Draft

Advisory Board on Radiation and Worker Health

National Institute for Occupational Safety and Health

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant 

Contract No. 75D30119C04183

Document No. SCA-TR-2023-SEC001, Revision 0

Prepared by

Stephen L. Ostrow, PhD

Nicole Briggs 

Ron Buchanan, PhD, CHP

Rose Gogliotti, MS

SC&A, Inc.

2200 Wilson Blvd., Suite 300

Arlington, VA 22201-3324

June 16, 2023 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for 

Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker 

Health (ABRWH), including its Working Groups or Subcommittees. Documents produced by 

SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or 

ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected 

by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 
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SC&A, Inc. technical support for the Advisory Board on Radiation and Worker Health’s 

review of NIOSH dose reconstruction program

Document title Interim SC&A Review of the SEC Petition Evaluation Report for Petition 

SEC-00256: Pinellas Plant

Document number SCA-TR-2023-SEC001

Revision number 0 (Draft)

Supersedes NA

Effective date June 16, 2023 

Task manager Stephen L. Ostrow, PhD [signature on file]

Project manager Bob Barton, CHP [signature on file]

Document reviewer(s) Bob Barton, CHP [signature on file]

Record of revisions

Revision number Effective date Description of revision

0 (Draft) 6/16/2023 Initial issue
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Table of Contents

List of Tables................................................................................................................... 4

List of Figures.................................................................................................................. 4

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

1 Executive Summary.................................................................................................. 8

2 Introduction and Background.................................................................................. 13

2.1 Site information ................................................................................................ 14

2.2 History of Board activities................................................................................. 15

3 Sources of Exposure .............................................................................................. 17

3.1 Radiation sources ............................................................................................ 17

3.2 External exposures .......................................................................................... 21

3.3 Internal exposures............................................................................................ 23

4 Radiation Monitoring............................................................................................... 32

4.1 Monitoring during the SEC period 1957–1990 ................................................. 32

4.2 Period of SEC evaluation excluded from SEC petition, 1991–1997................. 33

4.3 Internal monitoring records .............................................................................. 33

4.4 Additional Tiger Team findings about internal dosimetry.................................. 38

4.5 External monitoring .......................................................................................... 40

5 Interviews, Incidents, and Other Information Associated with Claimants and/or 

Former Workers...................................................................................................... 41

5.1 Computer-aided telephone interview information............................................. 41

5.2 Previously reviewed Pinellas dose reconstruction cases ................................. 41

5.3 Recordkeeping procedures .............................................................................. 43

5.4 Documented communications with former workers.......................................... 43

6 Petitioner Concerns ................................................................................................ 44

6.1 SC&A summary of petitioner concerns ............................................................ 44

6.2 NIOSH response and SC&A review comments................................................ 45

6.3 Additional petitioner concerns submitted following the December 2022 Board 

meeting............................................................................................................ 56

7 References ............................................................................................................. 61

Appendix A: DOE Tiger Team Report ........................................................................... 68

Appendix B: Radiological Incidents ............................................................................... 74

Appendix C: Former Worker Interview Notes ................................................................ 85
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List of Tables

Table 1. Summary of Advisory Board meetings and activities....................................... 15

Table 2. Pinellas claimants with tritium results .............................................................. 34

Table 3. Summary of Pinellas internal monitoring data for tritium 1986–1995 .............. 37

Table 4. Summary of Pinellas external monitoring data for 1985–1995 ........................ 40

Table 5. Comparison of monitoring records used in DR vs CATI reported monitoring 

history in previously reviewed cases ............................................................................. 42

Table B-1. Radiological incidents at Pinellas Plant ....................................................... 74

Table C-1. Summary of interview notes with former workers ........................................ 85

List of Figures

Figure 1. Number of different types of different products produced per year ................ 19

Figure 2. Number of units of different products shipped per year.................................. 20

Figure 3. Comparison of tritium bioassays as a fraction of annual total ........................ 35

Figure 4. Comparison of tritium bioassays as annual counts ........................................ 36

Figure 5. Comparison of tritium onsite to bioassayed individuals.................................. 37
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Abbreviations and Acronyms

ABRWH, Board Advisory Board on Radiation and Worker Health 

a.k.a. also known as 

ALARA as low as reasonably achievable 

ANL Argonne National Laboratory 

AWLPG Albuquerque Workload Planning Guide 

C carbon

°C degrees Celsius

CATI computer-assisted telephone interview

CDC Centers for Disease Control and Prevention 

Ci curie

CFR Code of Federal Regulations 

Co cobalt

CY calendar year

DCAS Division of Compensation Analysis and Support 

DD deuterium-deuterium fusion reaction 

DFO Designated Federal Official

DI deionized

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

DOL DEEOIC SEM DOL Division of Energy Employees Occupational Illness & 

Compensation Site Exposure Matrix 

dpm, DPM disintegrations per minute 

DR dose reconstruction 

DT deuterium-tritium fusion reaction

ECL Environmental Chemistry Laboratory 

EE energy employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

EHS environmental health and safety

EH&SP Environmental Health and Safety Program 

EPA U.S. Environmental Protection Agency 

ER evaluation report 
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g grams 

GE General Electric

GEND General Electric Neutron Devices

GENDD General Electric Neutron Devices Department

GEPP General Electric Pinellas Plant

H hydrogen 

GEXF General Electric X-Ray Division Florida 

HP Hewlett Packard, Health Physicist, or Health Physics (department) 

HRS Dept. of Health and Rehabilitative Services (Florida)

HTO tritium oxide

IH industrial hygiene 

IMBA Integrated Modules for Bioassay Analysis 

keV kiloelectron volt 

Kr krypton 

LAT lateral (x-ray)

mCi millicurie

μCi microcurie

μCi/L microcurie per liter

MDC minimum detectable concentration

MeV mega-electron volt 

mg/cm2 milligram per square centimeter

mrem millirem

NA not applicable 

NESHAP National Emission Standards for Hazardous Air Pollutants 

ng/ml nanograms per milliliter

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH DCAS Claims Tracking System

NRC Nuclear Regulatory Commission 

O oxygen 

OBT organically bound tritium 

ORAUT Oak Ridge Associated Universities Team

oz ounces 

PA posterior-anterior 
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PFG photofluorography 

Pinellas Pinellas Plant

POTW (Cross Bayou) Publicly Owned Treatment Works 

Pu plutonium 

Pu-238O2, 238PuO2 plutonium-238 dioxide 

RMMA Radioactive Materials Management Area

RTG radioisotope thermoelectric generator

SEC Special Exposure Cohort 

SECS Stack Effluent Control System 

SMT stable metal tritide

SNL Sandia National Laboratories

SPR Subcommittee for Procedure Reviews

Sr strontium 

SRDB Site Research Database

STC special tritium compound 

TBD technical basis document

TIB technical information bulletin

Tl thallium

TLD thermoluminescent dosimeter

TRS tritium recovery system

U uranium 

UNC University of North Carolina at Chapel Hill

WG work group 
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1 Executive Summary

The initial Special Exposure Cohort (SEC) Petition-00256 for the Pinellas Plant (Pinellas) was 

submitted to the National Institute for Occupational Safety and Health (NIOSH) on 

December 16, 2019 ([Redacted], 2019). The petitioners subsequently revised the class definition 

twice, on May 20, 2020 ([Redacted], 2020a), and on August 17, 2020 ([Redacted], 2020b). 

NIOSH qualified the latter petition for evaluation on October 20, 2020, and also modified the 

proposed class definition. NIOSH completed the SEC petition evaluation report (“ER” or 

“NIOSH SEC ER”) (NIOSH, 2021a) on October 13, 2021. At its December 8, 2021, meeting

(ABRWH, 2021b), the Advisory Board on Radiation and Worker Health (ABRWH, Board) 

requested that SC&A review the ER; this report is provided to the Board in response to this

request.

