there was a lack of early records on their inventory. 

In subsequent conversations, NIOSH indicated that all the records collected by the 

NIOSH/ORAU team were from Atlanta. There were 562 records available on the O-drive. 

There were 6 records from 1956–1960, 10 records from 1961–1970, and 53 records from 1971– 

1980. The inventory provided by DOE-Albuquerque indicated that there were significantly more 

early records in Atlanta. The number of records on the O-drive increased significantly after 1980 

until plant shutdown. The records include health physics and environmental information; 

however, the completeness of the records is difficult to ascertain. Site expert interviewees 

indicated that they had generated reports on their activities routinely. Some of the site experts 

indicated that records were destroyed. 

During the course of the interviews, SC&A became aware of the relationship between the 

Pinellas Plant and other DOE complex sites. Interviewees indicated that there was a flow of 

material and/or information between Pinellas and Sandia National Laboratory (SNL), the SRS, 

the Kansas City Plant, Lawrence Livermore National Laboratory (LLNL), Mound Laboratories, 

and Los Alamos National Laboratory (LANL). Each of the sites was asked to search their 

records database for relevant Pinellas documents. The Kansas City Plant and SRS had a limited 

amount of information; however, it was not relevant to dose reconstruction. SNL indicated that 

they found no relevant Pinellas records. LLNL referred SC&A to the SNL records group. A few 

technical reports were identified through the Argonne National Laboratory and have been 

provided. Based on conversations with DOE, the Department of Labor (DOL) is also having 

difficulty locating early Pinellas records. 

SC&A had the opportunity to review two of claimants’ radiation exposure files while in St. 

Petersburg. In at least one case, the individual’s file was grossly incomplete, even though she 

worked in the Radioisotope Thermoelectric Generator (RTG) program. This leads to concern 

about the completeness of the claimant information provided in site records. Another employee 

was informed that there was no record of her employment at Pinellas. There should be some 

level of quality assurance check on the information received to ensure a complete dose 

reconstruction. This requires that NIOSH/ORAU not only evaluate what is received but also 

what is available at the site or records repository. The individual records appear to originate out 

of SNL. 

The Occupational External Dosimetry TBD ORAUT-TKBS-0029-6 states: 

...that most of the records concerning facility monitoring, safety evaluations, 

investigations, etc. were on operations after 1970. Records of radiation dose to 

individual workers from personnel dosimeters were generally available for 1957 

to 1994 for the workers’ time of employment. 

The TBD gives no quantitative indication of the completeness of personnel dosimetry data, thus 

there is no way, short of a complete review of all the dosimetry records, of determining the 

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From 1960 to 1973, 27.5% of the Pinellas labor force wore dosimetry (377 of an average yearly 

labor force of 1,372). During the 1980s, approximately 20% were monitored for radiation dose. 

No documentation was found to show that all employees were monitored at any time during 

Pinellas operations. It is not clear what the policy was for assigning dosimetry to security, 

crafts, maintenance, janitorial, or administrative personnel with periodic duties related to 

radiation controlled areas. 

Section 6.2.2 of ORAUT-TKBS-0029-6 states: 

This analysis was unable to locate specific designs of the film dosimeters used for 

approximately the first 20 years (1957 to 1974) at the Pinellas Plant, and there is 

limited documentation that indicates there was an early relationship with 

Nuclear-Chicago (GEND 2004a). 

Table 6-5 on page 16 of ORAUT-TKBS-0029-6, assigns a missed dose of 0.24 beta-photons 

(monthly) for badges used during this time period. This assignment of missing dose evidently 

assumes that the badges used during this time period were equivalent to those provided by 

Nuclear-Chicago. Additional discussion is needed on the uncertainty associated with the 

assumed missing dose, given that the origin of the dosimetry is not clearly established. 

Documentation of the nature and type of dosimetry in place for the time period 1957 to 1974 has 

not been located. This leaves a relatively high degree of uncertainty in the accuracy of doses 

recorded and the missing doses for that time period. 

ORAUT-TKBS-0029-2 contains Table 2-4, Chronology of Unusual Events. The text indicates 

that the period covered by this table includes plant startup through 1982. The reason for not 

including years beyond 1982 should be offered. ORAUT-TKBS-0029-5 has a similar table 

(Table 5-10, page 23) that has information through 1989. 

There is a lack of sufficient environmental monitoring data to fully characterize source terms to 

which workers were exposed during D&D operations at Pinellas, particularly as production 

began to cease. While the primary radionuclide remaining as contamination in buildings, 

production systems, and ventilation systems would have been tritium, it would be prudent to 

address the assignment of doses to workers involved in D&D operations during the closure of the 

Pinellas Plant. 

5.1.2 Objective 2: Technical Accuracy 

In general, the TBDs for Pinellas favorably reflect the depth of knowledge and technical 

understanding of the various authors and experts who developed the documents. The analyses 

and recommendations are generally consistent with NIOSH guidance and the available data from 

the site. Some exceptions are noted below. 

Section 3.2 of the TBD (Demopoulos 2006) fails to describe adequately all the information upon 

which to establish beam quality for x-ray units in use from 1957–1997. In 1972, the site 
 

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documented installation of a single phase GE 225 unit. There is only limited documentation to 

show that the GE 225 unit, in use from 1972 through 1997, had added filtration, approximately 

3.5 mm of Al, as first measured by the Pinellas Health Department in 1972. In the absence of 

definitive tube output measurements, the TBD directs the use of default values and DCFs derived 

from ICRP Report No. 34 (ICRP 1982). These values are then applied to determine organ doses 

using Tables A.2 through A.8 of ICRP (1982). An issue of concern is that the DCFs are derived 

using a default HVL of 2.5 mm Al for Type 1 units, in use from 1946–1980. 

Section 3.2 of the Occupational Medical Dose TBD provides no documentation or references to 

support the assumption that only a limited group of workers received x-ray exams more 

frequently than every 5 years after 1974. To the contrary, up until about 1985, most DOE sites 

performed chest x-rays almost on a voluntary basis. DOE medical program reviews documented 

during the early 1990s showed many sites still used chest radiography as a general screening 

exam. Most workers accepted chest x-rays, even though the job did not require it. Also, the 

assumption that workers in special exposure categories, such as beryllium workers, were given 

chest x-rays only as part of their routine physical is not well documented and not consistent with 

special screening guidelines. The TBD applies no conservative assumption to cover such exams. 

5.1.3 Objective 3: Adequacy of Data 

On the whole, the TBDs address the data necessary for assignment of occupational dose, 

including missed and unmonitored dose, for the Pinellas Plant. The data critical for dose 

reconstructors are not always presented in a succinct and easily obtainable manner. 

The Occupational Internal Dose TBD ORAUT-TKBS-0029-5 does not adequately cover the 

dose potential from D&D activities that have been ongoing since the end of the weapons 

component production period. The section on metal tritide exposure is reserved until additional 

exposure data can be researched and developed. 

The Occupational External Dose TBD ORAU-TKBS-0029-6 lists DU as a radiation source, but 

fails to address any potential exposure to DU. Sufficient information should be presented to 

either dismiss DU as a potential dose contributor or provide dose constructors with guidance on 

the missed doses associated with its use at Pinellas. 

5.1.4 Objective 4: Consistency among Site Profiles 

SC&A compared and contrasted the methodologies to determine external, internal, medical, and 

environmental dose used in the Pinellas Plant Site Profile with other site profiles reviewed to 

date. These comparisons focused on the methodologies and assumptions associated with dose 

assessments and the derivation of values used to obtain a POC for individual claimants. 

Specifically, we compared the Pinellas Plant Site Profile to those for Mound and SRS, because 

of the similarity of radionuclides between the three sites. SC&A found a consistent application 

of NIOSH guidance and claimant-favorable assumptions at the sites compared. 
 

 

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All three TBDs fall short in providing specific guidance to the dose reconstructors on how best to 

do claimant-favorable dose reconstructions for metal tritides. NIOSH has yet to develop a 

consistent approach for the handling of stable metal tritide dose reconstructions. 

5.1.5 Objective 5: Regulatory Compliance 

SC&A reviewed the site profile with respect to Objective 5, which requires SC&A to evaluate 

the degree to which the site profile complies with stated policy and directives contained in 

42 CFR 82. In addition, SC&A evaluated the TBDs for adherence to general quality assurance 

policies and procedures utilized for the performance of dose reconstructions. Section 6 addresses 

this topic. 
 

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6.0 USABILITY OF SITE PROFILE FOR INTENDED PURPOSE 

SC&A has identified seven criteria that reflect the intent of the EEOICPA and the regulatory 

requirements of 42 CFR 82 for dose reconstruction. Because the purpose of a site profile is to 

support the dose reconstruction process, it is critical that the site profile assumptions, analytic 

approaches, and procedural directions be clear, accurate, complete, and defensible. SC&A used 

the following seven objectives to guide its review of the Pinellas Plant Site Profile TBDs to 

determine whether they meet these criteria: 

Objective 1 − Determine the degree to which procedures support a process that is expeditious 

and timely for dose reconstruction. 

Objective 2 − Determine whether procedures provide adequate guidance to be efficient in select 

instances where a more detailed approach to dose reconstruction would not affect the outcome. 

Objective 3 − Assess the extent to which procedures account for all potential exposures, and 

ensure that resultant doses are complete and are based on adequate data. 

Objective 4 − Assess procedures for providing a consistent approach to dose reconstruction, 

regardless of claimants’ exposures by time and employment locations. 

