PREDECISIONAL DRAFT 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF PROPOSED STABLE METAL TRITIDE DOSE 

RECONSTRUCTION METHODOLOGY AT PINELLAS 

Contract No. 211-2014-58081

SCA-TR-2016-SP001, Revision 0 

Prepared by 

Robert Barton, CHP 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2016 

Disclaimer 

This 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 predecisional 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: Technical Support for the Advisory Board on Radiation & 

Worker Health Review of NIOSH Dose Reconstruction Program 

DOCUMENT TITLE: Review of Proposed Stable Metal Tritide Dose Reconstruction 

Methodology at Pinellas 

DOCUMENT NUMBER/ 

DESCRIPTION: 

SCA-TR-2016-SP001 

REVISION NO.: 00 (Initial Draft) 

SUPERSEDES: N/A 

EFFECTIVE DATE: February 4, 2016 

TASK MANAGER: John Stiver, CHP 

PROJECT MANAGER: John Stiver, CHP 

DOCUMENT

REVIEWER(S): 

John Stiver, CHP 

John Mauro, PhD, CHP 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 02/04/16 Initial issue 

This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution. 
Effective Date:

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0 (Draft)

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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

TABLE OF CONTENTS 

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

Executive Summary .........................................................................................................................6

1.0 Introduction and Background ..............................................................................................8

2.0 Review of Available Contamination Data and Health Physics Practices at the 

Pinellas Plant ........................................................................................................................9

2.1 Availability of Health Physics and Contamination Data Past 1973 ......................14

2.2 Bounding Nature of Chosen Contamination Value in NIOSH 2015 .....................14

2.3 Characterization of Health and Safety Practices ....................................................18

3.0 Discussion of Remaining Parameters in SMT Dose Reconstruction Approach ................22

3.1 Choice of Resuspension Factor ..............................................................................22

3.2 Effectiveness of Survey Measurements for Capturing Stable Metal Tritides ........23

3.3 Choice of Solubilty Type for Assignment of SMT Intakes ...................................24

3.4 Worker Breathing Rates and Exposure Times .......................................................25

4.0 Summary Conclusion .........................................................................................................25

5.0 References ..........................................................................................................................26

Appendix A: Example of a Complete Monthly Health Physics Report ........................................27

Appendix B: Example of a Handwritten Survey Logbook from 1959 ..........................................33

Appendix C: Examples of Documented Contamination Control and Cleanup Activities .............34

Appendix D: Examples of Predicted Contamination Events that Show Evidence of 

Planning for Such Occurences ...........................................................................................40
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

LIST OF TABLES 

Table 1. Summary of Available Monthly Reports (GE 1957–1973) ............................................ 10

Table 2. Additional Information on Maximum Observed Contamination Values (dpm/100cm2) 

by Year .......................................................................................................................................... 16

LIST OF FIGURES 

Figure 1. Summary of Available Monthly Reports Referenced in GE 1957–1973 ...................... 11

Figure 2. Magnitude of Swipe Results Provided in Monthly Reports Referenced in GE 1957–

1973............................................................................................................................................... 12

Figure 3. Total Available Monthly Health Physics Reports from 1957–1973 ............................. 13

Figure 4. Maximum Observed Contamination Value by Year in dpm/100cm2 ........................... 15

Figure 5. Screenshot of a November 1963 Health Physics Monthly Report Indicating a 

Contamination Incident in which Decontamination was “Immediately Effected.” ...................... 18

Figure 6. Daily Survey of Areas 158, 182, and 108 Showing a Result for “A182C Step Off” that 

Triggered a Recounting of the Sample. ........................................................................................ 19

Figure 7. Recount of the Sample Identified in Figure 4 that Still Showed Contamination Levels 

Above the Limit of 440 dpm/100 cm2 .......................................................................................... 19

Figure 8. Second Recount of the Sample that Still Showed Contamination Levels Above the 

Limit of 440 dpm/100 cm2 ............................................................................................................ 20

Figure 9. Area was Re-Surveyed after Mopping and Showed Markedly Decreased Contamination

....................................................................................................................................................... 20

Figure 10. Screenshot of a 1982 Health Physics Procedure Indicating that “Paper” Was Used to 

Limit Long-Term Contamination During Certain Operations. ..................................................... 22
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation Worker Health 

cm2 square centimeters 

dpm disintegrations per minute 

dpm/100cm2 disintegrations per minute per 100 square centimeters 

GE General Electric 

HP Health Physics 

μCi microcurie 

μCi/cc microcuries per cubic centimeter 

μCi/in2 microcuries per square inch 

m-1 per meter 

m3 cubic meters 

NIOSH National Institute for Occupational Safety and Health 

NRC Nuclear Regulatory Commission 

NUREG/CR Nuclear Regulatory Commission – Contractor Technical Report 

ORAUT Oak Ridge Associated Universities Team 

SMT stable metal tritide 

SRDB Site Research Database 

TBD technical basis document 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

EXECUTIVE SUMMARY 

The most current version of the internal dose technical basis document (TBD) for the Pinellas 

Plant, ORAUT-TKBS-0029-5, Revision 02 (hereafter referred to as “ORAUT 2012”), prescribes 

a methodology for reconstructing doses from intakes of insoluble forms of tritium (also referred 

to as stable metal tritides (SMTs)) during the operational period. Subsequent to the release of 

ORAUT 2012, the issue of reconstructing doses to these insoluble forms of tritium was discussed 

during the Pinellas Work Group meeting on November 19, 2012. One of the main concerns 

stemming from those discussions was that the proposed methods were not contemporary with the 

approach that was developed for a similar exposure situation at the Mound Plant (ABRWH 

2012). In particular, the completeness of the available dataset and the appropriateness of the 

chosen resuspension factor were of particular import. 

On December 11, 2015, NIOSH released its updated methodology and associated justification: 

Review of NIOSH’s Current Approach to Reconstruction of Insoluble Tritium Particulate at the 

Pinellas Facility (hereafter referred to as “NIOSH 2015”). While not specifically discussed, that 

document was announced as ready for release at the November 2015 Advisory Board meeting,

and SC&A was tasked with reviewing it when it became available. This white paper presents the 

results of SC&A’s review, which identified seven observations and one finding, as follows: 

Observation 1: SC&A identified several supplemental periodic health physics reports that 

had recently been uploaded to the Site Research Database (SRDB) and that account for 

some of the observed gaps in the primary reference (GE 1957–1973) forming the basis for 

characterization of tritium contamination at Pinellas (NIOSH 2015). 

Observation 2: SC&A concurs with NIOSH that individual contamination survey results 

are limited until the late 1980s. No monthly or quarterly health physics reports (which 

generally report the highest contamination value for the given period) were observed by 

SC&A after the third quarter of 1973. 