SC&A recognizes that several new issues have recently been raised by the petitioners that may 

have SEC implications (e.g., potential uranium glass blowing operations) and that documents 

found in recent data captures have not yet been reviewed. However, SC&A is releasing this 

interim draft to inform the Board and to facilitate moving discussions forward. 

The ER concludes that doses experienced by the workers covered by the SEC petition can be 

reconstructed with sufficient accuracy in accordance with 42 CFR 83.13(c)(1) (“Is it feasible to 

estimate the level of radiation doses of individual members of the class with sufficient 

accuracy?”) and recommends denying the petition. This recommendation is based on data, 

methods, assumptions, and other sources of information described in the ER. 

SC&A’s review of the ER has two objectives: 

1. Provide information for use by the Board in determining whether doses can be 

reconstructed with sufficient accuracy, as defined in 42 CFR Part 83, “Procedures for 

Designating Classes of Employees as Members of the Special Exposure Cohort Under the 

Energy Employees Occupational Illness Compensation Program Act of 2000.” 

2. Provide a technical evaluation of the scenarios, data, assumptions, models, and other 

information given or referenced in the ER for reconstructing doses. 

From the evidence that it has examined, SC&A believes, with some caveats, that it may be 

possible to bound doses to workers covered by the SEC petition, in a scientifically sound and 

claimant-favorable manner, by application of the methodologies and data outlined in the ER and 

contained in supporting documents referenced in the ER or otherwise found by SC&A in the 

NIOSH Site Research Database (SRDB). These methods include, but are not limited to, use of 

one of the highest contamination survey measurements to reconstruct stable metal tritides 

(SMTs).

However, SC&A notes that it has yet to be demonstrated that a suitable co-exposure model can 

be developed for other soluble tritium compounds. This may be particularly problematic in light 

of the U.S. Department of Energy (DOE) Tiger Team findings noting noncompliance with the 

site bioassay program. Mitigating factors such as the comments made by the same Tiger Team 

commending the site for its radiation protection program, as well as generally low doses, may 
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inform whether such a co-exposure can be acceptably developed (refer to section 4.4 and 

appendix A for a detailed account of the Tiger Team review). 

This SC&A review summarizes Pinellas Plant history and site information, discusses the 

radiation sources and types of radiation that might have exposed personnel, and examines

radiation monitoring procedures and compliance both pre- and post-issuance of the 1990 DOE 

Tiger Team report (DOE, 1990a). It also evaluates whether the ER (1) adequately recognizes and 

addresses all petitioner concerns as articulated in the petition, computer-assisted telephone 

interview (CATI) reports, and subsequent petitioner communications to the Board and 

(2) accounts for all relevant reported radiological incidents at the plant. 

The Board will use this information, in part, as a basis for determining whether it finds that doses 

can be reconstructed with sufficient accuracy for the SEC class. SC&A has a few reservations it 

recommends the Board also consider, centered around compliance with bioassay program 

requirements before the Tiger Team assessment in 1990, which are summarized in 

observations 2, 4, 5, 7, and 9. 

While SC&A’s review had no findings, it made the following 13 observations, which may reflect

either unfavorably or favorably or provide noteworthy information on the radiation-related 

conditions and practices at Pinellas and the conclusions of the ER. 

Observation 1: Neutron generator production was fairly steady

SC&A’s review of neutron generator production from 1974 through 1993 showed that it was

fairly steady, with a peak in the early 1980s and a few notable dips in the late 1970s into 1980. 

(section 3.1) 

Observation 2: Potential for tritium contamination is adequately addressed

SC&A notes that key aspect 4 of the accepted NIOSH stable metal tritide model indicates that 

stable metal tritide exposures would only be applied if the energy employee were also monitored 

via urinalysis. However, given the deficiencies noted by the Tiger Team in the performance of 

the bioassay program as late as 1990, relying on bioassay completeness to establish exposure 

potential is likely inappropriate. (section 3.3.1) 

Observation 3: The ER does not reference recent special tritium compound document

The SEC evaluation report and ORAUT-TKBS-0029-5, revision 03 (the occupational internal 

dose technical basis document (TBD)), do not incorporate guidance for performing dose 

reconstruction for intakes of stable metal tritides from revision 01 of ORAUT-OTIB-0066 

(2020). NIOSH should commit to reference and discuss guidance from OTIB-0066 in the next 

revision of the occupational internal dose TBD and evaluate whether it has any consequential 

effect on the SEC evaluation report conclusions. In addition, as noted in key aspect 2 of the 

stable metal tritide model accepted by the Board (as presented by SC&A at the August 9–10, 

2016, Board meeting), sitewide air monitoring data or contamination survey data should be 

preferentially used over other modeling in dose reconstructions for stable metal tritides whenever 

available. (section 3.3.1) 

Observation 4: Lack of bioassays records for 1988–1990

Despite between 129 and 201 employees reportedly monitored by bioassays from 1988 to 1990, 

NIOSH only has monitoring records for 3–10 claimants per year. According to the 1990 DOE 
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Tiger Team report, approximately 1,750 people were employed in 1989, suggesting that 

monitoring records are missing. (section 4.3) 

Observation 5: Bioassay schedule noncompliance by the plant

One of the principal Tiger Team findings relevant to the SEC petition was noncompliance with 

the plant’s own requirements for termination, monthly, and weekly bioassays. Appropriate 

bioassay compliance (data completeness levels) in general is a subjective judgment to be made 

by the Board. In addition, the level of compliance with the bioassay program is unknown before 

the findings of the Tiger Team. It is SC&A’s opinion that at a minimum, NIOSH should 

demonstrate that an appropriate co-exposure model can be constructed to address apparent 

incompleteness in the tritium bioassay program (likely throughout its relevant operating history). 

Despite concerted efforts by the site to rectify the compliance issues, nearly one-fifth of worker 

bioassay requirements were still not met. Bounding co-exposure values would certainly appear 

warranted during this latter period (1991–1997). (section 4.3) 

The following five additional observations (6 through 10) are taken from SC&A’s review of the 

1990 DOE Tiger Team report (DOE, 1990a) (refer to section 4.4 of this SC&A review). 

Observation 6: Radiological protection program commended by Tiger Team

On a positive note, commending the radiological protection program, section 4.4.11.1 (p. 4-90) 

of the 1990 DOE Tiger Team report states, “The overall assessment is that all levels of the 

GEND [General Electric Neutron Devices, another name for the Pinellas Plant] organization are 

receiving adequate radiological protection. This is primarily due to a GEND staff that appears 

willing to accept line responsibility for radiological safety along with a technically strong health 

physics staff providing direction.” 

Observation 7: Bioassay sampling frequency requirements not followed as noted by 

Tiger Team

Section 4.5.11.1 (p. 4-90) of the 1990 DOE Tiger Team report compliments the plant for 

maintaining low overall internal dose exposures but also makes an important finding on 

noncompliance issues related to the plant not following bioassay sampling frequency 

requirements. This is one of the bases cited in the SEC petition: “Occupational internal 

exposures are low compared to other DOE sites. This accomplishment results from a 

conservative approach to working with tritium and through extensive use of engineering 

controls. However, compliance with the rules on providing bioassay samples at specified 

frequencies has not been satisfactory.” 

Observation 8: Contamination controls found generally good by Tiger Team

Section 4.5.11.1 (p. 4-91) of the 1990 DOE Tiger Team report discusses the effectiveness of 

contamination controls at Pinellas and notes that while it is generally good, there are instances 

when it is not: “Contamination controls are generally good. Contamination levels within the 

work areas are kept low and generally confined to the source. Indications were found that proper 

contamination control techniques are not always being followed, in some areas causing 

contamination spread to the general areas of the facility.”