Objective 5 − Evaluate procedures with regard to fairness and the extent to which the claimant is 

given the benefit of the doubt when there are unknowns and uncertainties concerning radiation 

exposures. 

Objective 6 − Evaluate procedures for their approach to quantifying the uncertainty distribution 

of annual dose estimates that is consistent with and supports a DOL POC estimate at the upper 

99% confidence level. 

Objective 7 − Assess the scientific and technical quality of methods and guidance contained in 

procedures to ensure that they reflect the proper balance between current/consensus scientific 

methods and dose reconstruction efficiency. 

6.1 AMBIGUOUS DOSE RECONSTRUCTION DIRECTION 

ORAUT-TKBS-0029-5 states: 

The dose reconstructor should consider TiT2 as type M based upon ICRP 71 and 

the recent article in the Health Physics journal. Besides incidents, metal tritide 

intakes could have occurred from any of the process areas listed in Table 5-8 for 

HTO processing as presented in section 5.12. 

This recommendation is given while the section on metal tritide exposure is reserved. It would 

be prudent to reserve a recommendation on lung clearance type until more is known about the 

exposure conditions. 
 

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6.2 INCONSISTENCIES AND EDITORIAL ERRORS IN THE SITE PROFILES 

Equation 5-2, page 8, of TBD ORAUT-TKBS-0029-5 lacks a description for the terms contained 

in the equation. 

Section 5.2.5 of ORAUT-TKBS-0029-5 contains the following statement: 

Radionuclides that were not included in the bioassay program at Pinellas but were 

used at unknown quantities are included in Table 5-3. 

The radionuclides included in Table 5-3 include only tritium and plutonium, which were 

included in the bioassay program. 

6.3 UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES 

A number of issues were identified that are common in the Pinellas and other site profiles 

reviewed to date and, in some cases, represent potential generic policy issues that transcend any 

individual site profile. These issues may involve the interpretation of existing standards, how 

certain critical worker populations should be profiled for historic radiation exposure (e.g., 

construction workers and early workers), and how exposure itself should be analyzed (e.g., 

treatment of incidents and statistical treatment of dose distributions). NIOSH has indicated that 

it may develop separate TIBs in order to address these more generic issues. The following 

represents those issues identified in the Pinellas and previous site profile reviews that in SC&A’s 

view represent transcendent issues that need to be considered by NIOSH as unresolved policy or 

generic technical issues. 

(1)	 Resolution is required on the availability of early records from other DOE sites. 

(2) Direction on the applicability of the TBD and/or TIBs to individual dose reconstructions 

is absent. 

(3) Mobility of the workforce between different areas of the site should be addressed. Site 

expert testimony that many workers moved from one plant to the next is a complicating 

factor. Establishment of an accurate worker history is crucial in such cases. This will be 

especially difficult for family member claimants. 

(4) Statistical techniques used in the application of the data to individual workers should be 

further considered and substantiated. 

(5) The significance of various exposure pathways and the assumptions made that influence 

dose contributions need to be considered (most notably) for solubility and ingestion. 

(6) Analysis needs to be performed regarding how “frequent or routine incidents” should be 

addressed, given the possibility that such “spike” exposures may often be missed by 

routine monitoring as a function of how often and in what manner it was conducted. 
 

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(7) Availability of monitoring records for “transient or outside workers,” e.g., subcontractors, 

construction workers, and visitors, who may have potential exposure while working on or 

visiting a facility should be ascertained. 

(8) Dose to D&D workers should be assessed. Many facilities have large-scale D&D 

operations, which extend back many years. Decontamination and decommissioning 

operations often require working in unknown situations, which may provide unique 

exposure situations. 

(9) A consistent methodology for assessing exposure to metal tritides should be developed 

and applied to all sites where these chemical forms are identified. 

Dose reconstruction for occupational medical exposures remains incomplete. NIOSH needs to 

reconsider the definition to include all forms of radiation medical exposure to ensure its 

considerations are claimant favorable. 
 

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7.0 REFERENCES 

42 CFR Part 82, Title 42, Public Health, Part 82, Methods for Radiation Dose Reconstruction 

Under the Energy Employees Occupational Illness Compensation Program Act of 2000, Code of 

Federal Regulations, May 2, 2002. 

Demopoulos, P.J., 2005, Technical Basis Document for the Pinellas Plant – Occupational 

Internal Dose, ORAUT-TKBS-0029-5, Rev. 00, Oak Ridge Associated Universities, Oak Ridge, 

Tennessee, October 7, 2005. 

Demopoulos, P.J., 2006, Technical Basis Document for the Pinellas Plant – Occupational 

Medical Dose, ORAUT-TKBS-0029-3, Rev. 00, Oak Ridge Associated Universities, Oak Ridge, 

Tennessee, July 4, 2006. 

GEND (General Electric Neutron Devices Department), 2004a, Collection of radiation surveys, 

personnel exposure reports, and other data from Pinellas PDN 25000141. 

Gorden, M. and Mobasheran, A.S., 2005, Technical Basis Document for the Pinellas Plant – 

Occupational Environmental Dose, ORAUT-TKBS-0029-4, Rev. 00, Oak Ridge Associated 

Universities, Oak Ridge, Tennessee, April 15, 2005. 

ICRP (International Commission on Radiological Protection) 1982, Protection of the Patient in 

Diagnostic Radiology, ICRP Publication 34, Pergamon Press, New York, New York 

ICRP (International Commission on Radiation Protection), 1995, Dose Coefficients for Intakes of 

Radionuclides by Workers, Publication 68, Pergamon Press, Oxford, England. 

ICRP (International Commission for Radiological Protection) 1996, Age-Dependent Dose to 

Members of the Public from Intake of Radionuclides, Part 4: Inhalation Dose Coefficients, 

Publication 71, Pergamon Press, Oxford, England. 

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

from Occupationally Related Diagnostic X-ray Procedures, ORAUT-OTIB-0006, Rev. 03, Oak 

Ridge Associated Universities, Oak Ridge, Tennessee. December 21, 2005. 

Notich, M.D., 2005, Technical Basis Document for the Pinellas Plant – Introduction, ORAUTTKBS-0029-1, Rev. 00, Oak Ridge Associated Universities, Oak Ridge, Tennessee, April 11, 

2005. 

NCRP 1989, (National Council on Radiation Protection and Measurements) 1989, Medical 

X-ray, Electron Beam, and Gamma-Ray Protection for Energies Up to 50 MeV (Equipment 

Design, Performance, and Use), Report No. 102, NCRP, Bethesda, Maryland. 
 

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Orr, M.P., 2005, Technical Basis Document for the Pinellas Plant – Site Description, ORAUTTKBS-0029-2, Rev. 00, Oak Ridge Associated Universities, Oak Ridge, Tennessee, August 5, 

2005. 

OCAS (Office of Compensation Analysis and Support) 2003, Tritium Calculations with IMBA, 

OCAS-TIB-002, Rev. 00, National Institutes of Occupational Safety and Health, Cincinnati, 

Ohio, April 22, 2003. 

OCAS (Office of Compensation Analysis and Support) 2006, Estimating Lung Doses for 

Plutonium Strongly Retained in the Lung, Draft ORAUT-OTIB-0049, Rev. 00-D, National 

Institutes of Occupational Safety and Health, Cincinnati, Ohio, February 2006. 

Palmrose D.E., Gorden, M.E., and Demopoulos, P., 2005, Technical Basis Document for the 

Pinellas Plant – Occupational External Dose, ORAUT-TKBS-0029-6, Rev. 00, Oak Ridge 

Associated Universities, Oak Ridge, Tennessee, September 15, 2005. 

Rollins, 2004, Technical Information Bulletin, Maximum Internal Dose Estimates for Certain 

DOE Complex Claims, ORAUT, OTIB-0002, Rev. 01, PC-2, Oak Ridge Associated Universities, 

Oak Ridge, Tennessee, May 7, 2004. 

SC&A 2004. SC&A Standard Operating Procedure for Performing Site Profile Reviews, Rev. 0. 

S. Cohen & Associates, McLean, Virginia. March 18, 2004. 

Ward, W. E., no date, Tritium Control Technology at the AEC’s Pinellas Plant, General Electric 

Company, Neutron Devices, St. Petersburg, Florida. 

Weaver, A., 1993, Pinellas Plant Radiation Safety Overview and Visitor Orientation, Martin 

Marietta Specialty Components, Inc., February 22, Accession Number 434-97-0438 (Project 

Document Number 240001103). 
 

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ATTACHMENT 1: TECHNICAL DOCUMENTS CONSIDERED DURING 

THE REVIEW 

Technical Basis Documents 

ORAUT-TKBS-0029-1, Technical Basis Document for Pinellas Plant – Introduction, Rev. 00 

(Notich 2005). 

ORAUT-TKBS-0029-2, Technical Basis Document for Pinellas Plant – Site Description, 

Rev. 00 (Orr 2005). 

ORAUT-TKBS-0029-3, Technical Basis Document for Pinellas Plant – Occupational Medical 

Dose, Rev. 00 PC-1 (Demopoulos 2006). 

ORAUT-TKBS-0029-4, Technical Basis Document for Pinellas Plant – Occupational 

Environmental Dose, Rev. 00 (Gorden and Mobasheran 2005). 

ORAUT-TKBS-0029-5, Technical Basis Document for Pinellas Plant – Occupational Internal 

Dose, Rev 00 (Demopoulos 2005). 