Observation 3: SC&A agrees with NIOSH’s assertion that contamination values in the 

millions of disintegrations per minute per 100 square centimeters (dpm/100cm2) would 

have been unusual and likely of short duration. Nonetheless, if the intention is to use the 

maximum contamination value observed in available site records, SC&A has identified 3

years in which the maximum contamination exceeded the proposed value of 

4.4×106 dpm/100cm2.

Observation 4: Available monthly health physics reports indicate that when contamination 

was discovered through either routine surveys or incidents, the area was immediately 

decontaminated. 

Observation 5: SC&A observed evidence in survey logbooks from the 1980s and 1990s that 

indicated situations where contamination above the control limit was often recounted and 

then the area was decontaminated and resurveyed. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

Observation 6: Based on a review of available health physics reports, it appears that the 

health and safety staff recognized situations that posed an elevated threat of tritium 

contamination and took precautions to minimize exposures. 

Observation 7: The potential for particulate SMT material to be trapped in the wetted 

cotton ball prior to filtration, and thus possibly hindering the transfer of SMTs into the 

measured rinsate liquid, should be investigated and/or clarified in NIOSH's proposed 

approach for the reconstruction of insoluble SMTs.

Finding 1: NIOSH 2015 recommends a worker exposure duration of 2,000 hours per year. 

However, ORAUT 2012 had prescribed an exposure duration of 2,600 hours per year,

based on documented statements from former workers indicating regular 50-hour work 

weeks. Absent additional information to the contrary, the original assumption of a 50-hour 

work week appears appropriate. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

1.0 INTRODUCTION AND BACKGROUND 

On December 11, 2015, NIOSH released its updated methodology and associated justification: 

Review of NIOSH’s Current Approach to Reconstruction of Insoluble Tritium Particulate at the 

Pinellas Facility (hereafter referred to as “NIOSH 2015”). That document focused on five main 

facets of the methodology used by the most current version of the internal dose technical basis 

document (TBD) for the Pinellas Plant, ORAUT-TKBS-0029-5, Revision 02 (hereafter referred 

to as “ORAUT 2012”): 

1. The appropriateness of the chosen resuspension factor 

2. Use of the highest contamination survey (swipe) value reported between 1957 and 1973 

3. Suitability/applicability of available survey measurements for the purposes of detecting 

stable metal tritides (SMTs) 

4. Magnitude and extent of tritide contamination at Pinellas 

5. Solubility assumptions concerning metal tritides 

As indicated in ORAUT 2012and prior discussions on insoluble forms of tritium, SMTs are 

problematic from the standpoint of dose characterization because normal bioassay and air 

sampling methods for detecting tritium intakes are not appropriate for insoluble forms. NIOSH 

2015 proposes a dose reconstruction methodology that utilizes area contamination surveys 

(swipe samples) along with assumptions characterizing the resuspension of the contaminated 

material and typical worker breathing rates and exposure time. 

ORAUT 2012 examined a collection of available periodic1health physics reports (hereafter 

referred to as “GE 1957–1973”) available on the Site Research Database (SRDB) in order to 

characterize tritium contamination levels and associated Health and Safety actions in response to 

contamination events. Specifically, the internal dose TBD determined the following concerning 

the contamination swipe data contained in GE 1957–1973: 

These reports indicate that as early as 1959, areas greater than 2×10-5 μCi/in2

(688 dpm/100 cm2) were recommended for decontamination. In 1969, the control 

limit was reported as 440 dpm/100 cm2. This indicates that a routine 

contamination control program was in place throughout the history of the site and 

that it would be unlikely to see high contamination levels for extended periods. 

The monthly health physics reports found in GE 1957–1973 often provide information on the 

maximum tritium surface contamination levels. Between 1957 and 1973, the highest surface 

contamination level reported was 4.4×106disintegrations per minute per 100 square centimeters 

(dpm/100 cm2) in 1970 (10,000 times the known control limit). The next highest value reported 

 

1

 The majority of reports during this time were issued on a monthly basis; however, beginning in 1970, reports were 

issued quarterly. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

in GE 1957–1973 was 1.4×106dpm/100 cm2(3.3×10-2 microcuries per square inch (μCi/in2)) in 

1959. The majority of the rest of the surface contamination levels reported in this reference are at 

least an order of magnitude lower than these two sample values. The currently proposed 

methodology utilizes the maximum observed value (4.4×106

dpm/100 cm2) to represent the 

insoluble tritium area contamination for all potentially exposed workers. 

This white paper focuses on the appropriateness and bounding nature of the chosen 

contamination value as well as the completeness of the available contamination data used in 

making this determination (Section 2). Although the focus of this review is on the available 

contamination survey data, the remaining assumptions characterizing the proposed approach are 

discussed briefly in Section 3. 

2.0 REVIEW OF AVAILABLE CONTAMINATION DATA AND 

HEALTH PHYSICS PRACTICES AT THE PINELLAS PLANT 

As stated in the introduction, NIOSH has reviewed a collection of health physics monthly reports 

to determine a bounding contamination value to use as the basis for assigning intakes of SMTs 

for relevant workers2

2

 NIOSH 2015 states that intakes of SMTs will be assigned only to workers who were on the tritium bioassay 

program. ORAUT 2012 states that workers who were not monitored for tritium would only be exposed to 

environmental levels of radioactive materials. 

at Pinellas. NIOSH has elected to use the highest value observed (4.4×106

dpm/100cm2) in a collection of reports found in GE 1957–1973. The number of monthly reports 

contained in that document is displayed in Table 1 and Figure 1. Individual monthly reports were 

available for all 12 months in 5 of the 17 years covered in GE 1957–1973. No monthly reports 

were available for 1968 and 1971. 

Also indicated in Table 1 is the number of reports that appear “complete.” The majority of 

available monthly reports were incomplete. The available documentation indicates that monthly 

reports were generally between 5 and 9 pages up through 1967; after this time, reports ranged 

from 13 to 17 pages. However, as evidenced by column 3 of Table 1, very few of these reports 

were complete documents, with only 5 of the 114 available reports (approximately 4.4%) 

containing all indicated pages.3

3

 The number of pages in a given monthly report could be ascertained by the page numbering scheme used, as pages 

were labeled as “1 of 6,” “2 of 6,” etc. 

An example of a complete monthly report contained in GE 

1957–1973 is shown in Appendix A. 

 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

Table 1. Summary of Available Monthly Reports (GE 1957–1973) 

Year

Total Number 

of Monthly 

Reports

Number of 

Complete 

Monthly 

Reports

Number of Smears

Taken as Indicated 

in Available 

Monthly Reports

Number of 

Actual Smear 

Results Reported

1957 5 3 536 3

1958 3 Unknown 226 0

1959 3 Unknown 585 21

1960 11 0 1,514 10

1961 12 0 8,428 0

1962 12 1 9,943 0

1963 4 0 1,505 0

1964 12 0 1,637 0

1965 2 1 1,147 0

1966 5 1 Not Stated 1

1967 5 0 Not Stated 0

1968 NMR NMR NMR NMR

1969 7 0 1005 4

1970 12 0 1492 1

1971 NMR NMR NMR NMR

1972 12 0 1195 2

1973 9 0 1079 0

NMR = No monthly reports identified. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

Figure 1. Summary of Available Monthly Reports Referenced in GE 1957–1973

0

2

4

6

8

10

12

Number of Monthly Reports

Year

Note: Beginning in 1970, health physics reports were issued quarterly. For the purposes of this figure, each quarterly report 

was represented as covering 3 months. 