Section 4.5.11.2 (p. 4-101) continues the discussion of contamination controls with a negative 

statement: “Proper contamination control techniques are not being followed by personnel when 

working in and exiting from Contaminated Areas.” The report (p. 4-102) notes that a contractor 
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disagreed that workers were inadequately protected given the extremely low contamination 

levels detected and that “radiation exposures from these contamination levels are not measurable, 

as supported by bioassay sampling.” 

Observation 9: Bioassay sampling program implementation inadequacies noted by the 

Tiger Team

Section 4.5.11.2 (p. 4-98 ff.) of the 1990 DOE Tiger Team report contains several radiological 

protection findings and concerns related to internal dosimetry that are relevant here. Of particular 

importance, finding RP.7 (p. 4-98) claims that “Procedural requirements have not been 

established for an employee’s termination bioassay, nor a system developed to identify and 

address those individuals who fail to provide a bioassay sample.” Additionally, “GEND 

estimated that 20 percent of the personnel that terminated in 1988 did not provide a termination 

bioassay,” and that “Individual workers, their supervisors, and management are not ensuring that 

required bioassay samples are provided. In 1989, bioassay samples were not submitted in 

accordance with GEND procedures. Seventy percent of the required monthly samples and 

35 percent of the required weekly samples were not submitted.” NIOSH cited these Tiger Team 

findings as sufficient to qualify the SEC petition for further evaluation. 

Observation 10: Tiger Team assessment of deficiency root causes: emphasis on 

production and mindset that Pinellas poses no unusual radiological risks

Section 5.7 (p. 5-33) of the 1990 DOE Tiger Team report covers management assessments. It

opines the following on the probable root causes of some of its deficiency findings and lists the 

following two: “First, emphasis on production has traditionally overshadowed interest in fully 

complying with environment, safety and health requirements”; and “Second, there is a wideset 

mindset that the Pinellas Plant poses no unusual or unique risks.” 

Observation 11: Transition Year of 1990 after Tiger Team assessment led to overall 

reduced exposures

The Tiger Team assessment took place in January and February 1990, and the Pinellas Plant 

initiated corrective action during fiscal year 1990 (October 1, 1989, through September 30, 

1990). While data indicate a significant decrease for external doses from 1990 to 1991, there was

an increase in internal doses from tritium from 1990 to 1991, then a gradual decreasing trend 

during the years 1992–1995. The number of workers bioassayed for tritium remained reasonably 

consistent during the period 1986–1995, and the number of workers monitored for external 

exposure gradually decreased during the period 1985–1995. According to the “1991 Annual 

ALARA Program Report for Ionizing Radiation,” the increase in internal dose was due to the 

“T” box incident and recovery operations in Area 182C conducted in late December 1991. To 

date, SC&A has not found indications that there are issues with exposure records that would 

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

(section 4.5) 

Observation 12: ER is consistent with interview records

SC&A reviewed all available documented communication (i.e., interview) records. The 

interviews reflect the full date range of work at Pinellas and encompass a broad range of 

professions. From the interviews, it is clear that site employees had a different experience with 

the health and safety policies at the site based on their role and job function. In general, the 

interviewed workers in physics, engineering, chemistry, and lab-related professions had 
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experience with the site internal and external monitoring program. The recollections reported in 

the interviews, in general, are consistent with the NIOSH SEC evaluation report. (section 5.4) 

Observation 13: Pinellas plant diligent in following up on contamination-related incidents 

and personnel exposures

Based on its review of the available incident information, SC&A concurs with NIOSH’s 

conclusion that Pinellas Plant was diligent about following up on contamination-related incidents 

and personnel exposures. The reports show investigations into the causes of various incidents, 

and most (1) indicate that followup monitoring was performed for employees involved in the 

incidents and (2) provide recommendations to prevent the incidents from reoccurring. However, 

given the lack of bioassay records for the years 1988–1990 described in observation 4 

(section 4.3) and the issues surrounding bioassay noncompliance described in observation 5 

(section 4.3), observation 7 (section 4.4), and observation 9 (section 4.4), it is possible that the 

program may not have captured all the internal exposures related to contamination incidents. 

(section 6.2.2) 
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2 Introduction and Background

The revised SEC petition, submitted to NIOSH on August 17, 2020 ([Redacted], 2020b, p. 4), 

proposed, in part, the following class definition: 

Employees of the Department of Energy (DOE), DOE contractors and/or 

subcontractors who were employed by General Electric Neutron Devices 

including all names of the company listed in Part C, Martin Marietta Specialty 

Components, and/or Lockheed Martin Specialty Components, Inc. (a.k.a. the 

Pinellas Plant) during the period from January 1957 through December 1997. 

NIOSH reviewed the petition and supporting information and determined that the petition 

qualified for evaluation under the F.4 basis (i.e., scientific or technical report issued by a 

government agency or peer reviewed journal that identifies dosimetry information is 

unavailable). The petitioners had quoted from the 1990 DOE Tiger Team report on Pinellas 

(DOE, 1990a) in support of their petition, and, after review of the report, NIOSH found it

provided sufficient information to allow the petition to qualify for further evaluation. Per

section 3.1 of the NIOSH SEC ER (NIOSH, 2021a, p. 20): 

The [Tiger Team] report states “... compliance with the rule on providing bioassay 

samples at specified frequencies has not been satisfactory” (DOE 1990a, PDF 

p. 216) and “... In 1989, bioassay samples were not submitted in accordance with 

GEND [General Electric Neutron Devices] procedures. Seventy percent of the 

required monthly samples were not submitted” [DOE 1990a, PDF p. 224]. 

NIOSH expanded upon this in its December 8, 2021, presentation to the Board (NIOSH, 2021b, 

slide 13), where it deemed the following two statements from the Tiger Team report sufficient to 

qualify for an SEC evaluation (section 4.4 and appendix A of this SC&A review discuss the 

Tiger Team observations and findings): 

• “GEND estimated that 20 percent of the personnel that terminated in 1988 

did not provide a termination bioassay.” [DOE 1990a, PDF p. 224] 

• “Seventy percent of the required monthly samples and 35% of the required 

weekly samples were not submitted.” [DOE 1990a, PDF p. 224] 

Since the 1990 Tiger Team report assessed plant conditions in 1988 and 1989, NIOSH 

determined that it was not directly applicable to the time period that followed it because Pinellas 

had adequately and promptly addressed the bioassay compliance issues raised in the report by the 

end of 1990. Consequently, NIOSH terminated the SEC class definition period on December 31, 

1990, rather than on December 31, 1997, as proposed in the petition. This truncated cutoff date is 

discussed further in section 4.2 of this SC&A review. However, SC&A notes that the Tiger 

Team finding of noncompliance may be applicable to the period preceding the Tiger Team’s 

review (refer to section 4.1 of this report). 

NIOSH (2021a, p. 20) qualified the final revised petition for evaluation on October 20, 2020, but 

modified the class definition to: 
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All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Pinellas Plant in Clearwater, 

Florida for the period from January 1, 1957 through December 31, 1990. 

NIOSH submitted its SEC ER on October 13, 2021 (NIOSH, 2021a), and presented it to the 

ABRWH at its December 8, 2021 (NIOSH, 2021b), meeting. 

The NIOSH SEC ER concludes the following about the Pinellas facility:

NIOSH concludes that it has access to sufficient information to estimate the 

maximum radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could be incurred in plausible circumstances by any member of 

the class under evaluation. Therefore, NIOSH does not recommend adding the 

NIOSH-evaluated class to the SEC. [NIOSH, 2021a, p. 21] 

Following discussions of the NIOSH SEC ER at the December 8, 2021, ABRWH meeting, the 

Board tasked SC&A with reviewing it. This review report presents the results of SC&A’s 

investigation. 