ORAUT-TKBS-0029-6, Technical Basis Document for Pinellas Plant – Occupational External 

Dosimetry, Rev. 00 (Palmrose et al. 2005). 

Technical Support Documents 

OCAS-TIB-002, Rev 00 (2003). Tritium Calculations with IMBA, Office of Compensation 

Analysis and Support, National Institute of Occupational Safety and Health, Cincinnati, Ohio. 

April 22, 2003. 

OCAS (Office of Compensation Analysis and Support) 2006, Estimating Lung Doses for 

Plutonium Strongly Retained in the Lung, Draft ORAUT-OTIB-0049, Rev. 00-D, National 

Institutes of Occupational Safety and Health, Cincinnati, Ohio, February 2006. 

ORAUT-OTIB-0002 Rev. 01 PC-2, 2004. Technical Information Bulletin, Maximum Internal 

Dose Estimates for Certain DOE Complex Claims, Oak Ridge Associated Universities, Oak 

Ridge, Tennessee. May 7, 2004 (Rollins 2004). 

ORAUT-OTIB-0006, 2005. Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-ray Procedures , Rev. 03, Oak Ridge Associated 

Universities, Oak Ridge, Tennessee. December 21, 2005. (Kathren and Shockley 2005). 
 

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ATTACHMENT 2: SITE EXPERT INTERVIEW SUMMARY 

Interviews were conducted with 10 former Pinellas Plant workers. Years represented by those 

interviewed ranged from 1957–1995. The interviews were conducted by “Q”-cleared members 

of the SC&A Pinellas Plant review team. The purpose of these interviews was to receive firsthand accounts of past radiological control and personnel monitoring practices at Pinellas, and 

better understand how operations were conducted. Interviews were conducted in St. Petersburg, 

Florida, on May 27–29, 2006. Interviews were conducted in small groups or one-on-one to 

solicit unclassified information. There are a number of operations related to weapons 

components that are considered classified and could not be discussed in these interviews. As a 

result, further interviews might be necessary during the comment resolution process. A revision 

to this document would be issued, if necessary. 

Interviewees were initially identified from NIOSH’s Worker Outreach meeting minutes. SC&A 

independently identified these former workers via the telephone directory and internet searches, 

as NIOSH could not disclose the contact information of the workers from their Worker Outreach 

meetings because of Privacy Act issues. Through the first few contacts made, SC&A spoke with 

the leader of the Quarter Century Club, who assisted in identifying additional workers. This 

method of identification of interviewees was laborious and very time-consuming. 

Workers were briefed on the purpose of the interviews and the Pinellas Plant Site Profile. They 

were asked to provide their names, in case there were follow-up questions. Participants were 

reminded that they would be provided the opportunity to review the interview summaries prior to 

inclusion into this report. Interviewees were cautioned not to provide classified information 

during the course of the interviews. 

Pinellas facilities discussed during the interviews included Buildings 100, 300, 400, the 

accelerator facility, and outside areas. The job categories represented included the following: 

• Environmental Protection Specialist 

• Health Physicist 

• Health Physics Inspector 

• Development Engineering 

• Quality Assurance Inspector 

• Process Control Operator 

• Material Handler 

• Janitor 

• Final Test Operator 

Individuals interviewed were given the opportunity to review the interview summary for 

accuracy and completeness. This is an important safeguard against missing key issues or 

misinterpreting some vital piece of information. Some disagreement between site experts arose 

related to documented policies for radiation protection versus actual practice. Both views are 

presented in this summary. 
 

 

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All interviews have been compiled and summarized below. The information provided is not a 

verbatim discussion, but a summary of information from multiple interviews with multiple 

individuals. Individuals provided this information based on their personal experience. It is 

recognized that these former worker recollections and statements may need to be further 

substantiated before adoption in the TBD. Statements from the interviews are included here with 

minimal effort by SC&A to verify their accuracy; however, they stand as critical operational 

feedback. These interview notes are provided in that context; former worker input is similarly 

reflected in our discussion and, with the preceding qualifications in mind, have contributed to our 

findings and observations. 

General Information 

DOE had knowledge that General Electric (GE) Milwaukee (X-ray Department, Neutron 

Devices Department) had experience with the tritium-deuterium reaction and, as a result, they 

were asked to establish and operate the Pinellas Plant. GE established a temporary plant located 

in the downtown St. Petersburg area. Later a permanent facility was established in Largo, 

Florida, including the hiring of 600 people of diversified technical backgrounds and the building 

of a railroad. Initially, GE did not know the details of the work to be performed at Pinellas, but 

within 3 years, they made a workable product. The Pinellas Area Office of DOE provided 

oversight to the facility and reported to the DOE Albuquerque Operations Office. 

There were connections between the Pinellas Plant and the Kansas City Plant, Los Alamos 

National Laboratory, Sandia National Laboratory (SNL), Lawrence Livermore National 

Laboratory (LLNL), and Mound Laboratories. These relationships mandated that Pinellas staff 

members visit the other facilities periodically. Pinellas employees were also involved in yield 

and effects testing of components at the Nevada Test Site (NTS). When the neutron generator 

work was terminated at Pinellas in September 1991, the responsibility went to SNL and the 

tritium operation went to the Savanna River Site (SRS). Pinellas gave one of the Radioflo Units 

to LLNL. 

There was pressure on members of the non-exempt workforce and several members of the 

exempt work force to meet production goals and milestones. During the production period, it 

was not uncommon to work double shifts or work every day until the goal was met. This was 

especially true in the 1960s. On average, site experts indicated that they worked up to 40% 

overtime. For other exempt staff members, the overtime was occasional and typically occurred 

in response to a problem (e.g., radiation alarm). 

A color-coding system was used to separate those with clearances from others. An area marked 

with green indicated a Q-cleared area. To enter these areas, one had to pass through Security. 

The information shared with the workers was on a need-to-know basis only. Area 400 was a 

high security portion of the plant, and was surrounded with razor wire. 

A portion of the workforce was mobile, primarily those involved in Test Equipment Design and 

Test Equipment Fabrication. 
 

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Subcontractors were a part of the workforce at the Pinellas Plant. The Environmental, Safety 

and Health (ES&H) Group was notified when subcontractors worked onsite. They determined 

whether the subcontractors needed monitoring. This may have included bioassay and/or 

dosimetry. Pinellas provided other DOE contractors with personnel exposure results to their 

respective sites when they visited Pinellas. 

Few of the upper management team visited the production areas on a frequent basis. As a result, 

upper management was not close to daily problems in various areas. 

Operations 

Building 100 was referred to as the Ferguson Building. There were a wide variety of operations 

conducted in Building 100. Some of these operations involved the use of radioactive material 

and others did not. A room within Building 100 was referred to by laboratory number, area, or 

process name (e.g., Area 108, Area 8, or Tube Exhaust and Test). The major operations 

including radioactive material are given in the table below. 

Laboratory* Function 

104 Machine Shop 

107 Tube Assembly/Tube Exhaust Area; Contained glass domes 

108 Tritium Loading Area 

109 Final Certification (x-ray, storage, vibrators) for Neutron Generators 

111 Storage of Tubes containing Tritium 

112 Core Winding Area/Resin Casing 

118 Vicinity Transitor Testing and Inspection prior to Assembly 

126 Tube Assembly 

128 Laboratory 

130 Laboratory 

131 Laboratory 

182 Loading Facility 

185 Systems Development 

* The information in the table corresponds to the original floor plan of Building 100 unless otherwise noted. 

The neutron generators manufactured by Pinellas were used to generate neutrons at a specific 

time within the weapons detonation scheme. The generators produced were of weapons reserve 

quality, and hence used in weapons systems (e.g., weapons used on the Trident Submarine). 

These worked on the principle of a tritium-deuterium reaction. A neutron generator has a 

vacuum tube for tritium and deuterium. Tritium is introduced into glass flasks of powdered 

uranium where it is held as uranium tritide. The powder was heated, driving the tritium gas into 

the tubes. The Neutron Tubes were loaded in Area 108 and then assembled into Tube 

Transformer Assemblies, and finally neutron generators in other areas. Room 18, Area 108, was 

used to turn DU slugs or pellets into uranium hydride. Titanium was used in place of uranium 

during some operations. Employees wore fresh air, a film badge, lab coat, shoe covers, and 

gloves during this process. In later years, the site transitioned from a glass tube system to a 

metal (stainless steel) system. When using glass tubes, there were periodic events where the 
 

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tubes would crack and result in contamination spread. This occurred about once every 1–2 

months. Experimental Research Tests were conducted on components. If the engineers 

increased the voltage on the test generator too much, tubes could break. Scandium tritide was 

present at Pinellas; however, the exact use is not known. 

Neutron Generators were tested to see if they put out the correct number of 14 MeV neutrons. 

The energy and number of neutrons emitted from a generator or tube was a production 

specification. Both routine and experimental tubes were tested in Room 131 on trays designed 

for leak testing. The tubes were then sent to another department for the addition of components. 

The unit was then returned to Room 131, where it underwent functional testing to determine if it 

would withstand high voltages. 

Operators were responsible for maintaining liquid nitrogen levels in Room 108 during the day. 

On the off-shift, Nitrogen Handlers completed this job. There was one maintenance person 

assigned to an area during the day (routine). 

The Machine Shop (Building 100, Room 104) was involved in sandblasting neutron generators 

for painting. Sandblasting dust became airborne and subject to being inhaled. Site experts 

reported that the yellow powder, which they suspected may have been DU powder, would get on 

the workers’ clothes in the Resin Casting area (Building 100, Room 112). The site was also 

involved in the development, building, and testing of equipment used for the operations and 

acceptance testing process. 