The magnitude of swipe results found in GE 1957–1973 is shown in Figure 2. Based on the data 

in GE 1957–1973, it is clear that the chosen value of 4.4×106dpm/100cm2is significantly larger 

than most other swipe samples reported in the available records. Additionally, the chosen value 

clearly bounds all of the maximum swipe samples reported during this time. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

Figure 2. Magnitude of Swipe Results Provided in Monthly Reports Referenced in GE 

1957–1973 

1.00E+01

1.00E+02

1.00E+03

1.00E+04

1.00E+05

1.00E+06

1.00E+07

Swipe Value (dpm/100 cm^2)

Date

NIOSH 2015 Proposed Value

Subsequent to the release of the methodology outlined in ORAUT 2012 (which forms the basis 

for selection of 4.4×106dpm/100cm2), more than 350 additional documents have been captured 

and uploaded to the SRDB. These documents include additional and supplemental monthly 

health physics reports as well as individual handwritten survey logs and incident reports. An 

example of a handwritten survey log is shown in Appendix B. SC&A examined these additional 

records with four main objectives: 

1. Assess if the supplemental records will fill the observed gaps in GE 1957–1973 (see 

Section 2.1).

2. Explore any monthly health physics reports and associated data occurring after 1973 (see 

Section 2.3).

3. Determine if there is evidence of contamination values exceeding the proposed value of 

4.4×106

dpm/100cm2(see Section 2.4). 

4. Evaluate the extent to which observed contamination reported in available records was 

decontaminated (see Section 2.2).

Each of these facets is discussed in the subsections below. 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

As noted in the previous section, GE 1957–1973 contained several years for which the monthly 

health physics reports were missing, including at least 2 years for which no health physics 

reports were observed. Additional data capture has obtained supplemental monthly health 

physics reports that can be used in conjunction with GE 1957–1973. Figure 3 displays a 

combination of the reports available in GE 1957–1973 and the additional reports recently 

uploaded to the SRDB. As seen in Figure 3, complete sets of health physics reports are available 

for 1960–1966, 1969–1970, and 1972. SC&A was unable to locate any health physics reports for 

1968 and 1970 in the supplemental records, nor any additional reports for 1957–1959 and 1973 

(beyond what had already been contained within GE 1957–1973). Finally, SC&A did not 

observe any periodic health physics reports beyond 1973, although contamination swipe data 

were identified for several years post 1973 (see Section 2.2). 

Figure 3. Total Available Monthly Health Physics Reports from 1957–1973 

0

2

4

6

8

10

12

Number of Monthly Reports

Year

Note: Beginning in 1970, health physics reports were issued quarterly. For the purposes of Figure 3, each quarterly report 

was represented as covering 3 months. 

Observation 1: SC&A identified several supplemental periodic health physics reports that 

had recently been uploaded to the SRDB and that account for some of the observed gaps in 

the primary reference (GE 1957–1973) forming the basis for characterization of tritium 

contamination at Pinellas (NIOSH 2015). 
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This is a working document provided by NIOSH’s Division of Compensation Analysis and Support (DCAS) or 

its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, 

preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

2.1 AVAILABILITY OF HEALTH PHYSICS AND CONTAMINATION DATA PAST 

1973

As was noted in the previous Section, SC&A did not observe any periodic health physics reports 

past the third quarter of 1973. However, SC&A did find sparse examples of reported 

contamination levels in various other references for 1976, 1980–1981, 1986–1988, and 1991–

1994. The highest observed value in each of these additional years, as well as the years covered 

by GE 1957–1973, is discussed in Section 2.3. Beginning in the late 1980s, and particularly in 

the 1990s, thousands of pages of contamination smear data are available for review in the SRDB.

It is not unexpected that additional periodic health physics reports and complete sets of 

contamination survey data were not available. NIOSH 2015 had noted the following: 

For the Pinellas Plant, little individual contamination smear data is available. 

The primary data source that we have for the Pinellas Plant’s contamination 

survey results were the monthly Health Physics Summary Reports that reported 

the highest contamination levels measured for a given month. 

An analysis of available data of the monthly Health Physics Summary Reports 

(SRDB 27095 [GE 1957–1973] found the highest surface contamination level 

reported was 4.4E+06 dpm/100 cm2, which is 10,000 times their control limit.

Observation 2: SC&A concurs with NIOSH that individual contamination survey results 

are limited until the late 1980s. No monthly or quarterly health physics reports (which 

generally report the highest contamination value for the given period) were observed by 

SC&A after the third quarter of 1973. 

2.2 BOUNDING NATURE OF CHOSEN CONTAMINATION VALUE IN NIOSH 

2015

As discussed previously, NIOSH 2015 references a collection of monthly/quarterly health 

physics reports from 1957 to 1973 (GE 1957–1973) as the basis for selection of the maximum 

observed value of 4.4×106 dpm/100 cm2. This collection of monthly reports is described in detail 

in Section 2.0. Additional reports, which supplement this collection, are discussed in Sections 2.1 

and 2.2. NIOSH 2015 states the following about the chosen contamination value: 

The likelihood of routine surface contamination level [sic] in the millions of 

dpm/100 cm2should be considered unusual and short in duration. 

As a comparison, the assumption of an average contamination level of 4.4E+06 

dpm/100 cm2is one to two orders of magnitude higher (depending on the year) 

than the surface contamination levels at Mound, which had a similar process as 

Pinellas. Therefore, the approach applied at Pinellas is considered bounding and 

favorable to the claimant. 
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preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

In addition to the references found in GE 1957–1973, SC&A identified and reviewed 

supplemental periodic health physics reports and contamination surveys to determine if 

contamination exceeding the proposed value may have existed at Pinellas. Figure 4 displays the 

maximum observed contamination measurement for each year for which such data were 

available. Table 2 presents additional descriptions of each maximum result and also indicates the 

years for which no numerical swipe samples could be obtained. 

Figure 4. Maximum Observed Contamination Value by Year in dpm/100cm2 

1.E+02

1.E+03

1.E+04

1.E+05

1.E+06

1.E+07

1.E+08

Maximum Observed Contamination Value 

(dpm/100cm^2)

Year

NIOSH 2015 Proposed 

Contamination Value

As seen in Figure 4 and described in Table 2, three of the years that had contamination swipe 

data displayed values greater than the proposed value of 4.4×106 dpm/100 cm2. The maximum 

observed contaminations for these 3 years were as follows: 

 1988: Two contamination measurements were found on the order of 107 dpm/100cm2; 

these locations appear to be associated with the removal of a hood and/or glove box (the 

contamination was found on the floor either right near the removed equipment or directly 

under the removed equipment). 
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 1992: Area 158B Flow Bench – Two surveys were performed for the area on consecutive 

days; both were on the order of 1.4×107dpm/100cm2. A handwritten note on the record 

indicates, “Rad Exh Hood.” 