Since the NIOSH SEC ER and SC&A’s review rely, in part, on the information in the technical 

basis documents (TBDs) comprising the site profile, a brief summary of the history and status of 

the site profile is in order. SC&A had reviewed the original site profile TBDs produced by 

NIOSH in 2005 and 2006 (ORAUT, 2005a, 2005b, 2005c, 2005d, 2005e, 2006) and submitted 

its assessment to the Board in 2006 (SC&A, 2006). That assessment identified 11 primary and 

eight secondary issues. 

Responding to SC&A’s assessment and several technical exchanges between NIOSH, SC&A, 

and the Board’s Pinellas Plant Work Group (WG), NIOSH revised the TBDs beginning in 2011 

(ORAUT, 2011a, 2011b, 2011c, 2011d, 2016, 2017). After further reviews and discussions, 

SC&A presented the final status of the issues at the August 9, 2016, Board meeting (SC&A, 

2016b) and stated that “SC&A and the Pinellas Work Group agree that all of the primary and 

secondary issues raised in SC&A’s site profile review have been adequately addressed and 

resolved” (slide 3). However, “Primary Issue 2” concerning stable metal tritides was “in 

abeyance until NIOSH delivers a revision of the internal dose TBD” (SC&A, 2016b, slide 3), 

which is still pending. (Section 3.3.1 of this review discusses the issue of SMTs in detail.) The 

result of these TBD discussions is that the basis for many of NIOSH’s assertions and methods in 

the SEC ER have already been reviewed and approved by both SC&A and the Board through the 

site profile review process and, therefore, have not been revisited here in great depth. 

2.1 Site information

Information on the Pinellas Plant is found in the current site profile TBDs (ORAUT, 2011a, 

2011b, 2011c, 2011d, 2016, 2017). Details of the history, building and equipment layout, 

manufacturing and other processes, radioactive source types and locations, and potential for 

personnel exposure are primarily in the site description TBD, ORAUT-TKBS-0029-2, 

revision 02 (ORAUT, 2011b), with parts repeated as appropriate in the other TBDs. 
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The plant, located on a 100-acre site in Clearwater, FL, was constructed in 1956 by the General 

Electric Company to manufacture neutron generators for the U.S. nuclear weapons program and 

expanded after 10 years of operation to include other specialized electronic and support 

components. Prominent among them from a radiological standpoint were radioisotope 

thermoelectric generators (RTGs). There was one large building, Building 100, which contained 

many areas designated for manufacturing, engineering, and administrative functions, and 17 

smaller, surrounding buildings and structures. Figure 5-1 of the ER shows a Pinellas Plant site 

map for reference. At peak operations, the plant employed approximately 2,000 people 

(GENDD, 1986).1

 The plant operated from 1957 through September 1994, with subsequent 

decontamination and decommissioning activities from October 1994 through 1997 and 

remediation activities in 1999, 2008, and 2009. Pope (2007) provides further information on the 

plant’s closing, which was prompted by DOE’s efforts in the late 1980s to reduce its overall 

budget by closing several Nuclear Weapons Complex plants and transferring their essential

functions to other plants. As part of that process, fabrication of neutron generators passed from 

Pinellas to Sandia National Laboratories (SNL). 

1 Table 6-8 of ORAUT-TKBS-0029-6, revision 02 (ORAUT, 2017), shows Pinellas employees per year for 1960–

1973 ranging from about 1,300 to 1,600, peaking at 1,597 in 1963. The total number of employees for years 1974–

1985 are listed as “not available.” However, GENDD (1986) states that the maximum was about 2,000 but does not 

give the corresponding year or basis for its statement. 

Over the plant’s long history, Pinellas has gone by many names, including, but not limited to, the 

908 Plant, GE X-ray Division Florida (GEXF), GE Neutron Devices Department (GENDD), GE 

Neutron Devices (GEND), GE Pinellas Plant (GEPP), General Electric Temporary Plant, GE 

Aerospace Neutron Generators, and Pinellas Peninsula Plant. These names occur throughout the 

literature and employee statements but are generally understood to refer to the same facility. 

Throughout this review, the plant is referred to as Pinellas, the Pinellas Plant, or the plant.

2.2 History of Board activities 

Table 1 summarizes the long history of Board activities, beginning in 2004, concerning Pinellas. 

Additionally, current evidence suggests that NIOSH conducted interviews with at least 16 former 

workers and/or subject matter experts in November 2007, 2013, 2020, and 2021. 

Table 1. Summary of Advisory Board meetings and activities

Meeting date Meeting group/purpose

September 2, 2004 NIOSH worker outreach

November 2, 2005 NIOSH worker outreach

May 27–29, 2006 SC&A conducted worker interviews

February 28–29, 2008 NIOSH outreach on SEC petitioning process

June 11, 2008 Work Group on Pinellas Plant

June 11, 2009 Work Group on Pinellas Plant

October 13, 2011 Work Group on Pinellas Plant

November 19, 2012 Work Group on Pinellas Plant

February 11, 2016 Work Group on Pinellas Plant

March 10, 2016 Work Group on Pinellas Plant
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Meeting date Meeting group/purpose

March 23, 2016 ABRWH meeting, SC&A status report

August 9, 2016 ABRWH meeting, SC&A final status report

December 8, 2021 ABRWH Meeting, NIOSH SEC presentation

December 8, 2022 ABRWH Meeting, SC&A ER review update presentation
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3 Sources of Exposure

The ER draws from the Pinellas site description TBD (ORAUT, 2011b), documents referenced 

therein, and other documents, such as those found in data capture activities, to describe the 

sources of radiation at the plant that might have exposed personnel through various pathways. 

The following sections discuss radiation sources and potential internal and external exposure 

sources. 

3.1 Radiation sources

Section 2.4 of the Pinellas site description TBD (ORAUT, 2011b), which is echoed in the ER, 

discusses the radiation sources at the plant and categorizes them as either radioactive materials 

that continuously emit radiation through radioactive decay, or radiation-generating devices that 

produce radiation only when they are operating. In the radioactive materials category, the TBD 

lists several products containing radionuclides, such as: 

• miniature linear accelerator-type neutron generators (containing tritium targets) used to 

initiate nuclear fission reactions 

• RTGs containing plutonium oxide heat sources that arrived at the plant as triply 

encapsulated units 

• borosilicate glass structures containing uranium 

• leak-testing systems containing krypton (Kr)-85 

• tritium storage systems

• instrumentation and dosimeter calibration and check sources

• analytical standards for laboratory analyses

The TBD asserts that, “With the exception of radionuclides used as analytical standards, tritium 

(

3

H), 14C [carbon-14], and 85Kr [krypton-85] were the only dispersible radionuclides normally 

encountered at the Pinellas Plant. All other radionuclides at the Plant were in nondispersible 

forms (plated sources, containerized sources, encapsulated sources, solid metal sources, etc.)” 

(ORAUT, 2011b, p. 14).

Tritium (a low-energy beta emitter with 5.7 kiloelectron volt (keV) average energy, 18.5 keV 

maximum energy, and a 12.32-year half-life) appeared at Pinellas in four forms: tritiated water 

(tritium oxide or HTO), tritium gas, organically bound tritium (OBT), and metal tritides.2

2 A note on nomenclature: Metal tritides also go by alternate names, including stable metal tritides (SMTs),

insoluble metal tritides, and insoluble tritium compounds; it is assumed here that all refer to the same forms. 

Plutonium (Pu) (as Pu-238, 87.7-year half-life, and Pu-239, 24,110 year half-life) is an alpha and 

x-ray emitter but may also produce neutrons and gamma rays from spontaneous fission. 

