REMAINING HANFORD SEC ISSUES 

FOR SEC PETITION SEC-00057-2 and SEC-00152 

Prepared by SC&A 

Updated August 19, 2011 

This is the second update of the Hanford SEC matrix. The first update was in November 2009 

(SC&A 2009); it was prepared following the Board’s October 22–24, 2009, meeting at which it 

accepted NIOSH’s recommendation that the SEC be extended to June 30, 1972, to cover all 

eligible Hanford workers, provided they meet the health endangerment requirement of 250 days 

or more of qualified employment. As a result, issues up to June 30, 1972, were no longer 

relevant for further SEC review. The matrix revision of October 2009 reflected this fact. SC&A 

was not asked to review SEC Petition SEC-00152, since that was an “83.14” petition initiated by 

NIOSH to recommend an addition to the Hanford SEC. 

The period covered by SEC Petition SEC-00057-2 extends to December 31, 1990. At the time of 

the October 2009 meeting, NIOSH had reserved judgment about the feasibility of dose 

reconstruction for the rest of the SEC-00057-2 period from July 1, 1972, to December 31, 1990. 

In 2010, NIOSH published a revised Technical Basis Document (TBD) for Hanford in which the 

dose reconstruction methods for all aspects of dose were set forth, taking into account the 

NIOSH findings in its SEC Evaluation Reports. The updated TBD also discussed the period in 

Petition SEC-00057-2 remaining to be addressed by NIOSH. SC&A was asked by the Advisory 

Board to review the revised TBD in light of the outstanding issues that had not yet been 

addressed at the time of the matrix update in October 2009. SC&A was also asked to not 

evaluate any dose reconstruction methods in the TBD that were not in the remaining SEC period 

from July 1, 1972, to December 31, 1990. 

The matrix below updates the November 2009 matrix (SCA 2009) based on the review of the 

2010 TBD (ORAUT 2010a through ORAUT 2010f). In the process, SC&A also reviewed the 

internal dose database, as well as a variety of Hanford documents in the Site Research Database. 

The main purpose was to examine whether NIOSH had established the feasibility of dose 

reconstruction for the outstanding matrix issues and, if not, what concerns still remained. SC&A 

completed its review in July 2011 and the report is in the process of being reviewed by the 

Department of Energy (DOE). This matrix update is based on the findings of that review. 

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. 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

1. Thorium-232 internal exposure from Sept. 1, 1946, up to December 31, 1959 

SEC proposed for Buildings 313, 306, 3722, 3706 

Buildings and locations other than the ones listed in the NIOSH ER appear to be involved, for instance, and 303-K, 305 Test Pile, 314, 321, 3307 A and B (change houses with thorium contamination), and Sites 300-33 and 300-26, sites with thorium contaminated soil. The 100 Area was also involved in thorium work; for instance, 105-D and 105-H reactors (there was a slug failure in the latter in 1954). The use of the REDOX facility (202-S) for U233 separation from irradiated Th-232 slugs was evaluated in 1955. Workers moved within an area without a record being maintained on a day-to-day basis. Many workers were roving workers and/or construction workers. 

This issue is reso

2. Americium-241 internal exposure, January 1, 1949 to December 31, 1968 

SEC proposed for Buildings 231-Z, 242-Z and 234-5Z 

Buildings and locations other than the ones listed in the NIOSH ER appear to have been involved. 303-C was used for americium storage. There was Am-241 separation in Building 325. The 216 series cribs and ditches were used for discharge of wastes from the Plutonium Finishing Plant. Workers moved within an area without a record being maintained on a day-to-day basis. Many workers were roving workers and/or construction workers. 

This issue is reso

3. Thorium-232 internal exposure from January 1, 1960, onward. 

The ER assumes that sufficient Th in-vivo data exist, and that dose reconstruction can be done. OTIB-0039 proposes to estimate Th intakes based on uranium intakes. NIOSH investigating further. 

The REX database summary in the ER contains no Th data points until 1969, very few scattered data points from 1970 to 1981, and none after that. Data adequacy not established. Validity of using U intakes for Th intake estimation not established. 

Data are not adeqDecember 31, 19exposure potentiintermittent. Valuse for Th dose n

Draft Hanford SEC Issues Matrix Page 2 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

4. HEU – uranium intake 

estimation 

ER does not discuss potential for HEU exposure. 