 1994: A swipe location was given as “Pipe B,” and the record indicates it was from the 

inside tubing that was taken out of an accelerator. The next highest result observed in this 

year was 1.23×106dpm/100cm2on a table top in Area 182C (this is below the NIOSH 

proposed value of 4.4×106 dpm/100cm2). 

For the contamination results in 1988, it appears that the highest values were the result of 

decommissioning and removal of equipment. Logically, contamination levels associated with 

such activities would not be encountered in an operational setting and not on a chronic, longterm basis. Similarly, the high contamination value observed in 1994 appears to be associated 

with the internal components of an accelerator, so any actual exposure potentially was likely 

limited in time and scope. The highest value for 1992 was associated with a “flow bench” in 

Area 158B (also referred to as a “Rad Exh Hood” based on a handwritten note on the computer 

printout); however, SC&A could not locate any other information to characterize the actual 

exposure potential of such contamination. 

Table 2. Additional Information on Maximum Observed Contamination Values 

(dpm/100cm2) by Year 

Year

Maximum 

Contamination 

(dpm/100cm2)

SRDB Ref.

ID Page Location/Additional Comments

1957 5.16E+05 133591 6 Tube Exhaust Area

1958 1.98E+06 15169 75 Hood Room I – Doors

1959 3.10E+06 15169 139 Hood Room I – South Panel

1960 2.28E+06 15169 503

Location given as “inside of tube.”

Next highest value was 1.76×106 dpm/100cm2in Area 8 

related to maintenance on the vacuum pump and increased 

system cleaning operations.

1961 1.55E+06 15180 99 Area 908 Hood Room – Hood

1962 5.40E+05 15406 75 Area 908 Hood Room – Interior

1963 NA NA NA NA

1964 3.79E+04 133586 8 Area 8 during an equipment cleaning operation.

1965 NA NA NA NA

1965 None Available

1966 1.32E+06 133581 2

Area 62 – found on a vacuum dolly caused by experimental 

work. Health physics was involved with the planning of the 

operation but were not present during the actual execution 

phase.

1967 NA NA NA NA

1968 NA NA NA NA

1969 4.90E+05 27095

Cell 3, Building 400. Used tritium flasks were being stored 

in the area, an incident investigation was enacted, and a full 

report is available.
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Year

Maximum 

Contamination 

(dpm/100cm2)

SRDB Ref.

ID Page Location/Additional Comments

1970 4.40E+06 27095

Area 108, Room 2. Resulted from maintenance operations on 

a metal system contained in a glove box. This is the 

proposed value to be used for all years in NIOSH 2015.

1971 1.20E+05 12804 Area 108, Room 18.

1972 2.46E+05 27095 Area 182D. An evaporator fixture flaked while being 

packaged for disposal.

1973 NA NA NA NA

1974 NA NA NA NA

1975 NA NA NA NA

1976 9.02E+05 133546 10 Room 182D, floor at the north east corner of the room.

1977 NA NA NA NA

1978 NA NA NA NA

1979 NA NA NA NA

1980 2.51E+05 12808 Receiving dock – Scanning Electron Microscope.

1981 1.92E+03 133544 4

Location given as “inside” of “stack section 2” (note: other 

swipes from inside and outside “stack section 2” were below 

220 dpm/100cm2)

1982 NA NA NA NA

1983 NA NA NA NA

1984 NA NA NA NA

1985 NA NA NA NA

1986 7.84E+02 12808 113

Area 108 to Area 1000. A contaminated drum found in Area 

1000 that had not been decontaminated prior to leaving Area 

108.

1987 9.50E+05 133494 6 Discovered on weld bench surface.

1988 2.47E+07 133490 18

Discovered on floor by removed hood. Another swipe at 

1.2e7 found on the floor under a removed glove box.

Remaining swipes in year below proposed 4.4e6 value.

1989 NA NA NA NA

1990 NA NA NA NA

1991 2.37E+06 133426 242 Found on “Front Cart Top Shelf” in Area 182D.

1992 1.41E+07 133570 491

Area 158B Flow Bench – Area was verified with two 

surveys on consecutive days both on the order of 1.4×107 

dpm/100cm2.

1993 2.54E+06 133407 403 Area 108, Room 22 – Hood.

1994 2.67E+07 133512 71

Swipe location given is “Pipe B” and record indicates it was 

from the inside tubing that was taken out of an accelerator. 

The next highest result observed in year was 1.23e6 on a 

able top in Area 182C.

NA = None available. 

Observation 3: SC&A agrees with NIOSH’s assertion that contamination values in the 

millions of dpm/100cm2 would have been unusual and likely of short duration. Nonetheless, 

if the intention is to use the maximum contamination value observed in available site 

records, SC&A has identified 3 years in which the maximum contamination exceeded the 

proposed value of 4.4×106 dpm/100cm2. 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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2.3 CHARACTERIZATION OF HEALTH AND SAFETY PRACTICES 

In reviewing available monthly health and safety reports, SC&A observed several instances in 

which it was reported that contamination had been found during normal radiation surveys and 

had been decontaminated immediately. One such example is shown below in Figure 5, and 

several other examples are described in Appendix C. 

Figure 5. Screenshot of a November 1963 Health Physics Monthly Report Indicating a 

Contamination Incident in which Decontamination was “Immediately Effected.”

Observation 4: Available monthly health physics reports indicate that when contamination 

was discovered through either routine surveys or incidents, the area was immediately 

decontaminated. 

This type of observation was also noted in NIOSH 2015: 

These reports also indicate that surface contamination levels above the control 

limits of 2E-05 μCi/in2(688 dpm/100 cm2), as early as 1959, and 440 dpm/100 

cm2(reported in 1969) resulted in the initiation of decontamination efforts. This 

was confirmed in an interview of a past radiological control personnel who 

indicated that metal tritide contamination was cleaned up fairly quickly. 

Radiological Control personnel would take wipes in the morning and, if 

contamination was identified, they would then mop up the area and resurvey. 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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SC&A confirmed the statements made in the former worker interview (a health physicist who 

worked from 1987 to 1997 at Pinellas) and also observed the practice of resampling a 

contaminated area after mopping in a 1992 smear survey dataset (see Figures 6–9 for examples).