Plutonium fission products, in turn, also emit radiation as they decay. Kr-85 (10.756-year halflife) is a beta-emitting noble gas. Natural and depleted uranium isotopes were also present. The 

uranium (U) isotopes (U-234, U-235, and U-238) emit alpha particles and x-rays when they 

undergo radioactive decay, and some of their decay chain progeny also emit alpha and beta
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particles and gamma rays as they, in turn, decay. The depleted uranium (lower U-235 isotopic 

percentage than in natural uranium), in a containerized configuration, was primarily used to store 

tritium in storage beds (depleted uranium hydrogen getter). Natural uranium was used as a 

dopant in borosilicate glass structures that were received by the Pinellas Plant in a sealed form. 

Nickel-63 (101-year half-life), used in krytrons (sealed, gas-filled glass tubes that were used as 

very high-speed switches in nuclear weapons), is a beta emitter. C-14 (5,730-year half-life) is a 

beta-emitting radionuclide, used in small amounts in the plant as a radioactive label in some 

laboratory solvents.3

3 ORAUT (2011b) notes that “A 1983 environmental assessment indicated that small quantities of 14C labeled 

solvents were used in a laboratory testing operation (DOE 1983). No other documentation was found to indicate 

other uses of 14C” (p. 16).

In addition to the radioactive materials, which always emit radiation, certain devices also 

generated radiation only when they were operating. The primary product of the plant was 

neutron generators (containing very small linear accelerators enclosed in vacuum tubes) used in 

the triggering mechanism of nuclear weapons, which accelerate deuterons into either a tritium 

target or deuterium target resulting in the emission of either 14 mega-electron volts (MeV) or 

2.5 MeV neutrons, respectively, from the nuclear fusion reactions. Ion accelerators were used for 

ion implantation and target assessment, materials analysis, and other purposes. Table 2-1 of the 

Pinellas site description TBD (ORAUT, 2011b) lists radiation-generating devices with their 

quantities and types. Finally, the plant conducted onsite personnel occupational medical x-ray 

examinations. 

SC&A thought it valuable to examine production of radioactive source-containing materials or 

radiation-producing devices over time in the Pinellas Plant to both understand the magnitude of 

the operations and find out if reported measured dose values correlate with production. 

Section 2.6.1 of the site description TBD (ORAUT, 2011b) notes that Area 108 of Building 100 

handled the most tritium at Pinellas, and that “Overall tritium use at Pinellas was generally low, 

with an average yearly inventory of approximately 15 g (0.53 oz)”; this is equivalent to about 

144,600 curies (Ci) activity. 

To date, SC&A found only one document, “Pinellas Plant Overview” (DOL, c19944

), that 

contains some of the desired information related to device production. It presents some relevant 

information in two unnumbered charts, both titled “Pinellas Plant Products.” The data in the 

charts are “based on 1989 AWLPG”; SC&A determined that this acronym stands for 

“Albuquerque Workload Planning Guide.” The first chart (reproduced here as figure 1) 

compares, in stacked bar format, the number of types produced per year of 10 different products 

for fiscal years 1974 through 1993. The second chart (reproduced here as figure 2) displays in a 

similar format the number of shipped units by year for each of the products. Two products of 

interest to this analysis are neutron generators (“Generators”), which contain tritium and produce 

neutrons and associated radiation, and RTGs, which contain plutonium. 

4 The U.S. Department of Labor (DOL) presentation is undated, but since the last year of the charts is 1993, 

SC&A assumes that the presentation was prepared soon thereafter.
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Figure 1. Number of different types of different products produced per year

Source: DOL (c1994). 
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Figure 2. Number of units of different products shipped per year

Source: DOL (c1994). 

It is not feasible to read actual numbers from the charts, but some trends can be discerned. 

Neutron generator production was ongoing at the start of the chart in 1974, with about 20 

different types and about 8,000 shipped, and ending in 1993 (the plant ceased operations in 

1994) with 15 different types produced and 2,000 shipped. The trend in number of different 

types by year is fairly steady, with some dips in the late 1970s and 1980. The trend in number 

shipped is as high as over 10,000 units in 1983 and as low as about 1,000 units in several years, 

particularly from 1987 through 1993. 

It is not clear from the available copy of the presentation which of the colored stacks represents 

RTGs, since several products were given similar reddish colors, but, assuming the stacks are 

ordered in the same way as the 10 different products listed with corresponding colors in the 

legends above the charts, RTGs would be the fifth up from the bottom of each bar (neutron 

generators would be the lowest). The number of different types of RTGs appears to be no more 

than a few throughout all the years. SC&A could not draw any definitive conclusions about the 

amount shipped per year on that chart since not all of the reddish-colored bars appear each year. 

Therefore, SC&A has one observation about neutron generator production. 

Observation 1: Neutron generator production was fairly steady

SC&A’s review of neutron generator production from 1974 through 1993 showed that it was

fairly steady, with a peak in the early 1980s and a few notable dips in the late 1970s into 1980. 
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3.2 External exposures

Section 5.3 of the ER addresses external radiation exposure sources at the Pinellas Plant. This 

information also appears in the occupational external dose TBD, ORAUT-TKBS-0029-6, 

revision 02 (ORAUT, 2017), which was reviewed by SC&A and the Pinellas WG with all issues 

resolved (refer to section 2 of this report). ER section 5.3 begins by summarizing what NIOSH 

considers to be the potential for external occupational exposures: 

The activities with a potential for external radiation exposure at the Pinellas Plant 

included testing the neutron tubes and neutron generators, working near the 

plutonium oxide heat sources, using other radiation-generating devices, and in 

rare instances, external exposure to Kr-85 gas leaks. The radiological materials 

with potential for external exposure included Kr-85, carbon-14, and plutonium. 

The depleted uranium used in the tritium storage beds presented no significant 

external radiation hazard due to the low specific-activity and the non-penetrating 

radiation emitted. [NIOSH, 2021a, p. 37] 

Other radionuclides were also present at Pinellas, but they were mostly sealed check sources and 

other low-activity sources that would not make significant contributions to sitewide external 

dose. The introductory paragraph of ER section 5.3 concludes: 

While radioactive materials and radiation-generating devices were necessary to 

the product manufacturing, the majority of the work performed at the Pinellas 

Plant did not involve exposures to external sources of radiation. This lack of 

external radiation exposure potential is why the Pinellas Plant did not 

monitor many workers for external doses. [NIOSH, 2021a, p. 37; emphasis 

added] 

The last sentence of this quotation is the primary justification given for more workers not being 

monitored for external radiation. The following subsections discuss the different types and 

sources of external radiation considered in the ER: photon, beta (electron), and neutron. 

3.2.1 Photon radiation

Section 5.3.1 of the ER discusses potential photon exposure sources in several plant areas: 

• Neutron Generator Production Areas: The main source of photon exposure would have 

been from testing neutron tubes and neutron generators. 

• RTG Production Areas: According to a 1991 as low as reasonably achievable (ALARA) 

report for 1990 (Harder, 1991, p. 1), the plutonium-238 dioxide (Pu-238O2 or 238PuO2) 

heat sources produced gamma radiation that amounted to an estimated 67 percent of the 

plant’s photon dose in 1990. 

• Ion Implanter Accelerator: This Model 200 Hewlett Packard (HP accelerator was 

originally installed in the Chemistry Laboratory in Building 100 (the main production 

building), then relocated to Building 800. 
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3.2.2 Beta radiation

Section 5.3.2 of the ER discusses potential external exposures from beta (electron) radiation. It 

notes that the principal source of this radiation was from tritium but does not find it a significant 

radiation hazard due to the low energy of its beta particle (5.7 keV average and 18.5 keV 

maximum energy), which would not allow it to penetrate the top layer of the skin. The ER 

(p. 39) states that “The maximum range of the beta particle is less than 5 millimeters in air. The 

range of this beta radiation is about 0.6mg/cm2 [Weaver 1989, PDF p. 7], which is less than the 

thickness of the epidermal layer of the skin [NIOSH 2007]; therefore, NIOSH does not consider 

tritium to be an external radiation hazard.” This assumption is consistent with usual health 

physics considerations in the Energy Employees Occupational Illness Compensation Program 

Act (EEOICPA) program in general and elsewhere.