HEU was used at Hanford at various times. Only fluorometric urine data for uranium are available until 1983, preventing an estimation of U isotopic composition. HEU was used in early tritium and U-233 production (1949–1954), for reactor power enhancement (to June 1958), and possibly in the mid-1960s for U-233 production (N reactor). Some R&D uses continued into the 1980s. J and C slugs containing HEU were canned at Hanford. Fluorometric data are generally not adequate to estimate exposure to HEU in a context where most exposure to most workers was to low enriched or natural uranium. 

Scattered handlinHEU continued pneeds to demonsto interpret fluorsufficient in-vivo reconstruction an

5. Uranium intake estimation prior to 1948 

ER considers Hanford U data prior to 1948 unreliable and backextrapolation of later data to be scientifically inappropriate due to changes in equipment and methods. The ER proposes to use AWE data for this period. 

Equivalence of the use of AWE uranium data for the experimental and early production processes has not been demonstrated to be bounding or suitable for Hanford circumstances in an SEC context. 

This issue is reso

6. Uranium intake estimation to 1990 for unmonitored workers 

The ER proposes using coworker data. 

Adequacy of coworker model (Table 6-3 in OTIB-0039) remains to be established in the SEC context. 

Uranium bioassadose reconstructiSome revisions aNIOSH’s approa

7. U-233 intakes 

The ER proposes using the highest U-233 intake estimate. 

Adequacy of U-233 internal monitoring data and data for associated contaminants to determine bounding dose (or a 

dose estimated with greater accuracy) needs to be examined as a potential SEC issue. The history of U-233 production and separation also needs evaluation in the SEC context. 

 NIOSH should d1972 thorium pemake and separafound evidence f

Draft Hanford SEC Issues Matrix Page 3 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

8. Recycled uranium intake estimation. 

The ER does not discuss intakes of contaminants in RU. The TBD has some data, with the earliest dating from 1988. 

Exposure to the trace contaminants in RU may be a potential SEC issue starting in 1952, when RU was recovered at Hanford from the high-level waste tanks. The potential ending time would need further study. Adequacy of the RU contaminant table in ORAUTTKBS-0006-5 (Vol. 5, Rev. 01, Table 5.32.5-2, p. 24)) needs to be examined in light of 42 CFR 83 requirements, and historical data at Hanford indicating higher contaminant levels. Some data indicate higher levels of trace contaminants in the early period than are shown in the TBD table. 

Data from 1970–claimant favorabNIOSH should u1980s data.

9. Neptunium-237 intakes, 1958 to 1972 

The ER states that, “Plutonium[-238] bioassay was considered sufficient to monitor for neptunium intakes” (p. 41). 

The validity of the suggested approach has not been established, especially in the context that Hanford handled separated Np. Only four Np bioassay samples exist for 1972 (REX database summary) and none before that. 

Neptunium data separation was d1972. Later neptdiscussed, but it This issue needs NIOSH should pthe dose assignmrelationship.

10. Tritium intake estimation from 1949 onwards 

The ER states that data are available from 1949 onward and that they are sufficient for coworker dose determination. 

The REX database shows no tritium samples until 1982. SC&A awaits the results of NIOSH’s data capture efforts on this issue. 

Inadequate techn1981 coworker inSpecific worker 1972, to June 30OBT and tritide edefined and cow

11. Promethium-147 

The ER contains a discussion of processes involving promethium, but has no discussion of dose reconstruction methods. 

The REX database has promethium bioassay data from 1966 onward. Promethium processing may have started in 1962, and possibly earlier. Feasibility of dose reconstruction remains to be established, at least to 1966. Adequacy of data needs to be investigated from 1966 onwards. The coworker model does not address pre-1966 exposures or roving worker exposures (for workers not based in Buildings 308 or 325). 

Contrary to the Tduring 1972–197assignment is noIncidents are docaddress dose recoincidents. 

Draft Hanford SEC Issues Matrix Page 4 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

12. Sr-90, Cs- 137, MFP intake estimation 

Prior to 1965, the approach suggested is use of mixed fission product and Cs-137 data. The ER states mixed fission product urinalysis started in 1947; “erratic until 1948” (p. 39) 

 Dose reconstruction feasibility before 1948 is a 

potential issue. 

 The REX database summary shows no fission 

product data prior to 1974. Use of the REX database for the early years needs to be assessed for possible changes in processes and validity of back extrapolation, and for its use in coworker dose estimation. 