Figure 6 presents smear samples taken in three areas (182, 158, and 108) and indicates that one 

sample was well above the control limit of 440 dpm/100cm2; this resulted in a recount of the 

sample (shown in Figure 7). Figure 8 displays a second request for recounting based on the 

results of the first recount in Figure 7. Finally, Figure 9 shows the results of a new survey of the 

area with markedly lower contamination values (~10% of the control limit) that occurred after 

the area was decontaminated (mopped). This type of example was observed in numerous in other 

survey logs in the late 1980s and 1990s. 

Figure 6. Daily Survey of Areas 158, 182, and 108 Showing a Result for “A182C Step Off” 

that Triggered a Recounting of the Sample. 

Figure 7. Recount of the Sample Identified in Figure 4 that Still Showed Contamination 

Levels Above the Limit of 440 dpm/100 cm2 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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Figure 8. Second Recount of the Sample that Still Showed Contamination Levels Above the 

Limit of 440 dpm/100 cm2 

Figure 9. Area was Re-Surveyed after Mopping and Showed Markedly Decreased 

Contamination 

Observation 5: SC&A observed evidence in survey logbooks from the 1980s and 1990s that 

indicated situations where contamination above the control limit was often recounted and 

then the area was decontaminated and resurveyed. 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

In addition, SC&A noted that several of the monthly health physics reports indicated that there 

were certain activities that were expected to result in levels of contamination that might exceed 

the control limit. These reports also note that protective actions were taken and contamination 

control measures were put in place that minimized such events. For example, a monthly health 

physics report from December 1969 stated the following: 

Anticipated contamination above the control limit of 440 dpm/100cm2, was 

associated with work in Areas 108, 132B, 154, 155, 158, 162, 182A, 182B, 182C, 

and 182D. The maximum contamination level, 4.3×10-5 dpm/100cm2, was 

detected on the work surface of a hood in Room 20, Area 108, following the 

disassembly of a vac-ion pump. 

Continuous monitoring was provided by Environmental Health during 

disassembly. 

Airborne tritium concentrations to a maximum of 1.3×10-3 μCi/cc were 

encountered by employees performing maintenance on a mass spectrometer in 

Room 3, Area 108.” [GE 1957–1973] 

Interestingly, the currently proposed bounding contamination value of 4.4×106 dpm/100cm2 was 

the result of a similar situation in which the contamination had been anticipated and actions had 

been taken prior to the activity. Specifically, the health physics report dealing with the situation 

states: 

Contamination in excess of area control levels occurred in Area 108 and 154. 

Maintenance operations on a metal system contained in a glove box in Room 2, 

Area 108, resulted in tritium floor contamination exceeding area control levels by 

a factor of 10,000. Controls imposed prior to the commencement of work, 

confined the contamination to the room, however, the levels were considerable 

[sic] higher than expected. [GE 1957–1973] 

Finally, it appears that at times “paper” was used to cover floor and work surfaces prior to 

activities that might result in contamination. After the specific operation had taken place, the 

paper was removed and disposed of as contaminated waste. One such example is shown in 

Figure 10 from a health and safety manual from 1982. This type of activity would minimize the 

occurrence of significant contamination occurring for long periods of time. 
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preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support 

and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

Figure 10. Screenshot of a 1982 Health Physics Procedure Indicating that “Paper” Was 

Used to Limit Long-Term Contamination During Certain Operations. 

Observation 6: Based on a review of available health physics reports, it appears that the 

health and safety staff recognized situations that posed an elevated threat of tritium 

contamination and took precautions to minimize exposures. 

3.0 DISCUSSION OF REMAINING PARAMETERS IN SMT DOSE 

RECONSTRUCTION APPROACH

Aside from the selection of the area contamination value reviewed in detail in Sections 2.0–2.3, 

the remaining assumptions and parameter choices are pertinent in developing bounding and 

claimant favorable intakes of SMTs. These include the following: 

 Selection of a resuspension factor 

 Ability of the Pinellas measurement system to detect SMT contamination (mainly the 

effect of filtration prior to the actual measurement) 

 Solubility type of the assumed SMT intakes 

 Breathing rate and exposure duration 

This section provides a brief discussion of each of the above characteristics of the proposed 

intake model for SMTs. 

3.1 CHOICE OF RESUSPENSION FACTOR 

NIOSH 2015 proposes the use of a resuspension factor of 5×10-5 m-1 based on the methodology 

developed for the Mound Site (see Issue #1 of NIOSH 2015). This represents an increase in the 

originally recommended value of 1×10-6 per meter (m-1) found in ORAUT 2012. It is important 

to note that in the case of the Mound site, the 95th percentile contamination value had been 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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selected along with a resuspension value of 5×10-5 m-1. Because of the limitations on available 

survey data at Pinellas, this resuspension factor of 5×10-5 m-1 is being proposed in conjunction 

with the maximum observed contamination value.4

4

 Note that in Section 2.3, SC&A has identified three other contamination surveys that exceeded the NIOSH 2015 

proposed value of 4.4×106 dpm/100cm2. 

The resuspension factor used at Mound and currently proposed for Pinellas is based on 

recommendations in NUREG/CR-5512 (NRC 1992), which cites the International Atomic 

Energy Agency recommendation for indoor areas of nuclear facilities with surface contamination 

and moderate activity. SC&A finds that the choice of a resuspension factor of 5×10-5 m-1 is 

technically appropriate and claimant favorable in the proposed methodology for reconstruction 

of tritide intakes at Pinellas. 

3.2 EFFECTIVENESS OF SURVEY MEASUREMENTS FOR CAPTURING STABLE 

METAL TRITIDES 

NIOSH 2015 investigated the ability of the measurement system and contamination smear 

techniques used at Pinellas for detecting SMTs. Specifically, the concern was raised that the use 

of filters prior to counting the smear sample may have removed the applicable SMT particles,

which would render the measurement system incapable of producing an accurate result. NIOSH 

2015 states the following under Issue #3: 

The three tritium contamination smear analysis procedures that are available 

indicate that the Pinellas Plant used wetted cotton balls to collect smear samples 

for tritium contamination monitoring. The available procedures also indicate that 

the cotton ball smear samples were rewetted in a paper cup with a prescribed 

amount of deionized water (8 to 10 ml, depending on the procedure), and that a 

rinsate was squeezed from the cotton balls while they were still in the paper cup. 

These procedures indicate that the rinsate from the cotton balls was then filtered 

through a Whatman #1 filter. 

NIOSH 2015 presents the following information to alleviate concerns with the use of filters on 

smear samples: 

1. The practice of filtering the sample may have been limited to certain years: 

a. Two of three procedures that mention filtering through the Whatman #1 filter were 

undated but likely were from the late 1960s into the 1980s. 

b. Worker interviews indicate filters may not have been used by 1977. 

i. One health physicist who worked from 1987 to 1997 indicated no filtration took 

place. 

 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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ii. Two workers from the chemistry department from 1977 to 1997 did not recall a 

filtration step in the analysis process. 

2. The pore size for a Whatman #1 filter is approximately 11 microns, with a maximum of 

12.7 microns (a non-respirable particle size). One reference indicated that titanium 

hydride (an SMT) had average particle sizes of 6–9 microns and, therefore, would not 

have been removed by filtration. 