Kr-85 (251 keV average and 687 keV maximum beta energy) poses a greater external beta 

exposure hazard than tritium because its beta particles have sufficient energy to cause a skin dose 

through exposure to a cloud of the gas. The plant used Kr-85 in leak detection systems. Although 

the plant recovered most of the gas after each leak test, some of it might have escaped into the 

environment despite the two leakage detection systems being surrounded by ventilation shrouds. 

However, SC&A’s investigation of documented incidents at the plant found no instances of a 

cloud release of Kr-85. 

X-ray diffraction and electron-beam equipment contained electron-producing sources and could 

only have directly exposed workers in the vicinity if the equipment containments were 

compromised. Various large and small sealed sources were also beta emitters. SC&A 

investigation of personnel exposures has not revealed any monitored external doses associated 

with these sources of radiation. 

C-14 (49.5 keV average and 156.5 keV maximum beta energy) produces beta particles with 

energies greater than 15 keV and is thus considered an external beta radiation hazard. The plant 

used small amounts of this radionuclide as a tracer in some solvents. The ER notes that the 

amount of C-14 at the plant is considered negligible, with little potential for external beta 

exposure to personnel. SC&A concurs. 

A 1992 Pinellas summary of natural uranium glass concerns notes that the plant used borosilicate 

glass containing 1.5 percent by weight of naturally occurring uranium oxide (Pinellas Plant, 

1992–1994, PDF p. 2). As part of plant operations, this glass was cut and chemically etched. Site 

health physicists (HPs) evaluated the exposure risk and determined that the conservative highest 

whole body external dose expected from work with the glass was 15 millirem (mrem)/year and 

the highest dose to the extremities was 75 mrem/year. These are well below DOE limits at that 

time of 5 and 50 rem, respectively. Therefore, uranium glass is not considered a significant 

external beta radiation hazard.

3.2.3 Neutron radiation

As discussed in section 3.1 of this SC&A review, potential neutron exposures at the Pinellas 

plant could have come from either radiation-generating devices, such as the neutron generators, 

or from the sealed 238PuO2 heat sources, which were used in the RTGs. 
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When activated, the neutron generators accelerated deuterium ions into deuterium- or tritiumcontaining targets and, through nuclear fusion processes, produced 2.5 MeV or 14.1 MeV 

neutrons, respectively. A 1986 GEND “Pinellas Plant Facts” summary notes that the neutron 

generators, which had to be replaced periodically in nuclear weapons due to radioactive decay of 

the tritium (12.33-year half-life), were designed by SNL (GEND, 1986, p. 14). A fuller 

description of how the neutron generators work can help inform a review of the ER and 

referenced sources; such a description appears in a 2002 SNL history of the Nuclear Weapons 

Complex, part of which is excerpted here: 

Deuterium atoms are entrapped in a source material located at one end of a highvacuum tube. Tritium atoms are entrapped in a target material at the other end. 

The tube is connected to an electronic circuit.

The weapons system provides an input signal to a timer in the neutron generator. 

The timer is synchronized with the weapon system’s fuzing circuitry [which 

detonates a nuclear weapon] to ensure that neutrons are released at the precise 

time for initiation. A high current is sent to the source and ionizes the deuterium 

into a plasma. A very high voltage is placed between the source and the target and 

accelerates the deuterium ions into the tritium. . . . Fusion reactions occur between 

the deuterium and tritium nuclei and produce neutrons. [SNL, 2002, pp. 127–128] 

The 238PuO2 sealed sources were manufactured by Los Alamos National Laboratory; the 1990-

vintage RTGs producing 5 watts thermal power and 25 milliwatts electric power at 2 volts for 

over 25 years (Pu-238 has an 87.7-year half-life). The plutonium in the RTGs also produced 

neutrons from fission initiated by (alpha, neutron) reactions, but continuously rather than 

intermittently as is the case with the neutron generators (GEND, 1990). The Pinellas 1990 

ALARA report (Harder, 1991) states that the plutonium heat sources were the only measurable 

sources of neutrons at the plant. 

3.3 Internal exposures

The petition requests inclusion of the Pinellas Plant in the SEC based partially on radiological 

characterizations that did not include strontium (Sr)-90, cobalt (Co)-60, thallium (Tl)-204, 

beryllium, and uranium. In contrast, the SEC ER asserts that only tritium was an internal 

exposure risk at Pinellas and, therefore, did not include other radioisotopes in its evaluation. The 

following sections discuss the radioisotopes mentioned in the petition, as well as several others 

that could have potentially caused an internal dose. It must also be noted that beryllium, cited by 

the petition, is a nonradioactive hazard and outside the scope of this program. 

3.3.1 Tritium

The ER identifies tritium as the only source of internal radiation exposure risk to personnel. 

Tritium intakes and related issues have been extensively discussed with the Pinellas Plant WG 

and in both NIOSH and SC&A documents. The current occupational internal dose TBD, 

ORAUT-TKBS-0029-5, revision 03 (ORAUT, 2016), gives dose guidance for both soluble and 

insoluble tritium in different forms. Section 7.1.1.1 of the ER (p. 62) references section 5.8.1.1 of 

that TBD for a description of the methodology NIOSH uses to reconstruct internal doses from 
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soluble tritium (tritium gas, tritium oxide, and organically bound tritium) from bioassay results. 

In summary, NIOSH: 

• Calculates exposures to both 100 percent tritium gas and 100 percent organically bound 

tritium and then selects the most claimant-favorable value.

• Assumes that workers exposed to insoluble tritium compounds (i.e., metal tritides) would 

also have worked with soluble tritium and that they would have then been monitored for 

tritium. Consequently, NIOSH assigns insoluble tritium exposures only for periods when 

a worker submitted a urine sample. Pinellas had limited exposure potential for the 

insoluble forms compared to the soluble forms; however, NIOSH assesses all workers 

monitored for soluble tritium as though they received exposures to insoluble tritium at the 

same time. This is a claimant-favorable approach.

Potential tritium exposure at Pinellas has been a subject of concern and scrutiny since SC&A’s 

earliest review of the Pinellas site profile TBDs, which were issued from 2005 through 2006 

(ORAUT, 2005a, 2005b, 2005c, 2005d, 2005e, 2006). As discussed in section 2 of this review, 

SC&A reviewed the TBDs in 2006 and identified 11 primary and eight secondary issues (SC&A, 

2006). Of these, primary issue 2 (“Potential doses from insoluble metal tritides not sufficiently 

addressed”), primary issue 7 (“Missing internal dose estimation methods for unmonitored 

workers, such as maintenance and support personnel, not provided”), and secondary issue 3 

(“Perimeter tritium monitoring stations”) relate to tritium. Subsequent documents, reviews, and 

discussions resulted in SC&A issuing an updated “Issue Resolution Matrix for Pinellas Plant” on 

March 15, 2016 (SC&A, 2016a), which indicated that primary issue 7 and secondary issue 3 

were closed. 

As part of resolving primary issue 2, NIOSH issued a paper in 2015, “Review of NIOSH’s 

Current Approach to Reconstruction of Insoluble Tritium Particulate at the Pinellas Facility” 

(NIOSH, 2015), in which the Pinellas SMT model was based on that used for the Mound plant. 