Between 1975 and 1990, Building 400 became involved in producing Radioisotope 

Thermoelectric Generators (RTGs). The primary function of these sources was to generate heat 

and ultimately electrical power. Radioisotope Thermoelectric Generators were composed of 

Pu-238 on a thermal electric battery in insulation. The Pu-238-encapsulated discs arrived in blue 

cans and were shipped out in padded yellow containers. Armed guards accompanied the 

material, and remained with it until it was unloaded and put in storage. The Pu-238 used for 

RTGs was triply encapsulated. They were primarily a gamma exposure hazard. The heat 

sources were set up in a clean room. Two RTG heat sources were loaded into a fixture, and the 

fixture was then placed in a pass-through window. Up to six units could be processed at one 

time. The operator would exit the clean room and put the unit into a furnace for 5–6 hours to 

allow the heat to press the two heat sources together. The containers were manually transported 

to inspection. Site experts described Building 400 as “very hot” with respect to radioactive 

material. 

The thermo-battery pellets required inspection periodically throughout the manufacturing 

process to determine if they were within tolerance (i.e., no dips, chips, water stains, etc.) Other 

plant inspections were conducted on metalized ceramics, glass tubes, and components used in the 

Magnetic Area. 

The Radiflo Unit was used for leak testing, and contained a gas mixture of Kr-85 and nitrogen in 

known quantities. Glass containers used for tritium were brought to the Radiflo for leak testing. 

The unit was brought up to a pressure, which was maintained for a period of time. Tubes were 

placed in the unit then brought up to pressure for a certain length of time. The amount of leakage 
 

 

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was then calculated, based on the concentration of Kr-85. Following testing, Kr-85 was returned 

to the storage tank. Sometimes there would be leakage into the unit, thus requiring the use of a 

cold trap to capture Kr-85 from the diluted nitrogen/krypton mixture. 

Radiological Health and Safety 

Initially, Pinellas health physicists had difficulty obtaining information related to the monitoring 

of tritium. As a result, many of the techniques were developed in-house. Eventually, SNL and 

Mound laboratories provided some information. Prior to the Tiger Team Assessment in the early 

1980s, there were five health physicists onsite to handle the plant’s program. 

Regulations in the 1950s, 1960s, and 1970s were minimal, so exposure measurements were not 

as rigorous as they were later. In general, members of the workforce disregarded radiological 

postings. Radiation tape was commonly used on the floors to mark radiological areas. Desks 

were placed inside radiological areas, and individuals typically drank their coffee at their desks. 

Employees were not allowed to eat in the assembly areas and Area 108; however, some 

individuals ignored the prohibitions. The Tiger Team audit at Pinellas initiated a dramatic 

change; for example, a more substantial use of radioactive material labeling began. 

Area 108 was the “hot-spot” of the plant. This area monitor alarmed periodically because of 

elevated radiation levels. Decontamination of the areas and glass systems occurred often, and 

decontamination also occurred in other areas (e.g., Area 165), mostly at night when radiological 

control samples were taken. Spills were cleaned up, a smear survey conducted, and the area was 

either determined to be within acceptable limits or the decontamination process was repeated. A 

space above the ceiling of Area 108 periodically had to be vacuumed for contamination removal. 

Area 109 was among the several areas posted as a contamination area. 

Personal Protective Equipment use was based on where an employee worked and the materials 

handled. For Area 108, staff working with radioactive material during the day wore white 

coveralls with booties. This was not always the case with the off-shift personnel. Company 

shoes were provided for those working with liquid nitrogen fillers. In Area 116, lab coats, shoe 

covers, and a hat were worn. Visitors to radiological areas wore yellow shoe covers. 

The beta/gamma and neutron monitoring were dependent on the area and the job function. 

Health Physics reviewed each job description and determined what monitoring was required. It 

was the responsibility of the supervisor to sign individuals up for dosimetry and bioassay. The 

process was documented in the Radiological Instruction Manual. 

The production workers or those working with radioactive material were provided with 

dosimetry. Support staff employees (e.g., Test Equipment Engineers, Process Control Engineers, 

Material Handlers, Nitrogen Handlers, and Expeditors) were not always monitored. Dosimetry 

was not provided to all personnel in the Tube Transformer Assembly (TTA) and the Resonator 

Area. Other employees were assigned dosimeters when they made entries into radiological areas 

of the plant. Administrative employees were generally not assigned dosimeters or asked to 

submit bioassay samples, although they did enter radiological areas to deliver paychecks and the 

plant newsletter. Extremity dosimetry in the form of finger rings was primarily assigned to those 
 

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working on the RTG program, as this work involved hands-on operations with Pu-238. Copper 

step wedges were used for calibration to determine the density versus dose for film badges. A 

procedure was eventually put in place for the calibration process. The site had some pocket 

ionization chambers for use as necessary. 

If there was an unusual reading, the exposure on the badge was recorded as indicated during 

readout. For example, a woman intentionally overexposed her badge and RadCon assigned the 

dose that was indicated on the badge, knowing that her actual dose was less. There was an 

elevated background level at the badge storage racks in Building 300 due to aggregate and 

plaster in the walls. These racks had to be moved and the incident was documented. 

In 1957, Pinellas health physics staff traveled to Albuquerque, New Mexico, to learn how to read 

Nuclear Track Emulsion Type A (NTA) film. To read NTA film, the proton recoil tracks were 

counted to determine the neutron exposure. If a neutron struck the NTA film head-on, it would 

shoot through the film leaving a dot, while others neutrons would scatter, creating a track. The 

tracks were counted; however, the dots were not. The main track and scatter were counted as 

one track. Neutron film was calibrated using a polonium-beryllium (PoBe) source. Each batch 

of film had a set of exposed neutron film to provide the dose curve. This calibration curve was 

used each time they developed NTA film at Pinellas. 

For Area 108, employees submitted weekly urinalysis samples. Special urine samples were 

collected if area alarms went off. Urine was collected at the end of the shift. The recording 

levels for tritium bioassay started at 0.67 μCi/liter. The value was reduced to 0.3 μCi/liter, 

0.1 μCi/liter, and finally 0.003 μCi/liter with the Beckman Liquid Scintillation counter. 

Bioassay samples were considered positive at 1 μCi/liter, and a work restriction was issued at 

10 μCi/liter. Special bioassay samples were collected when there was any rise in the individual’s 

routine bioassay sample, as required by the Radiation Work Permit, or after an incident involving 

tritium release. There was a Hand and Foot Monitor in Area 108, and “sniffers” were also used 

by some individuals to detect tritium in their breathing zone. One technique that was 

recommended to employees as a means to purge the system of radioactive material was to drink 

beer. 

Documentation shared with SC&A indicated a relative biological effectiveness through 1974 of 

1.7 for tritium and 10.0 for neutrons was used. The biological half-life for tritium was assumed 

to be 12 days. Recorded tritium results for 1975 and later use a quality factor of 1.0. Although 

urine was submitted, workers indicated that the results of the analysis were not shared with them. 

Kanne Chambers were used for general area monitoring. Each hood had four systems and a drop 

monitor outside the hood in front of each system in TTA. A Kanne Chamber with a recorder and 

alarm capabilities was placed outside the room. They were periodically checked with an external 

source. Portable tritium air samplers were available in areas without a fixed Kanne Chamber. 

Neutron monitoring in the field was limited to area monitors at each station. Cesium-137 was 

used for calibrating Kanne Chambers. Cobalt-60 and PoBe sources were used to calibrate other 

instruments. 
 

 

 

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Prior to entering the clean room, personnel had to use a blower to blow the dust and other loose 

material off themselves. The clean room protective clothing included floor-length gowns with 

long sleeves, booties, beanie caps, and a mask similar to a painter’s mask. 

The accelerator built in Building 800 was well shielded with thick concrete walls; however, there 

was an issue identified with skyshine. The mission was related to tritium targets. Pinellas 

handled C-14 sources, but site experts interviewed were not aware of the use of Ni-63. Nickel 

transistor tubes were shipped to Pinellas in lead pigs and were surveyed with a Geiger- Mueller 

Counter to eliminate the possibility of receiving Co-60 by mistake. 

There was heavy use of Electron Beam Welders in Building 300, which was originally a separate 

building from Building 100. Industrial x-ray units were used throughout the plant for various 

inspection tests. They were surveyed periodically by health physics with a Geiger- Mueller 

Counter. These surveys were documented and were stored with the health physics records. 

Environmental Monitoring 

Environmental monitoring had included soil sampling, water sampling (onsite and offsite), and 

air sampling. There was no direct radiation monitoring. There were perimeter and offsite (e.g., 

by the Clearwater/St. Petersburg airport, roof of the Clearwater County Building) air monitoring 

stations. The samples were exchanged monthly. Pinellas also conducted a Meteorological Study 

looking at wind conditions, temperature, and release rates. Any tritium released as an oxide was 

collected on Silica Gel. Gaseous tritium passed through heated copper oxide and converted to 

tritium oxide, so it could also be collected on the gel. The maximum airborne concentration of 

tritium recorded was 4 × 10-9 μCi at the boundary. 