3. Soluble forms of tritium were in much greater abundance than the insoluble SMT 

material. Therefore, assuming that all contamination was 100% SMT would account for 

any limitations on the smear surveys due to filtration. 

With regard to Item 1 on this list, SC&A verified the references contained in NIOSH 2015 and 

concurs with NIOSH’s assessment of the material. One of the undated survey procedures that 

mentions the Whatman Filter #1 alluded to in NIOSH 2015 is consistent with Project Document 

Number 240001177 found in the internal TBD (ORAUT 2012); this reference was dated circa 

1966. This would be consistent with the assertion that the use of Whatman #1 filters was 

restricted to certain time periods. 

SC&A also confirmed that the Whatman #1 filter paper has a pore size of 11 microns5

5

 By comparison, Type #2 filters have a pore size of 8 microns, and Type #3 have a pore size of 6 microns. 

(SigmaAldrich 2016) and so agrees that respirable particles would not have been removed from the 

sample in any significant amount prior to assessment of the contamination on the survey smear. 

SC&A agrees that insoluble forms of particulate tritium make up only a fraction of the tritium 

contamination observed at Pinellas. Therefore, the assumption that all contamination on 

available survey smears was SMT material is considered claimant favorable and bounding. 

However, SC&A is concerned that the use of a “wetted cotton ball” for collecting the initial 

contamination may result in the “trapping” of particulate SMT material within the cotton ball and 

hinder the transfer of contamination from the swab to the rinsate. Because NIOSH (2015) does 

not specifically discuss this possibility, SC&A has requested clarification from NIOSH regarding 

this potential avenue for source degradation prior to measurement. 

Observation 7: The potential for particulate SMT material to be trapped in the wetted 

cotton ball prior to filtration, and thus possibly hindering the transfer of SMTs into the 

measured rinsate liquid, should be investigated and/or clarified in NIOSH’s proposed 

approach for the reconstruction of insoluble SMTs.

3.3 CHOICE OF SOLUBILTY TYPE FOR ASSIGNMENT OF SMT INTAKES 

NIOSH 2015 has elected to assume that all intakes associated with resuspended contamination 

are considered insoluble. It is clear that many different solubility types might have been 

experienced by workers at Pinellas; however, it is not possible to differentiate between distinct 

solubility types for the purposes of assigning intakes of SMT material. It should be noted that 

 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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ORAUT 2012 had originally instructed dose reconstructions to consider both Type M and 

Type S tritium compounds when considering intakes of SMTs. SC&A agrees that the selection 

of Type S solubility for all intakes associated with resuspended contaminated material is 

claimant favorable and bounding. 

3.4 WORKER BREATHING RATES AND EXPOSURE TIMES

NIOSH has assumed a worker breathing rate of 1.2 cubic meters per hour (m3/hour) over a 

standard 2,000 hour work year. The choice of 1.2 m3/hour is the assumed value for a reference 

worker performing “light activity” and is appropriate for the type of work expected to occur at 

Pinellas. The 2,000-hour work year is based on a typical 40-hour work week in conjunction with 

50 weeks per year. However, ORAUT 2012 stated the following concerning the exposure 

duration to workers exposed to SMTs: 

Assuming a breathing rate of 1.2 m3/hour and the exposure time assumption of 

2,600 hours (based on a review of telephone interviews provided by former 

workers, 50-hour weeks were routine), annual inhalation and ingestion intake 

rates for insoluble tritium were calculated... [emphasis added] 

NIOSH 2015 does not provide a specific rationale for decreasing the assumed exposure time 

from 2,600 hours per year to 2,000 hours per year as prescribed in ORAUT 2012. Unless specific 

information has been obtained and identified for the decrease in annual work hours, the original 

claimant-favorable assumption of a 50-hour work week based on documented telephone 

interviews would appear appropriate. 

Finding 1: NIOSH 2015 recommends a worker exposure duration of 2,000 hours per year. 

However, ORAUT 2012 had prescribed an exposure duration of 2,600 hours per year,

based on documented statements from former workers indicating regular 50-hour work 

weeks. Absent additional information to the contrary, the original assumption of a 50-hour 

work week appears appropriate. 

4.0 SUMMARY CONCLUSION 

Based on a thorough review of NIOSH 2015 and the underlying documentation, SC&A 

concludes that the methodology provides a framework that effectively bounds the potential for 

exposure to insoluble tritium compounds experienced at the Pinellas Plant. This conclusion is 

based on the following: 

 Use of one of the highest observed contamination survey values in characterizing the 

resuspended material present for worker intake 

 Use of a conservative resuspension factor to account for airborne particulate tritium 

material from contaminated surfaces 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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 Documentation (including health physics procedures, actual contamination surveys, and 

interviews with former workers) indicating that, when contamination was detected above 

the control limits, it was quickly decontaminated and the area resurveyed to assure 

compliance with the applicable limits 

 Use of mitigating procedures, such as disposable paper on surfaces likely to be 

contaminated, to assure long-term contamination was not experienced by Pinellas 

workers 

Although actual contamination smear survey data are sparse to nonexistent for many years, 

documentation suggests that events or incidents that would approach the assumed contamination 

value in NIOSH 2015 would not have existed for any significant amount of time. SC&A did 

identify 3 years in which the maximum measured contamination exceeded the proposed value in 

NIOSH 2015; however, it is questionable in at least two of the three cases whether substantial 

exposure potential was likely to have existed. Finally, SC&A recommends that, absent sufficient 

documentation or rationale, the original assumption of a 50-hour work week from ORAUT 2012 

be adopted. 

5.0 REFERENCES 

ABRWH 2012. Transcript of the Advisory Board on Radiation Worker Health – Work Group on 

Pinellas – November 19, 2012. U.S. Department of Health and Human Services – Centers for 

Disease Control – National Institute for Occupational Safety and Health. November 19, 2012. 

GE 1957–1973. HP Summary Reports 1957–1973. General Electric. Pinellas Plant, St. 

Petersburg, FL. Date Captured: June 8, 2004. SRDB REF ID: 27095. December 11, 2015, 

NIOSH 2015. Review of NIOSH’s Current Approach to Reconstruction of Insoluble Tritium 

Particulate at the Pinellas Facility, Revision 0. Division of Compensation Analysis and Support, 

National Institute for Occupational Safety and Health, December 11, 2015. 

NRC 1992. Residual Radioactive Contamination from Decommissioning – Technical Basis for 

Translating Contamination Levels to Annual Total Effective Dose Equivalent. U.S. Nuclear 

Regulatory Commission, Contractor Technical Report, NUREG/CR-5512. October 1992. 

ORAUT 2012. Pinellas Plant – Occupational Internal Dose. Gleckler, B.P., Sharfi, M.M., Oak 

Ridge Associated Universities Team, ORAUT-TKBS-0029-5, Revision 02. February 21, 2012. 