SC&A responded with its own paper in February 2016, “Review of Proposed Stable Metal 

Tritide Dose Reconstruction Methodology at Pinellas” (SC&A, 2016c). 

After discussions at WG meetings, the WG accepted the NIOSH SMT model and put primary 

issue 2 in abeyance until the internal dose TBD is revised appropriately and then reviewed

(SC&A, 2016b). As stated in the March 2016 issue resolution matrix, “NIOSH indicated that the 

next TBD revision will include a discussion of how intakes of tritides, OBT, and HTO are 

addressed individually” (SC&A, 2016a, p. 3). While the WG and SC&A agree with NIOSH’s 

stated resolution of the issue, the final language appearing in the revised TBD would have to be 

examined before the issue could be closed.

SC&A’s presentation at the August 9, 2016, Board meeting (SC&A, 2016b, slide 5) summarized 

the five key aspects of the SMT model as follows: 

1. Resuspension factor: Increased from 1E-6 to 5E-5 per meter (same as 

Mound). 
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2. The use of the highest tritium contamination measurement (1957–

1973): Airborne contamination estimated based on highest observed value 

in monthly health physics reports from 1957 to 1973. (Note: Assumed 

level of SMT contamination level is 1 to 2 orders of magnitude higher than 

the assumed values at the Mound site.)

3. Technical adequacy of the method to detect tritium that is bound to 

particulate metal: Contamination swipes utilize a cotton ball that was 

rinsed with DI [deionized] water (counting liquid) and then filtered prior 

to measurement by liquid scintillation counting. Particulate tritium could 

potentially be trapped in the cotton ball and not transferred to the counting 

liquid. 

4. The magnitude and extent of potential for tritium contamination at 

Pinellas: SMTs only handled in areas where tritium was handled, and all 

tritium workers were monitored via urinalysis. Model only applied to 

those with tritium bioassay (i.e., coworker intakes not applied to 

unmonitored workers). 

5. Choice of solubility type for the metal tritides present: Assumes all 

SMT intakes are Type M or Type S depending on which is favorable to 

the individual claimant. 

SC&A’s Board presentation on the treatment of SMTs concluded that “All 5 key aspects of the 

SMT model have been incorporated into TBD-5 Rev. 3 [the occupational internal dose TBD; 

ORAUT, 2016]” (SC&A, 2016b, slide 11). 

The Pinellas SEC ER (October 20, 2021) and the occupational internal dose TBD (rev. 03, 

July 18, 2016) do not incorporate the guidance for performing dose reconstruction (DR) for 

intakes of “special tritium compounds” (STCs, including SMTs) in revision 01 of ORAUTOTIB-0066, “Calculation of Dose from Intakes of Special Tritium Compounds,” issued

October 15, 2020 (ORAUT, 2020; “OTIB-0066”). The TBD was released several years before 

revision 01 of OTIB-0066, and the ER was released at approximately the same time as the OTIB. 

The OTIB-0066, revision 01, publication record states: 

Removed recommendation to use ORAUT-OTIB-011 for assessing OBT. Added 

discussion on practical interpretation of urinalysis results following an intake of 

an SMT. Incorporates formal internal review comments. Constitutes a total 

rewrite of the document. [ORAUT, 2020, p. 2] 

In recognition of the major changes in OTIB-0066, revision 01, compared to the original version, 

the Board tasked SC&A with reviewing it, which resulted in SC&A producing an assessment on 

April 28, 2021 (SC&A, 2021). The “Background” section of SC&A’s memorandum references 

section 2.0 of OTIB-0066, revision 01 (ORAUT, 2020, p. 5), which summarizes the issue it 

addresses:

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

detected by urine bioassay as easily as tritium oxide [“water”]. “Stable” is used to 
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indicate that the tritium is not easily separated from the metal matrix in which it is 

bound. The material is more strongly retained in the lung, resulting in much 

smaller fractions of the intake excreted in urine. Therefore, a relatively small 

amount of tritium in a urine sample can indicate a large intake of an SMT. 

Ideally, workplace information, in the form of air monitoring, surface 

contamination activity, and process knowledge, are used to assign potential 

intakes of this material, which is addressed in a site profile when possible

[emphasis added]. 

In the absence of other available monitoring data, urinalysis can be used to 

provide a best estimate of an intake. The purpose of this TIB is to provide 

guidance on how to use urine bioassay data to calculate best estimates of the 

annual organ doses for intake of tritium in a metal matrix.

Observation 2: Potential for tritium contamination is adequately addressed

SC&A notes that key aspect 4 of the accepted NIOSH SMT model indicates that SMT exposures 

would only be applied if the energy employee (EE) were also monitored via urinalysis. However, 

given the deficiencies noted by the Tiger Team in the performance of the bioassay program as 

late as 1990, relying on bioassay completeness to establish exposure potential is likely 

inappropriate. 

SC&A’s 2021 OTIB-0066 review (SC&A, 2021) notes that SC&A’s 2008 evaluation of 

revision 00 of OTIB-0066 had four findings, two of which were closed (findings 2 and 4) and 

two of which were in abeyance (findings 1 and 3). “SC&A concludes that both findings [1 and 3] 

have been adequately addressed and resolved and recommends closure” (SC&A, 2021, p. 4). At 

its November 3, 2021, meeting, the Subcommittee for Procedure Reviews (SPR) agreed to close 

these two issues, leaving no remaining open issues (ABRWH, 2021a). Hence, the methodology 

presented in OTIB-0066, revision 01 (2020), for treating exposures to STCs has been accepted 

by the SPR. 

It should be noted that the petitioners sent a letter to the Board dated December 12, 2017, 

describing their concerns with DR from exposure to metal tritides. SC&A believes that the 

conclusions from the 2021 SPR meeting address and resolve these concerns. SC&A’s 

observation 3 recommends a TBD action and that NIOSH evaluate the issue for any significant 

SEC consequences.

Observation 3: The ER does not reference recent special tritium compound document

The SEC evaluation report and ORAUT-TKBS-0029-5, revision 03 (the occupational internal 

dose TBD), do not incorporate guidance for performing dose reconstruction for intakes of stable

metal tritides from revision 01 of ORAUT-OTIB-0066 (2020). NIOSH should commit to 

reference and discuss guidance from OTIB-0066 in the next revision of the occupational internal 

dose TBD and evaluate whether it has any consequential effect on the SEC evaluation report 

conclusions. In addition, as noted in key aspect 2 of the SMT model accepted by the Board (as 

presented by SC&A at the August 9, 2016, Board meeting), sitewide air monitoring data or 

contamination survey data should be preferentially used over other modeling in dose 

reconstructions for SMTs whenever available. 
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A discussion of potential metal tritide exposures appears in an Oak Ridge Associated 

Universities Team (ORAUT) interview of a former Pinellas Health Physicist (HP), where the HP

stated (as paraphrased by ORAUT) that “the same contamination survey procedures were used 

for metal tritide contamination as for tritiated water contamination” (ORAUT, 2013, 

p. 3). Furthermore,

[The HP] indicated that they knew where tritide contamination would likely 

occur, which was typically limited to 2-3 areas within the operation line. [The 

HP] thought that there might be more causes of tritium contamination in 

destructive testing. [Another HP] discovered that tritide exposures were occurring 

in an unexpected area via the bioassay results of a worker that was offsite for a 

long enough period of time for any (soluble) tritium to be eliminated from their 

body. When that worker returned to work, their urine still had tritium in it, which 

could only have been from a (less soluble) metal tritide exposure. Once they 

figured out the cause of the metal tritide exposure, they move the operation that 

was causing it into a fume hood and eventually into a glove box, to help prevent 

further exposure to tritides. [ORAUT, 2013, p. 3] 

Three takeaways from this account by a former Pinellas HP are that (1) the locations of metal 

tritide contamination were limited, (2) the Health Physics group was on the lookout for potential 

sources of metal tritide exposure, and (3) when sources of exposure were found, the Health 

Physics group took positive steps to eliminate the potential. In addition, it should be reiterated 

that SMT exposures are based on available sitewide air monitoring data; therefore, identifying 

workers in specific areas where SMTs are handled is not crucial to establishing a bounding 

exposure. 