The tritium was not completely retrieved by the uranium beds from the systems. As a result, 

when the system was opened, there was a release to the environment. This was observed by the 

spikes on the stack monitor. The stack monitor was a 16.5 liter Kanne Chamber. Flaming the 

glass systems to rid them of impurities such as stopcock grease generated a lot of releases out the 

stack. If they broke, there was also a potential exposure to the work area. Any time the metal 

exhaust system was opened; there was a conversion of gas to HTO. There was an elephant truck 

over the area for ventilation. The Building 100 exhaust system included a method for recovering 

tritium, thus reducing the tritium released. 

Tritium released in the liquid effluent stream had a limit of <3 μCi/liter. The tanks were sampled 

to determine the concentration, and water was added if the concentration was too high. Part of 

the offsite monitoring included sampling liquid down stream. 

Chemical and radioactive waste was diverted to the northeast pond. There were some cases 

where neutron tubes were dumped in the northwest pond. It is not known if these tubes 

contained radioactive components or were tubes that were rejects and unloaded. At times, there 

may have been dumping in the ocean. The site also had a spray irrigation area. The pond has 

been well characterized and is specifically addressed in the 1972 environmental assessment. The 

U.S. Geological Survey was performing a Ground Penetrating Radar survey and located drums 

buried on the northeast section of the property. A follow-up survey located drums in the 
 

 

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northwest section of the property. Although the waste met the regulations at the time it was 

buried, it did not meet the more stringent criteria of the 1990s. The drums were removed during 

remediation and sent elsewhere for disposal. 

During the decontamination and decommissioning (D&D) phase of the plant, workers were 

encouraged to close the plant down as fast as they could. The decision to close the plant came in 

the early 1990s. In 1995, all production for the DOE was halted. The cleanup was completed by 

1997. Higher-risk activities conducted during D&D included dismantling the stack, removing 

gloves boxes and other laboratory equipment, and retrieving waste drums. There were smears 

taken of all the equipment, walls, glove boxes, etc., at this time. 

Incidents or Unusual Occurrences 

Few incidents were mentioned during the course of site expert interviews: 

• 	 There was one incident where contaminated materials were received from another DOE 

site. 

• 	 There was a release of 79.8 Ci of tritium out the stack on July 25, 1984. There was a 

problem associated with the sieve from the Tritium Recovery System. 

• 	 Kr-85 was released out the stack of Building 100. The exact date is documented in the 

health physics reports. 

If incidents occurred, they were generally documented in monthly and quarterly health physics 

reports. 

Records 

Pinellas Plant personnel transferred an electronic database of radiation exposure records and hard 

copy files to Albuquerque after the plant shutdown. (Note: Nulls in records indicated 

individuals were not monitored.) Other documents generated by health physics included 

periodic (i.e., weekly, monthly, and/or quarterly) environmental and health physics reports. 

There were also incident reports generated. If personnel had to be decontaminated, there was a 

Personnel Contamination Report issued. 

There is a disagreement among site interviewees as to whether records were destroyed. Some 

interviewees maintain that records from health physics were never destroyed. It was stated that 

one ES&H staff member accompanied an employee to the site library to access the employee’s 

radiation records. The records had been converted from hardcopy to microfilm. The librarian 

located the microfilm, but the images were illegible and the original records had been destroyed 

after conversion. Another individual formerly working for ES&H indicated that files he kept 

while at Pinellas were destroyed after he retired. One record shown to SC&A during the 

interview indicated an incomplete record of an individual’s work history. She began her 

employment in May 1968 as a Process Control Operator in Building 400. During her tenure at 
 

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Pinellas, she was married and changed her name in 1982. Although documentation indicated 

that she started in May 1968, monitoring records were only available for 1979 and 1980. 

Daily operations logbooks were maintained by Security, foremen, and individuals. The logbooks 

typically included what occurred during a given day (i.e., routine work, non-routine work, 

experiment results, events). The foreman of a particular area was responsible for maintaining 

security logs, which required employees to sign in and out of sensitive areas. 

Occupational Medicine 

The Medical Department had procedures with the settings for the medical x-ray unit. Exams 

were conducted once per year; however, there was a subset of individuals that received semiannual exams. At startup, some individuals were on a 5-year frequency. The exams included 

chest and lumbosacral x-rays. Some site experts indicated they received up to four views per 

chest x-ray exam (Anterior-Posterior, Posterior-Anterior, lateral on each side). Health Physics 

monitored the medical x-ray units using a calibrated integrated ion chamber (R-Chamber). In the 

1970s and 1980s, the Pinellas County Health Department started to calibrate the medical x-ray 

unit at Pinellas. 

Miscellaneous 

• 	 Pinellas did not have in-vivo count capabilities. 

• 	 The Pinellas County and Florida State Health Physicists worked closely with the plant to 

monitor environmental releases. Howard Moreland authored an article entitled Tritium 

the New Genie in 1979. He referenced Ulray Clark (Florida Public Health Physicist), 

who was quite critical about how tritium exposures were under-rated in the federal 

government. 

• 	 There were numerous chemical hazards associated with operations at Pinellas. 

Chemicals that site experts worked with included toluene, turpentine, beryllium resins, 

acetone, asbestos, xylene, ethyl alcohol, sewage, methylene chloride, and liquid nitrogen, 

as well as other toxic chemicals. 

• 	 Pinellas was known for its high-quality products. In about the 1980s, they took over the 

magnetic work previously done by the Kansas City Plant, due to their quality product 

reputation. 

• 	 The Ferro Electric Devices were sent to Pinellas from Mound. These were used in the 

explosive generator. 

• 	 Area 16 was responsible for building various timer subassemblies. 
 

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• 	 A site expert attended a classified meeting during the Cold War; the year of 1980. The 

director of the meeting told employees that they could become ill with thrombocytosis 

working with radiation, radioactive materials, and toxic chemicals at Pinellas. Workers 

have noted a cluster of cancers in individuals who worked in a particular area of the 

facility. 

• 	 There was a community concern related to the involvement of Pinellas in the nuclear 

weapons program. Picketing occurred on a weekly basis in front of the plant. 

• 	 The glass tubes would be cracked, releasing material. There were occasional breaks of 

tubes. 

NIOSH TBD Comments 

The former head of Health Physics reviewed the NIOSH TBD and thought it was relatively 

comprehensive and reflective. This individual was interviewed by NIOSH regarding the Health 

Physics program. Concerns were raised that those individuals who were not monitored by the 

site are being compensated. 

There is concern among former Pinellas workers that Pinellas is being lost in the shuffle of the 

compensation program. An employee received a letter from NIOSH denying her employment 

record for Pinellas. 
 

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ATTACHMENT 3: KEY QUESTIONS FOR NIOSH/ORAU REGARDING 

SITE PROFILE DOCUMENTS 

ORAUT-TKBS-0029-3 through ORAUT-TKBS-0029-6 

Absence of Early Health Physics, Industrial Hygiene, and Environmental Records 

The absence of pre-1980s records brings into question the ability to adequately assign radiation 

doses during the early years at Pinellas. Improvements in radiological monitoring and bioassay 

methodology, instrumentation, and in health physics, industrial hygiene, and environmental 

control programs, contraindicate the use of 1980s documentation for determining radiation doses 

for the early years of Plant operations. The assumptions incorporated into ORAU-TKBS-0029-4 

and ORAU-TKBS-0029-5, in most instances, given the absence of firm information, appear to be 

claimant favorable. However, there can be a high degree of uncertainty in using later years 

information and data to assign doses for early years’ operations. This uncertainty is not 

adequately addressed in the TKBS to the degree that it should be to ensure that dose 

reconstructors would consider its relevance. 

Question: How can NIOSH be confident that all assumptions regarding early occupational 

doses are claimant favorable, given the absence of records and information? 

It appears that only documents available at Atlanta National Archives were considered in 

development of the Pinellas TKBSs. SC&A has evidence that some of the more important early 

documents may, in part, be located at other DOE sites, and is currently working with NIOSH and 

the relevant sites to obtain them. Should we obtain these records and they present information 

significantly variant from that assumed in the TKBS, revision of some or all the TKBSs may be 

in order. 

Question: Will NIOSH revise the TKBSs to accommodate information obtained by SC&A from 

other DOE sites and sources? 

ORAUT-TKBS-0029-2 

Changing Plant Operations 

Figure 2-3 is apparently a recently developed site map. It does not reflect changes made to the 

site over the operating lifetime. Likewise, the discussion in Section 2.2 appears to reflect the 

condition of the site late in its operating history. 

Question: Would it not be beneficial to discuss some of the major modifications to the 

operating facility during its lifetime? 

Depleted Uranium (DU) 

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The depleted uranium metal was fully contained inside the storage flask, and no 

information could be found to indicate that depleted uranium metal was released 

during plant operations (Ward, p. 12). 

Interviews with a former employee raised the possibility of loose depleted uranium 

contamination in an area of Building 100. There were no bioassay programs in place to 

determine internal dose from exposure to DU, thus DU internal exposure could represent a 

significant source of unmonitored exposure. There is minimal information in ORAUT-TKBS0029-2 on the production of the tritium beds, so it is not possible to discern if the process 

involves operations that could lead to internal exposures. Further discussion of the DU-related 

process may be in order. 

Question: How certain is NIOSH that depleted uranium does not represent an unmonitored 

source of radiation exposure? Were there any operations within the Pinellas Plant that could 

have led to internal exposure to DU? Will NIOSH consider revising ORAUT-TKBS-0029-2 to 

describe the treatment of DU at Pinellas, including further documentation that it does not 

represent a source of unmonitored dose? 