 Sr-90 bioassay data available from 1965 onwards.  Cs-137 whole-body count data available from 1960 

onward (according to the ER), but no data points in REX until 1972. 

Ample data are ayears. Quality oaddressed, as MDyears. Audits foclear if they were Sr-90 intake assifavorable. Sr-90 to be developed iseparation and enTank farm workeof 1977. Compaconditions for inexamined. Coworker model areas, but may noAreas.

13. Tank Farm alpha contamination 

The ER does not explicitly discuss this issue. 

Site expert interviews indicate that tank farm exposures, 

including alpha-emitting radionuclide intakes (such as those from resuspension), may have been missed. 

Tank farm data iother matrix item

14. Plutonium intake estimation 

The ER has an extensive discussion of data and dose reconstruction approach. 

May not be an SEC issue. Frequency of Pu urinalysis fell sharply in the late 1950s. Minimum detection limits were variable (higher in earlier years). Coworker models need to be evaluated from an SEC standpoint (e.g., adequacy of the REX database for coworker models). 

Super S intake noMDA not met in not found. Implireconstruction anneed review. Uninto 1988 and 19Method of redacsamples may resdose. 

15. Hot particle ingestion The ER does not discuss this issue Ingestion of hot particles could be an issue for 1947 and 1948 T and B plant emissions and for 1952–1955 REDOX plant emissions (TBD Vol. 4 Rev. 2, p. 27). This issue is reso

Draft Hanford SEC Issues Matrix Page 5 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

16. Cm-244 

The ER states, “However, extraction of curium-244 from high-level waste occurred at the 325 Building sometime in the 1970s. Since the curium and americium procedures were the same, the results would have been reported as curium only, if so requested through the bioassay request system....” 

Significant amounts of Cm-244 (65 grams—more than 5,000 curies) appear to have been processed in the 1960s in Building 325 (Gerber, M.S. 1993. Multiple Missions: The 300 Area in Hanford Site History, WHC-MR-0440, Westinghouse Hanford Company, Richland, Washington. September 1993, p. 23). Earliest Cm-244 data in the REX database summary in the ER are from 1968 (6 data points), after which there are 8 more in 1974. NIOSH has not presented a DR method for estimating Cm-244 intakes during the campaign that purified 65 grams in the 1960s. 

Exposure potenti1978. No data foCoworker model 1990. NIOSH has not gfor using Pu data 

17. Neutron doses to December 31, 1971 (after which TLDs were introduced) 

ER proposes to use: 

 n/p ratios until 1958.  Adjusted NTA film 

data, to end of 1971 

NIOSH is engaged in an extensive neutron-related data capture effort. 

Issues: 

 Validity of n/p ratios for specific time and work 

location 

 Adjustment factor accuracy and/or bounding value  Area coverage of neutron monitoring  Construction worker neutron monitoring, since there 

is a claim in the petition that some construction workers were not monitored for neutrons (OTIB0052 for construction workers did not address neutron doses) 

This issue is reso

Draft Hanford SEC Issues Matrix Page 6 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

18. External exposure geometry 

The ER does not explicitly discuss this issue. 

Site expert evidence indicates significant geometry issues 

in some circumstances that may prevent film badge or TLD from registering relevant organ dose. 

This is a site pro

19. Lack of adequate monitoring: Petitioner issue 

The ER discusses this in Section 7.4 and bases dose reconstruction feasibility on coworker models 

Coworker model adequacy from the SEC point of view needs to be evaluated in general and specifically in light of petitioner affidavits. 

External data are addressed in othe

20. Skin contamination 

The ER and TBD describe skin dose and extremity dose monitoring and assignment. 

Site expert interviews indicate unusual potential for skin exposure in some maintenance work. This needs to be evaluated against available data. TBD discusses hot particle skin dose. Validity of skin dose coefficients in the Hanford external dose TBD (Rev. 3) needs to be investigated. Hot particle skin doses need to be evaluated for 1947–1948 and 1952–1954. 

This issue is joinsince it relates to exposure is captu

21. Missing records –routine (Petitioner issue) 

The ER refers to the coworker model OTIB0052 for construction workers and general guidance to fill in doses corresponding to missing records. 

SEC-specific analysis for Hanford is needed to verify that the approaches specified are bounding doses (or more accurate than bounding doses) for all members of the proposed class. 

Review of box laindicates vast mapre-July 1, 1972. clear date for conhave had relevanduplicates exist. 

22. Missing incident records 

The ER does not explicitly address this issue. 