Sigma Aldrich 2016. Online Catalogue for the Sigma Aldrich Chemical Company – Product 

#Z271071. Sigma-Aldrich Website, accessed January 19, 2016 at 

www.sigmaaldrich.com/catalog/product/aldrich/z271071. 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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APPENDIX A: EXAMPLE OF A COMPLETE MONTHLY HEALTH 

PHYSICS REPORT 
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

APPENDIX B: EXAMPLE OF A HANDWRITTEN SURVEY LOGBOOK 

FROM 1959 
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cleared for distribution.

APPENDIX C: EXAMPLES OF DOCUMENTED CONTAMINATION 

CONTROL AND CLEANUP ACTIVITIES 

SRDB Date Description

133591 September

1957

“Surface contamination smear surveys in Tube Exhaust, generally 

revealed detectable levels of radioactivity. Decontamination was 

affected as required. Surveys in other plant areas revealed no detectable 

levels of contamination.”

133591 October 

1957

“Because of the increase in extent and magnitude of surface 

contamination in the area, a proposal pertaining to routine cleaning was 

submitted to, and accepted by, Tube Exhaust and Plant Facilities’

supervision.”

133582 December 

1957

“Operations in Tube Exhaust resulted in four instances of personnel 

contamination. Two instances were associated with vacuum pump 

maintenance, one with glass system repair and one occurred when a 

high concentration of airborne radioactivity was encountered.

Routine and special surveys disclosed lower levels of contamination in 

the Tube Exhaust Area attributable to a major decontamination effort 

and to decrease in the Area’s work load. There were no appreciable 

levels of contamination detected in any other area.”

133578 January 

1959

“Tube exhaust had 3.3×10-2 μCi/in2in HR-18. Notes any area above 

2×10-5 μCi/in2(688 dpm/100cm2, decontamination was 

recommended.”

133577 February 

1960

“Exhaust corridors showed 12% smears above the control limit. 

Broken tube caused floor contamination of 1.1×10-5 μCi/in2, 

decontamination was effected immediately.”

133577 November 

1960

“On August 12, 1960, during the transfer of a broken tritium flask from 

Room 14 to Room 18, Area 8, titanium hydride particles fell to floor 

causing a spread of radioactive contamination throughout Area 8 and 

into the Exclusion Area corridor. Decontamination efforts were 

continued on a three-shift basis on August 13 and 14.”
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reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

SRDB Date Description

133585 February 

1961

“Two instances of contamination in exclusion area corridors.

Analyses of material containing radioactivity, resulted in two instances 

of floor contamination in the Chemistry Laboratory. On both occasions 

the contamination was contained within the laboratory area which had 

been established as a ‘Contamination Zone’. Decontamination, 

subsequent to each analysis, was effected without difficulty.”

133585 February 

1961

“Removal of a vacuum pump from the stack effluent control system 

resulted in contamination of the floor in the Fan Room. The 

contamination was contained within the room and was easily removed 

at the completion of the operation.”

133585 April 1961

“1 of 259 smears was above the control level in exclusion area 

corridors.

Breakage of a system in room 20 resulted in a spread of radioactive 

contamination throughout Area 8. Decontamination of the area was 

completed within five hours.”

133585 May 1961

“1 of 322 smears was above the control level in the exclusion area 

corridors.

On two occasions, radioactive contamination was detected in the Area 

8 corridors. In one instance the contamination was associated with 

cleaning operations in Hoodroom 18 while the other resulted from the 

reappearance of contamination which had been deposited under 

deteriorated floor tile in Hoodroom 20. In both instances, the 

contamination was contained within Area 8. Decontamination was 

effected without difficulty.”

133585 July 1961

“There were no indications of radioactive contamination exceeding 

control levels in the exclusion area corridors or the Tube Exhaust 

corridors during the report period.

An increase in contamination frequency, attributed to shut-down 

operations, was noted in the Area 8 hoodrooms. Radioactive 

contamination, exceeding control levels, was detected in the Fan Room 

following repairs on the SEC system and in Tube Test when a tube was 

broken. In both instances, the perimeters of contamination were 

controlled and decontamination immediately effected.”
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

SRDB Date Description

133585 September 

1961

“On September 22, a tritium flask was broken in Hoodroom 24, Area 8, 

resulting in high levels of radioactive contamination inside the hood. 

Immediately following the breakage, the flask was packaged to prevent 

further release of radioactive material. Subsequent to disposal of the 

flask as contaminated waste on September 25th, decontamination of the 

hood’s interior was initiated. During this operation, low-level 

contamination of the room’s floor occurred. Decontamination within 

the room was completed without difficulty.”

133585 November 

1961

“1 of 442 smears was above the control level in Area 8 corridors. The 

contamination was effectively contained within Area 8.

During the month two instances of localized radioactive contamination 

occurred in Area 32B and 15 resulting from broken tubes. The areas 

were decontaminated and bioassay specimens obtained from the 

involved personnel. No significant body depositions of tritium were 

detected.”

133587 January 

1962

“One instance of floor contamination in excess of the detectable level 

occurred in Area 15, as a result of tube breakage. Decontamination was 

immediately effected.”

27095 April 1962 “Low level contamination occurred in Area 15 in connection with tube 

breakage. Decontamination was immediately effected.”

27095 May 1962 “Low level contamination occurred in Area 12 in connection with tube 

breakage. Decontamination was immediately effected.”

27095 August 

1962

“Low level contamination occurred in Area 12 and Area 15 as a result 

of tube breakage. Decontamination was immediately effected.”

27095 October 

1962

“Low level contamination occurred in Area 15 in connection with tube 

breakage. Decontamination was immediately effected.”

133580 July 1963

“One instance of localized contamination occurred in the Receiving 

Well when condensate from a refrigerator being transferred under 

regulated release status, spilled on the floor. Decontamination was 

immediately effected without spread of the radioactive material.”

113580 September 

1963

“One instance of localized contamination occurred in the Industrial 

X-Ray Viewing Room of Area 9 as a result of product tube breakage. 

Decontamination was immediately effected.”
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been 

reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 552a and has been 

cleared for distribution.

SRDB Date Description

113580 November 

1963

“One instance of localized contamination was experienced when Turco 

solutions was accidently spilled on the floor in Laboratory-29A. 

Decontamination was immediately effected.”

113580 December 

1963

“One instance of localized contamination was experienced when a 

product tub was accidentally dropped in Area 15. The area was 

immediately decontaminated.”

113586 February 

1964

“Contamination, resulting from breakage of a number two flask, was 

contained within the room in which the breakage occurred. 

Decontamination was completed without difficulty.”

133586 June 1964 “An instance of floor contamination was detected during renovation in 

Hoodroom 3, Area 8. The area was effectively decontaminated.”

133586 September 

1964

“Floor contamination on the order of 1×10-5 μCi/in2resulting from a 

tube puncture in Area 65 was effectively removed.”