Solid Radioactive Waste 

Section 2.3.3 contains the statement: 

The majority of radioactive waste from the site consisted of tritium-contaminated 

classified components. These components were packaged and shipped to a DOEcontrolled site for disposal. 

Interviews with former employees raised the possibility of onsite burial of radioactive wastes. If 

onsite burial occurred, it could have been an additional source of exposure for unmonitored site 

workers. 

Question: Does NIOSH have any information to indicate or dismiss the possibility of onsite 

burial of radioactive materials? 

ORAUT-TKBS-0029-3 

Frequency of Medical Chest X-rays 

In Section 3.1, the statement is made: 

The policy for chest x-ray frequency may have been (no written policy has been 

located) every 5 years before age 40 and every 3 years > 40 years of age. 

Question: What is the basis for this statement? What frequency will NIOSH have the dose 

reconstructor assume? 
 

 

 

 

 

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Medical X-rays other than Chest X-rays 

In Section 3.1, the statement is made: 

Other x-rays that were offered to employees included KUB, lumbar spine, 

cervical spine, hand, ankle, foot, sinuses, and wrist. As far as it is known, these 

x-rays were not given in conjunction with employment and are not included in 

doses under EEOICPA. 

 Question: Without documentation, what is the basis of determining that these x-rays were not 

related to employment? 

ORAU-TKBS-0029-4 

Detection Limit for Tritium/Krypton Gases 

Section 4.1.2.1 contains the statement: 

Air samples were drawn through Kanne type ionization chambers connected to 

pico ammeters to analyze tritium gas and krypton gas (minimum detection limit of 

6.4E-6 μCi/ml) (IT/Radiological Sciences Laboratory, 1986). 

Question: To which of the radionuclides does the minimum detection limit refer? 

Description of Emissions Monitoring Sampling 

In Section 4.1.2.1, emission monitoring sample collection techniques are described for tritium 

and krypton, while radioanlaytical methods are discussed for plutonium and C-14. 

Question: Should monitoring sample collection techniques be described for plutonium and 

C-14? 

Aeration of Industrial Effluent as Exposure Source 

Section 4.1.2.2 contains the statement: 

From 1974 to December 1, 1982, the industrial effluent was combined with the 

sanitary waste effluent in the 2,600,000 gallon west lake where the waste water 

was aerated and pumped to a nine-acre spray irrigation field. 

Aeration of these effluents is not considered as a source of airborne tritium exposure in the 

document. 

Question: Should aeration and spray field operations be considered as a source of airborne 

tritium exposure? 
 

 

 

 

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Source of Early Plant Emissions Data 

Section 4.1.4 contains the statement: 

By 1992, approximately 82% of the total releases had occurred during the first 4 yr 

of operation, 1957 through 1960. Table 4.1.4-2 lists the radionuclide releases 

from Pinellas Plant exhaust stacks (AEC, 1972; 1973; 1974; ERDA, 1975; 1976; 

1977; DOE, 1978; 1979; 1980; 1981; 1982; 1983b; 1984; 1985; 1986; 1987; 

1988; 1989; 1990; 1991; 1992; 1993; 1994; 1995b). 

The source citations are for the years 1972 through 1995, with none for the period before 1972. 

Question: What is the source(s) of the emissions data for 1957 through 1971? What is the basis 

for the assertion that 82% of the total releases occurred from 1957 through 1960? 

Perimeter Tritium Monitoring Stations 

Tritium air monitoring stations were operated on the perimeter of the site for a major part of the 

plant operating history. Up to six samplers were continuously operated and collecting samples 

for determining tritium gas and oxide airborne concentrations. The existence of these stations is 

not mentioned in ORAU-TKBS-0029-5. This is a major omission and a missed opportunity to 

verify the modeling results by comparing them to measured values. 

Question: Does NIOSH plan to revise the TKBS to include a comparison of modeled airborne 

concentrations to measured values for tritium? 

Inadequacy of Section 4.4 – Uncertainty 

This entire section is inadequate and needs to be rewritten to address the topic it presumes to 

discuss, i.e., uncertainty. The discussion in this section centers on factors that affect the quantity 

of dose calculated and not the uncertainty associated with estimates. While it may not be 

possible to quantify the uncertainty of estimated doses, a more relevant discussion on the relative 

magnitude and factors affecting uncertainty is needed. 

Question: Does NIOSH plan to revise the TKBS to include a more relevant discussion of 

uncertainty? 

ORAU-TKBS-0029-5 

MDCs and Uncertainties for Plutonium and Bioassay Measurements are Inadequately 

Addressed 

ORAU-TKBS-0029-5 should provide more information about the uncertainties and how the 

activity concentrations were calculated. The information in ORAU-TKBS-0029-5 is not 

sufficient to verify the adequacy of this information. 
 

 

 

 

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Question: Can NIOSH provide more information on the use of the values in Table 5.1 to 

calculate internal doses? 

Following an explanation of the usage of Equation 5-1 for calculating the MDC for Pu, the 

equation and statement below are given: 

Plutonium MDCs for either 238Pu or 

239Pu was calculated with the following formula: 

A Pu = {Net ROICTS (

238Pu or 239Pu) × CF} ( 5 -1)

 {Net ROICTS (

242Pu) × sampl e size } 

Question: Can SC&A be provided an explanation on the origin and purpose of this equation and 

definitions of the symbols? 

The average MDC value is an important parameter for the calculation of the missed dose, mainly 

because for plutonium, the frequency of the routine bioassay program was annual. According to 

data presented in Table 5-1 (page 9/31), in 1980, the average MDC value for Pu-238 is 

6.23E-11 uCi/mL and the maximum MDC value is 3.17E-10 uCi/mL; and the average MDC 

value for Pu-239 is 3.41E-11 uCi/mL and the maximum MDC value is 1.90E-10 uCi/mL. There 

is a factor of 5 between the average MDC value and the maximum value. 

Question: Can NIOSH provide information to explain the wide range of individual MDC values 

for bioassay samples for plutonium? 

The following statement is included in this section: 

No confirmatory evidence of a positive plutonium bioassay or a dose calculation 

and investigation was found in the Pinellas Plant documentation. 

Question: Is this statement true for the entire plant operational period, for 1988, or for the period 

after 1988 when a positive result had to meet a five-criterion test? 

Two conditions for rejection of a positive Pu bioassay result are: 

The ratio of 238Pu to 239Pu in a bioassay sample must be about 5:1 (±20%) or 

238Pu is detected while 239Pu is not detectable. 

The application of these criteria to Pu bioassay results for the three years (1988, 1989, and 1990) 

discussed in the TBD was responsible for approximately 30% of the samples being designated as 

non-positive. These results should be reviewed on an individual basis, in that the use of this 

criterion, because of the relative large uncertainties associated with values near the detection 

limits for Pu, could result in the rejection of positive Pu-238 results. At a minimum, this would 

have prevented an investigation into the circumstances that could have led to the positive result. 
 

 

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Question: Does “(±20%)” mean the range of ratios to be rejected is from 4 to 6? Is NIOSH 

confident that the use of this criterion did not cause the rejection of positive Pu-238 bioassay 

results? 

Plutonium Contamination 

The ORAUT-TKBS-0029-5 on page 13/31, item 5.3.1.2, Plutonium Contamination Monitoring, 

states that one source had a contamination level greater than the detection limit, as stated below: 

Upon receipt of plutonium sources directly to Building 400, there were leak 

checks in the receiving area in the containment hood, and the sources were 

repackaged into 2R storage and transport containers and placed into the storage 

vault. A 6-dpm/swipe release limit was the control level for the source 

contamination release limit at the 95% confidence level [an Eberline SAC-4, 

ESP-1/Ludlum 43-10 or Baird accu-count was used (Burkhart 1989)]. A 

maximum of 1 of 70 plutonium sources received during the course of one month 

had a contamination level greater than the detection limit of 6 dpm. All were 

decontaminated before RTG processing. Plutonium sources greater than 200 dpm 

contamination levels were sent back to the vendor (Huffman 1979). There was no 

documentation found indicating that any units had to be sent back. 

Question: Since the contamination was detected, can SC&A be provided more information 

about it? What was the result of finding this contamination? What follow-up actions resulted? 

Nickel-63 and Carbon-14 

The ORAUT-TKBS-0029-5 states that Ni-63 and C-14 were also part of the processes in 

Pinellas, but no internal monitoring was conducted. 

Question: What guidance will NIOSH present for dose reconstruction associated with 

exposures from Ni-63 and C-14? 

Plutonium Solubility 

In the ORAUT-TKBS-0029-5 on page 16/31, it stated that: 

ICRP Publication 68 lists plutonium oxides as absorption type S (ICRP 1995, 

p. 83). A discussion of absorption type for plutonium oxides in ICRP 71 indicates 

that bioassay data from accidentally exposed workers to 238PuO2 could have been 

closer to type M (ICRP 1996, p. 329). 

ICRP 71, on page 329, also states that plutonium can have different lung clearance 

characteristics when inhaled as mixed metal oxide. The extent of increased dissolution/clearance 

depends on the metal and the relative proportions of plutonium to metal. 
 

 

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Since there is an uncertainty on the definition of the solubility rates for Pu-238, and also there is 

not a clear definition of the solubility of the handled compound, the selection of the type of 

compound for dose reconstruction should be more claimant favorable. For some scenarios, the 

selection of Type M compound is not the claimant-favorable approach. 

Question: Does NIOSH intend to provide further guidance to dose reconstructors regarding 

plutonium solubility? 