DOE files of claimants who have affidavits in the Petition need to be examined. Data completeness for incidents needs to be checked. This also links to potential destruction of records and existence of duplicate records. Specific incidents need to be evaluated, including a criticality in the 1950s. 

Individual DOE-examined contain mentioned in CAThe REX databaincidents. No pafrom personnel r

Draft Hanford SEC Issues Matrix Page 7 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

23. REX database adequacy and representativeness for coworker models 

The ER acknowledges that the REX database is not complete for early-year data, but that other reports provide the data in question. 

Coworker models are based on the REX database. The representativeness of the REX database for estimating coworker doses needs to be examined in the SEC context. 

This issue is additems. 

24. Polonium-210 

Bismuth was irradiated at Hanford starting in 1945, but separation and processing did not begin till 1968, from which date bioassay data are available. 

Verification of no processing of irradiated bismuth target rods before 1968 is needed. This issue is reso

25. Miscellaneous radionuclides (e.g., Cr51, Ru-106, Ce-144, Co60) The ER relies on the internal dose TBD. Adequacy of the TBD approach for bounding doses needs to be assessed. 

MDA for several 1981. Earlier authey were done). address these radSome radionuclidfrom 1983 or 198model is needed products for the 2farm workers, anprocessing buildi

26. Data completeness 

The ER cites individual dose records and other sources of data. Principal reliance is on individual dose records for the most part. 

Completeness of individual dose records may need investigation. 

This item has beematrix items. 

Draft Hanford SEC Issues Matrix Page 8 of 10 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

However, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

Draft Hanford SEC Issues Matrix Page 9 of 10 

: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act information and has 

er, as this is a “living” document that is continually changing, later versions will require additional reviews before being made 

Issue number and 

description 

NIOSH ER Position 

(SC&A Reading) SC&

A Statement 

SC&A u

For th

Decemb

NOTICE

Howev

27. Building 324 leaks N/A 

There were leaks of high-level waste in the A-, B- and CCells, Building 324. The B-Cell leak resulted in soil contamination, discovered in 2010 during decommissioning. SC&A was asked to investigate the issue but only for the remaining SEC period, July 1, 1972 to December 31, 1990. This item was submitted to the WG by the public during the SEC review process. 

There were leaks Cell, Building 32reportedly in 198cell began in the conducted intervreportedly good. monitoring data when the major BSome specific radata. There were C-Cells. The soil be contaminated verify whether thincluding those dCell leaks, were data that exist cafavorable assumpincident-related d
Hanford SEC Issues Matrix – Draft Preliminary SC&A Assessment 

References 

ORAUT 2010a. Hanford Site – Introduction, ORAUT-TKBS-0006-1, Rev. 04, Oak Ridge 

Associated Universities, Cincinnati, Ohio. March 2010. 

ORAUT 2010b. Hanford Site – Site Description, ORAUT-TKBS-0006-2, Rev. 02, Oak Ridge 

Associated Universities, Cincinnati, Ohio. February 2010. 

ORAUT 2010c. Hanford Site – Occupational Medical Dose, ORAUT-TKBS-0006-3, Rev. 02, 

Oak Ridge Associated Universities, Cincinnati, Ohio. January 2010. 

ORAUT 2010d. Hanford Site – Occupational Environmental Dose, ORAUT-TKBS-0006-4, 

Rev. 03, Oak Ridge Associated Universities, Cincinnati, Ohio. January 2010. 

ORAUT 2010e. Hanford Site – Occupational Internal Dose, ORAUT-TKBS-0006-5, Rev. 3, 

Oak Ridge Associated Universities, Cincinnati, Ohio. January 2010. 

ORAUT 2010f. Hanford Site – Occupational External Dose, ORAUT-TKBS-0006-6, Rev. 04, 

Oak Ridge Associated Universities, Cincinnati, Ohio. January 2010. 

SCA 2009. Remaining Hanford SEC Issues for SEC Petition SEC-00057-2 and Petition SEC00152: Draft Matrix Issues Update, S. Cohen & Associates, Vienna, Virginia. November 2, 

2009. 

Draft Hanford SEC Issues Matrix Page 10 of 10 SC&A – Updated August 19, 2011 

NOTICE: This August 19, 2011, version of the Hanford Site SEC Issues Matrix has been reviewed for Privacy Act 

information and has been cleared for distribution. However, as this is a “living” document that is continually 

changing, later versions will require additional reviews before being made available to the public.