133586 November 

1964

“Floor contamination was experienced during equipment cleaning in 

Area 8. Decontamination was effective in reducing activity to 

permissible levels.”

133579 February 

1965

“The construction of cathode replicas in Area 54 resulted in low-level 

floor contamination. Previously established control measures 

effectively contained the radioactivity within the area. 

Decontamination was effected at the completion of the job.”

133581 March 1966

“100 times the applicable limit was detected in the main section of the 

Test and Analysis Laboratory, Area 65. The contamination had been 

tracked from the ‘Contamination Area’ of the laboratory. 

Decontamination was effective.”
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SRDB Date Description

133581 September 

1966

“Radiological assistance continued to be provided at G.E.X.M. relative 

to the re-location of Engineering Development in Florida. Through 

September a total of 1054 smears had been obtained and processed for 

radioactivity analysis. There was one instance of contamination 

resulting from transfer of material from Milwaukee to Pinellas Plant. 

The source of contamination, a flexible metal connecting line, caused 

low level contamination of the transport van, some containers in the 

shipment, packing blankets and of the Plant’s warehouse. Excepting for 

the blankets, decontamination was effected without difficulty. A total 

of 371 blankets containing an estimated 3×104 μCi of tritium were 

disposed of as contaminated waste. Associated personnel exposures 

were negligible.”

133581 December 

1966

“Continuous monitoring was provided during the unpacking and 

assembly of the glove box line in Area 82c. One instance of 

contamination in the Exclusion Area corridor, at the 82c entrance, 

occurred during the transfer of contaminated equipment to the 

overhead. Decontamination was immediately effected.”

27095 September 

1967

“Routine area surveys and continuous air monitoring revealed 

contamination controls to be effective with the exception of an incident 

occurring in Area 7, an uncontrolled area. On September 21, 1967 a 

contamination incident occurred when radioactivity was released from 

a glove box in Area 7, causing contamination of employees’ shoes, the 

corridor area between Areas 7 and 8, and localized sections of Areas 7 

and 8. The incident occurred when a hack saw, used in opening a 

container of tritium loaded material, was removed from the glove box 

line without benefit of contamination survey, and was carried to Area 

8. There were no significant radiation exposures associated with the 

incident and decontamination was effective.”

27095 May 1969

“A total of 305 contamination surveys were performed during the 

report period. Instances of contamination above area control levels 

were experienced on several occasions during maintenance on metal 

exhaust systems in Area 108. Controls, instituted prior to the 

commencement of work proved adequate in confining the 

contamination to the immediate work area. Decontamination was 

effected with no significant exposures.”
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SRDB Date Description

27095 September 

1969

“A total of 217 contamination surveys were performed during the 

report period. Instances of contamination above area control levels 

were experienced during maintenance work on the Source Loading 

Station, Area 108, in Area 165A following work on a portion of a 

metal exhaust system, and in Room 2, Area 108 following removal of a 

vac-ion pump from a glove box. Decontamination was effected.”

27095 1st Quarter 

1970

“Contamination occurred in Area 154 when a flaking tube part was 

removed from its container for microscopic examination. On noticing 

the flaking, the technician requested a survey by Environmental Health. 

Survey results indicated contamination of tools, equipment and floors 

in the area. Controls to prevent further spread of contamination proved

to be effective and decontamination was accomplished.”

27095 May 1973

“A routine contamination survey performed in May revealed extensive 

floor and work surface contamination in area 158B. Additional surveys 

disclosed contamination spread into areas 156, 157, and the north-south 

corridor outside of area 157. Decontamination was effected.”
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and review contractors) positions, unless specifically marked as such. This document represents preliminary 

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APPENDIX D: EXAMPLES OF PREDICTED CONTAMINATION 

EVENTS THAT SHOW EVIDENCE OF PLANNING FOR SUCH 

OCCURENCES 

SRDB Date Description

133579 February 

1965

“The construction of cathode replicas in Area 54 resulted in low-level 

floor contamination. Previously established control measures 

effectively contained the radioactivity within the area. 

Decontamination was effected at the completion of the job.”

27095 February 

1969

“Anticipated contamination above the control limit of 440 

dpm/100cm2, was associated with work in Areas 108, 132B, 154, 155, 

158, 162, 182A, 182B, 182C, and 182D. The maximum contamination 

level, 4.3×10-5dpm/100cm2, was detected on the work surface of a 

hood in Room 20, Area 108, following the disassembly of a vac-ion 

pump.

Continuous monitoring was provided by Environmental Health during 

disassembly.

Airborne tritium concentrations to a maximum of 1.3×10-3 μCi/cc were 

encountered by employees performing maintenance on a mass 

spectrometer in Room 3, Area 108.”

27095 May 1969

“Instances of contamination above area control levels were experienced 

on several occasions during maintenance on metal exhaust systems in 

Area 108. Controls, instituted prior to the commencement of work 

proved adequate in confining the contamination to the immediate work 

area. Decontamination was effected with no significant exposures.”

27095 November 

1969

“Anticipated and controlled contamination occurred in Areas 108 and 

158B in association with vac-ion pump maintenance and routine 

analyses respectively.”

27095 December 

1969

“Contamination detected in Area 108 and 182D, in association with 

maintenance of a leak detector and source loading respectively had 

been anticipated and provisions were provided for protection and 

control.”
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SRDB Date Description

27095 1st Quarter 

1970

“Contamination in excess of area control levels occurred in Area 108 

and 154. Maintenance operations on a metal system contained in a 

glove box in Room 2, Area 108, resulted in tritium floor contamination 

exceeding area control levels by a factor of 10,000. Controls imposed 

prior to the commencement of work, confined the contamination to the 

room, however, the levels were considerable [sic] higher than 

expected.”

27095 2nd Quarter 

1970

“A total of 316 contamination control surveys performed during the 

report period indicated controls were effective. Several instances of 

anticipated contamination within controlled areas occurred during 

planned work, associated with maintenance of metal exhaust systems, 

operations in Room 18, Area 108, disposal of oxidized beds, and work 

in 182D.”

27095 3rd Quarter 

1970

“Several instances of contamination within controlled areas occurred, 

however, controls were effective in preventing contamination spread, 

and minimizing tritium exposures to personnel.”

27095 4th Quarter 

1970

“A total of 331 contamination surveys were performed during the 

report period. Several instances of contamination within controlled 

areas occurred. Procedures for contamination control were effective in 

preventing contamination spread, and minimizing tritium exposures to 

personnel.”

27095 1st Quarter 

1973

“A total of 352 contamination surveys and 30 radiation surveys were 

performed during the report period. Localized contamination associated 

with work involving a high potential for radioactivity spread was 

effectively minimized and controlled through radiological safety 

procedures imposed prior to commencing the jobs. The work involved 

maintenance of metal exhaust and loading systems and removal of 

glass systems from room 13, area 108.”