Insoluble Metal Tritides 

The neutron tube manufacturing process required spray coating the inside of a glass tube with a 

thin metal film, resulting in the formation of insoluble stable metal tritides (SMTs), namely 

ScT2, ErT2, and TiT2. There is no internal documentation indicating that there were adequate 

means of detecting exposures or monitoring SMTs. Powders were normally contained within 

vacuum systems and metal systems that generally remained intact; however, documented 

incidents involving some of these materials occurred. 

ORAUT-TKBS-0029-5 states: 

Besides incidents, metal tritide intakes could have occurred from any of the 

process areas for HTO processing. 

 A review of the incidents listed in the above document (Table 5-10, page 24) clearly indicates 

the potential for metal tritide contamination and personnel exposure, even though no 

measurements were made. The practice of destructive testing of neutron generators and the 

methodology for performing the testing make it possible those exposures to metal tritides 

existed. Further discussion of the potential exposure pathway and doses should be included in 

ORAUT-TKBS-0029-5. Insufficient guidance is provided for estimating the exposure to metal 

tritides. 

Question: Does NIOSH intend to provide additional guidance for assessing doses for metal 

tritides at Pinellas? 

The Decontamination and Decommission (D&D) Era of Pinellas Operations is Not 

Sufficiently Addressed 

Monitoring practices, particularly internal dosimetry, are not specified in the TBD for the D&D 

period (1995–1997) at the Pinellas Plant. A number of questions present themselves that are not 

addressed by the existing Pinellas Site Profile. 

Question: What specific external and internal monitoring program was established for D&D 

operations, and how effectively was it implemented? With the use of first-, second-, and thirdtier subcontractors, to what extent were these workers “captured” in the site’s dosimetry 

program, and were their records maintained? How would the co-worker dose model be applied 

for unmonitored workers located adjacent to D&D operations; was resuspension of radioactive 

particulates an onsite issue during D&D? 
 

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Decontamination and decommissioning is not addressed in any detail in the documents reviewed 

to date on the “O” drive concerning external doses. In revisions to the TBDs, NIOSH should 

devote a section to D&D operations, and find ways to quantify dose for workers involved in 

D&D and demolition operations. No external dose monitoring, precautions, unusual conditions, 

or incident tracking during D&D are mentioned. All D&D workers in the radioactive areas 

should have been badged for photons, beta, and possibly neutrons. It is not clear if this was 

done, or if workers always wore respiratory protection during D&D operations. 

The period from the end of operations to complete closure of the site appears to be missing from 

the TBDs reviewed to date. It is not possible to evaluate the external dose issues during this 

period without additional information on the D&D operations, health physics and monitoring 

procedures, and dose data results. 

Question: Will NIOSH address D&D operations in subsequent revisions to the TBDs? 

Natural Uranium in Glass Concerns 

A document entitled, Natural Uranium in Glass Concerns, by A. S. Weaver (Document No. 

2401370) taken from the “O” drive was reviewed by SC&A. The following is excerpted from 

the document: 

An existing operation at the Pinellas Plant uses glass containing (1.5% by weight) 

naturally occurring uranium oxide (U100). This operation has been conducted for 

many years. Processes with this glass have been reviewed to assess worker 

radiation exposures and potential environmental impact. 

Personnel exposures during handling have been assessed using conservative work 

periods and measured dose rates. Estimated worse case exposure to whole body 

and extremities are well below DOE annual limits (5000 mrem/yr whole body 

(WB) and 50,000 mrem/yr extremities). Highest doses would be 15 mrem/yr to 

WB and 75 mrem/yr extremities, DOE requires monitoring if exposures may exceed 

10% of annual limits. 

Later in the document, the following statement is made: 

Dosimetry devices will be issued to workers as a means of verifying the estimated 

doses. 

The usage of the glass containing uranium oxide was apparently widespread and occurred over a 

number of years. The statement relative to issuing dosimetry devices implies that the workers 

handling the glass were, prior to the date of this document, 1992, unmonitored. There is no 

reference to this source of potential unmonitored dose in ORAUT-TKBS-0029-5. 

Question: Does NIOSH consider the potential unmonitored dose to be sufficient to revise the 

TBKS to reflect it? 
 

 

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ORAUT-TKBS-0029-6 

Assessment of Personnel Badging Policy 

ORAUT-TKBS-0029-6 states: 

From 1960 to 1973, U.S. Atomic Energy Commission (AEC) annual exposure 

summary reports indicate that Pinellas had 27.5% of its labor force wearing 

dosimetry (377 of an average yearly labor force of 1,372). During the 1980s, 

while the data are not completely available, from 370 to approximately 400 of 

1,650 to 1,975 workers (approximately 20%) were monitored for radiation dose. 

No documentation was found to show that all employees were monitored at some 

time during Pinellas operations. 

It is important to know who was considered a “radiation worker” and how they were selected for 

badging, as this has dose consequence. The TBD does not clearly address these issues by 

clarifying the basis for how monitoring was conducted, nor which worker categories were 

badged. These issues need to be reviewed and substantiation provided that the maximally 

exposed workers were badged, and that there is a means to estimate radiation dose to 

unmonitored support workers with access to production areas. Additionally, since many Pinellas 

records on facility monitoring, safety evaluations, investigations, etc., prior to 1980 are not 

available, the determination of the adequacy of badging assignment and allocation of 

unmonitored dose will be complicated. 

Question: Will NIOSH revise the TKBS to more adequately address the impact and potential 

unmonitored dose to unmonitored personnel? 

Problems with Personnel Dosimetry 

Section 6.2.2 of ORAUT-TKBS-0029-6 states, 

This analysis was unable to locate specific designs of the film dosimeters used for 

approximately the first 20 years (1957 to 1974) at the Pinellas Plant, and there is 

limited documentation that indicates there was an early relationship with 

Nuclear-Chicago (GEND 2004a). 

Table 6-5 on page 16 of ORAUT-TKBS-0029-6 assigns a missed dose of 0.24 beta-photons 

(monthly) for badges used during this time period. This assignment of missing dose evidently 

assumes that the badges used during this time period were equivalent to those provided by 

Nuclear-Chicago. Additional discussion is needed on the uncertainty associated with the 

assumed missing dose, given that the origin of the dosimetry is not clearly established. 

Question: Will NIOSH revise the TKBS to more adequately address the impact and potential 

missed dose to Pinellas workers? 
 

 

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NTA Film Fading 

Section 6.2.1.1 of ORAUT-TKBS-0029-6 recognizes the problematic fading characteristics of 

the NTA neutron badges. On page 13, ORAUT-TKBS-0029-6 states: 

GEND established a factor of 3 to correct for track fading beginning in January 

1970, based on a track fading study (GEND 1969). 

Following this declaration, there is a discussion of the potential errors related to applying this 

factor based on the time of exposure relative to the reading of the dosimeter. However, no 

“missed dose” is listed in Table 6-5 to account for dosimeter fading. In addition, it is not clear 

that correction for fading was applied to recorded doses prior to 1970. 

Question: Can NIOSH provide more definitive guidance on assigning the missed dose for NTA 

film fading? 
 

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REFERENCES 

1. ICRP, 1982, Protection of Workers in Diagnostic Radiology, International Commission 

on Radiological Protection, Publication 34, Pergamon Press, Oxford, England. 

2. ICRP (International Commission on Radiological Protection), 1991, “1990 

Recommendations of the International Commission on Radiological Protection,” 

Publication 60, Pergamon Press, Oxford, England. 

3. Meyer, H.E., 1951 “Experiment for Fading of Latent Image on Type NTA Film 

Emulsions,” September 13, in Meyer (1994, Volume Viii, p.1). 

4. NBS (National Bureau of Standards), 1957, Protection Against Neutron Radiation Up To 

30 Million Electron Volts, Handbook 63, U.S. Government Printing Office, Washington 

D.C. 

5. Luck, A.D., Occupational Safety and Health Division, 28 April 1995, memorandum to 

Barclay, H., MMSC, and Simonton, R., PAO, “Final DOE Review Team Comments for 

the Pinellas Plant Radiation Program” (Doc. # 240001297, scanned 6/10/04). 

6. Holliday, J.N., Health Physicist, 3 January 1975, memorandum to Barker, A.J., Medical 

Director, “Survey of Medical X-Ray Facility”, (Doc. # 030001821, scanned 12/08/04) 

7. DOE/EA-1092, Environmental Assessment for Decontamination and Dismantlement, 

April 1995, U.S. Department of Energy, Albuquerque Operations Office. 

8. ORAUT-TKBS-0029-1, Rev. 00, April 11, 2005, Technical Basis Document for the 

Pinellas Plant – Introduction, Notich, M. D., Oak Ridge Associated Universities, Oak 

Ridge, Tennessee. 

9. ORAUT-TKBS-0029-2, Rev. 00, August 5, 2005, Technical Basis Document for the 

Pinellas Plant – Site Description, Orr, M. P., Oak Ridge Associated Universities, Oak 

Ridge, Tennessee. 

10. ORAUT-TKBS-0029-3, Rev 00 PC-1, July 4, 2006, Technical Basis Document for the 

Pinellas Plant – Occupational Medical Dose, Demopoulos, P. J., Oak Ridge Associated 

Universities, Oak Ridge, Tennessee. 

11. ORAUT-TKBS-0029-4, Rev. 00, April 5, 2005, Technical Basis Document for the 

Pinellas Plant – Occupational Environmental Dose, Gorden, M., and Mobasheran, A., 

Oak Ridge Associated Universities, Oak Ridge, Tennessee. 

12. ORAUT-TKBS-0029-5, Rev. 00, October 7, 2005, Technical Basis Document for the 

Pinellas Plant – Occupational Internal Dosimetry, Demopoulos, P. J., Oak Ridge 

Associated Universities, Oak Ridge, Tennessee. 
 

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13. ORAUT-TKBS-0029-6, Rev. 00, September 15, 2005, Technical Basis Document for the 

Pinellas Plant – Occupational External Dosimetry, Palmrose, D., Gorden, M., and 

Demopoulos, P., Oak Ridge Associated Universities, Oak Ridge, Tennessee. 

14. Burkhart, R. A., 1989, Release Criteria Used at GEND, October 2 (PPDN 240001010). 

15. GEND (General Electric Neutron Devices Department), 1969 (actual author, title, and 

date unknown), Subject: Dosimetric fade study, Pinellas PDN 240001317, Pinellas Plant, 

St. Petersburg, Florida. 

16. GEND (General Electric Neutron Devices Department), 2004a, Collection of radiation 

surveys, personnel exposure reports, and other data from Pinellas PDN 25000141. 

17. Huffman, G. N., 1979, Pu Contaminated Waste, January 30 (PDN 240001348). 

18. IT/Radiological Sciences Laboratory, 1986, A Technical Evaluation of the Air 

Monitoring Systems in Use for Exhaust Stack Emissions and Environmental 

Measurements at the Pinellas Plant, Largo, Florida, Oak Ridge, Tennessee, September. 

19. Ward, W. E., no date, Tritium Control Technology at the AEC's Pinellas Plant, General 

Electric Company, Neutron Devices, St. Petersburg, Florida. 

20. ICRP (International Commission on Radiation Protection), 1995, Dose Coefficients for 

Intakes of Radionuclides by Workers, Publication 68, Pergamon Press, Oxford, England. 

21. ICRP (International Commission for Radiological Protection) 1996, Age-Dependent Dose 

to Members of the Public from Intake of Radionuclides, Part 4: Inhalation Dose 

Coefficients, Publication 71, Pergamon Press, Oxford, England. 
 

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ATTACHMENT 4: NIOSH RESPONSES TO SC&A KEY QUESTIONS 

To be provided when received. 
 

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ATTACHMENT 5: SUMMARY OF CONFERENCE CALL ON SC&A 

QUESTIONS PROVIDED TO NIOSH 

To be provided after Conference Call takes place. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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ATTACHMENT 6: OVERVIEW OF NIOSH RECOMMENDED DOSE 

RECONSTRUCTION PROCEDURES FOR THE PINELLAS PLANT 

The following is a brief summary, with some notes, of how it appears that NIOSH presently 

plans to perform dose reconstruction for monitored and unmonitored workers at the Pinellas 

Plant for 1957–1994. This was derived from studying the Occupational External Dosimetry 

TBD ORAUT-TKBS-0029-6 (Palmrose et al. 2005) and other Pinellas-related documents. 

Monitored workers with dose records available 

Beta and Photon 

1957–1974: (All radiation workers badged with photon film of undocumented type.) 

3⁄4 Beta - Photons– Dose of record + 240 mrem/yr possible missed dose due to MDL (Nuclear Chicago or 

Pinellas – whole body). 

3⁄4 Beta - Photons– Dose of record + 240 mrem/yr possible missed dose due to MDL (Film badge - wrist). 

3⁄4 Beta - Photons– Dose of record + 240 mrem/yr possible missed dose due to MDL (Film badge - finger). 

1974–1990: (All radiation workers badged with photon and neutron NTA film.) 

3⁄4 Photon – ~1974–April 1990: Dose of record + 60 mrem/yr possible missed dose due to MDL (Landauer 

G1 badge with Monthly changeout). 

3⁄4 Photon – ~1974–April 1990: Dose of record + 20 mrem/yr possible missed dose due to MDL (Landauer 

G1 badge with Quarterly changeout). 

3⁄4 Beta – ~1974–April 1990: Dose of record + 240 mrem/yr possible missed dose due to MDL (Landauer G1 

badge with Monthly changeout). 

3⁄4 Beta – ~1974–April 1990: Dose of record + 80 mrem/yr possible missed dose due to MDL (Landauer 

G1badge with Monthly changeout). 

3⁄4 Photon – July 1974–~1983: Dose of record + 120 mrem/yr possible missed dose due to MDL (Landauer K 

badge with Monthly changeout). 

3⁄4 Beta – July 1974–~1983: Dose of record + 240 mrem/yr possible missed dose due to MDL (Landauer K 

badge with Monthly changeout). 

3⁄4 Photon – July 1974–~1983: Dose of record + 120 mrem/yr possible missed dose due to MDL (Landauer J 

badge with Monthly changeout). 

3⁄4 Beta – July 1974–1983: Dose of record + 240 mrem/yr possible missed dose due to MDL (Landauer J 

badge with Monthly changeout). 

3⁄4 Beta – July 1974–~1983: Dose of record + 240 mrem/yr possible missed dose due to MDL (Landauer Mwrist badge with Monthly changeout). 

3⁄4 Photon – July 1974–~1983: Dose of record + 120 mrem/yr possible missed dose due to MDL (Landauer 

M-wrist badge with Monthly changeout). 

3⁄4 Photon – ~1983–1990: Dose of record + 120 mrem/yr possible missed dose due to MDL (G5-wrist badge 

with Monthly changeout). 

3⁄4 Photon – ~1983–1990: Dose of record + 40 mrem/yr possible missed dose due to MDL (G5-wrist badge 

with Quarterly changeout). 

3⁄4 Beta – ~1983–1990: Dose of record + 240 mrem/yr possible missed dose due to MDL (G5-wrist badge 

with Monthly changeout). 

3⁄4 Beta – ~1983–1990: Dose of record + 80 mrem/yr possible missed dose due to MDL (G5-wrist badge with 

Quarterly changeout). 

1990–1997: (All radiation workers badged with photon and neutron NTA film.) 

3⁄4 Photon – 1990–1997: Dose of record + 60 mrem/yr possible missed dose due to MDL (Landauer 

Z1dosimeter with Monthly changeout). 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Neutron 

1957–1978: NTA track film 

3⁄4 Neutron – Dose of record + 402 mrem/yr possible missed dose; corrected for fading, MDL threshold, and 

poor energy response for RTG (1975–1990) 

July 1974– ~1983: Landauer Type K 

3⁄4 Neutron: Dose of record + 402 mrem/yr possible missed dose due to track fading. 

3⁄4 Neutron: Dose of record + 240 mrem/yr possible missed dose due to MDL. 

3⁄4 Neutron: Dose of record + 360 mrem/yr possible missed dose due to poor energy response for RTG 

October 1979–October 1987: Mound albedo dosimeter 

3⁄4 Neutron: Dose of record + 120 mrem/yr possible missed dose due to MDL 

3⁄4 Neutron: Dose of record + 132 mrem/yr possible missed dose due to signal fading 

3⁄4 Neutron: Dose of record + 40 mrem/yr possible missed dose due to poor energy response for RTG 

~1978–1997: Landauer Neutrak E1 dosimeter 

3⁄4 Neutron : Dose of record + 240 mrem/yr possible missed dose for MDL – Monthly changeout (until Jan. 

1990) 

3⁄4 Neutron : Dose of record + 80 mrem/yr possible missed dose for MDL – Quarterly changeout 

3⁄4 Neutron : Dose of record + 79 mrem/yr possible missed dose for poor energy response for RTG – Monthly 

changeout 

October 1987–1997: Landauer 18 Neutrak Extended Range dosimeter 

3⁄4 Neutron : Dose of record + 240 mrem/yr possible missed dose for MDL – Monthly changeout (until Jan. 

1990) 

3⁄4 Neutron : Dose of record + 80 mrem/yr possible missed dose for MDL – Quarterly changeout 

3⁄4 Neutron: Dose of record + 79 mrem/yr possible missed dose due to poor energy response for RTG – 

Monthly changeout (until Jan. 1990) 

3⁄4 Neutron: Dose of record + 20 mrem/yr possible missed dose due to poor energy response for RTG – 

Quarterly changeout.(after Jan. 1990) 

Unmonitored/Undermonitored Workers 

External 

From ORAUT-TKBS-0029-6, Section 6.4.1.1: 

Unmonitored dose should be assigned to account for external dose that may have been received 

that was not measured. Summarized dosimetry data available for the period 1983–1993 indicates 

that the highest annual external dose for an individual at the Pinellas Plant was 0.550 rem. 

Typical annual dosimetry results for personnel monitored between 1957 and 1979 indicated few 

individuals received doses greater than 0.500 rem. Even though doses at the Pinellas Plant were 

expected to be lower than the maximum individual dose, the maximum doses may be assigned 

based on an assumption of 0.550 rem to each full or partial year. However, typically over 95% of 

monitored workers received annual doses below 0.100 rem. The only exceptions found to this 

were for the years 1958 and 1960, when only 80% and 84% of the monitored population were 

below 0.100 rem. The data indicates that an annual dose of 0.100 rem is representative of the 

upper 95th percentile dose for the Pinellas Plant. The unmonitored photon doses would be adjusted 

by DCF and other applicable factors. 
 

 

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Internal 

ORAUT-TKBS-0029-5 offers no specific guidance for unmonitored workers.