3.3.2 Uranium

Depleted uranium was used on site in tritium storage beds. Secondary issue 8 from the original 

SC&A TBD review (SC&A, 2006) concerns the potential for missed depleted uranium intakes. 

This issue arose when some literature and interviews with former employees raised the 

possibility that loose (not contained) depleted uranium was present in Building 100 from the 

cutting/machining of depleted uranium beds, which were used to store tritium. NIOSH 

investigated this issue and determined that the cutting work described by these workers and 

literature was done at the GE X-ray Milwaukee site, which is not part of the Pinellas SEC 

review. In 2009, SC&A reviewed the records identified by NIOSH and agreed that the records 

conclusively establish the work described was done off site from the Pinellas Plant. This issue 

was discussed and closed at the June 11, 2009, Pinellas WG meeting (ABRWH, 2009, pp. 58–

64), as also noted in the issues resolution matrix (SC&A, 2016a, p. 8). 

Another Pinellas report, concerned with potential exposure concerns from natural uranium glass 

used to store tritium, states that no internal hazards were identified (Pinellas Plant, 1992–1994). 

In an ORAUT interview with a site HP, the HP indicated that there were two accidental breaks in 

the U-beds (stainless steel tritide storage beds that used uranium tritide to store tritium)

(ORAUT, 2013). According to the HP, they were not large activity beds nor the main storage 

beds, and no uranium contamination was found. They were both classified as minor incidents, 

and the beds were taken out of service. The interview did not mention any dates associated with 
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these incidents, and SC&A could not locate any documentation of incidents associated with these 

descriptions. One possibility is that the lack of documentation indicates the low degree of 

severity of the incident. 

3.3.3 Plutonium

SC&A had previously examined the issue of plutonium monitoring at Pinellas as part of its 

review of revision 00 of the occupational internal dose TBD (SC&A, 2006; pp. 26, 33). This 

review was discussed at subsequent Board meetings (ABRWH, 2009, PDF pp. 26–31; ABRWH, 

2011, PDF pp. 70–89; ABRWH, 2012, PDF p. 28). SC&A documented the final resolution in the 

March 15, 2016, update of the issue resolution matrix (SC&A, 2016a, p. 4), which summarizes 

the plutonium issue (issue 3) as follows:

This was a concern early in the issues resolution process, when some potential 

exposure to plutonium (Pu) was not ruled out. Based on discussions at the 

October 2011 WG meeting, it was determined that the only source of potential 

intake was from handling of newly received triple encapsulated radio-thermal 

generators (RTGs). However, there was no surface contamination greater than 

200 dpm (the rejection level), and NIOSH calculations show that to receive even 

1 mrem annual dose would require handling thousands of RTGs in a year. 

Therefore there is no credible source of exposure. In Revision 2 of TBD 5 

[occupational internal dose], all Pu discussion was removed based on discussion 

at the October 2011 WG meeting. If evidence of a positive exposure is 

discovered, NIOSH will need to develop a dose reconstruction (DR) 

methodology. 

In this review, SC&A chose to revisit the potential for plutonium exposure beginning with a 

more detailed look at the form, handling, and plant operations involving plutonium. A good 

summary appears in a 1982 DOE safety analysis that was written in support of a planned 

expansion of Building 400, which housed the RTG facility (DOE, 1982): 

An RTG consists of a heat source containing a small amount of plutonium oxide 

encapsulated in a thimble-sized container. The heat source is enclosed within 

thermal insulating material so that its temperature approaches 500o

C [degrees 

Celsius]. It is mated with a thermopile consisting of many thermocouples 

connected electrically in series and thermally in parallel between this high 

temperature source of heat and the relatively cool outer case. The temperature 

differential causes heat to flow through the thermopile which the latter converts to 

electrical energy. . . . The current design produces 25 milliwatts of electrical 

power at low voltage for in excess of 25 years. [DOE, 1982, PDF p. 3] 

This safety analysis also noted that RTGs had been manufactured in Building 400 since 1975 and 

that the sealed heat sources, containing Pu, were manufactured at another DOE facility (DOE, 

1982, PDF p. 6). 

An undated document in the Pinellas SRDB files elaborates that the first plutonium appeared at 

Pinellas on January 18, 1957, when a 7-gram Pu-239 calibration source was received (“First 

Plutonium,” n.d.). More importantly for this review, the “First Plutonium Delivered Onsite” 
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document describes the chronology of the RTG operations as follows: “The first receipt of 

plutonium for use in the Radioisotopic Thermoelectric Generator (RTG) was on November 4, 

1975, when seven heat sources totaling 54.4 grams of Pu-238 were received from Sandia 

Laboratories,” and “all plutonium, with the exception of calorimeter sources and small 

instrument calibration check sources, were removed from the plant in February 1991” (“First 

Plutonium,” n.d., PDF p. 2). 

DOE (1982, PDF p. 6) states: “The heat source is mated with a thermopile, (manufactured at this 

site), enclosed in thermal insultation and packaged in a welded steel case. . . . The heat sources 

themselves are manufactured to a design verified to withstand external stresses in excess of those 

foreseen in any postulated accident [discussed elsewhere in the DOE report].” Discussing the 

environmental safety and health “programs, systems, procedures, facilities and equipment” 

related to the RTGs, the DOE safety analysis states that “Their [controls] effectiveness can be 

demonstrated by the fact that there is not, nor has there ever been, any plutonium 

contamination inside the facility nor released to the environment” (DOE, 1982, PDF p. 6; 

emphasis added).

Section 5 of DOE 1982 describes the operations associated with the plutonium heat sources, 

emphasizing contamination detection and control. This is worth repeating here to gain a sense of 

the flow of the sources from intake to assembly into RTGs: 

Shipments of heat sources are delivered directly to Building 400. The shipping 

packages are surveyed for surface contamination by instrument and swipe, then 

transferred to the source storage vault room. The truck is also surveyed before 

being released.

When the shipment packages are to be opened, they are moved from the vault 

room to the source inspection hood. Here they are opened and surveyed in 

accordance with Radiological Safety Procedure F-3 (see Appendix A) and, if free 

of contamination, are placed in a source storage container and returned to the 

vault. If the unpacking survey shows greater than 200 DPM [disintegrations per 

minute], the source is immediately repackaged and returned to the supplier. If the 

survey shows detectable contamination less than 200 DPM, an effort is made to 

decontaminate the source in accordance with Radiological Safety Procedure F-4 

(See Appendix A). This circumstance has not occurred in over six years of 

RTG operations at this site [emphasis added]. 

When sources are to be placed in the glovebox for assembly into an RTG, they are 

moved from the vault to the source inspection hood, surveyed again in accordance 

with Radiological Safety Procedure F-5 (see Appendix A), cleaned with alcohol, 

placed in a cleaned storage container and transferred to the glovebox. [DOE, 

1982, PDF p. 34] 

Section 6 of DOE (1982, PDF p. 40) notes that “Three layers of encapsulation contain the source 

material (Figure 6-1). The outer layer is a nickel alloy and the inner two layers are a tantalum 

alloy.” The report’s accident analysis for “Source Leakage” concludes that “The probability of 

source leakage, although possible, is so small that it can be assumed that it will not occur” (DOE, 
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1982, PDF p. 45). The unidentified document on plutonium in the Pinellas SRDB files echoes 

that conclusion: 

Fall-out plutonium has been detected at the Pinellas Plant, but analysis for 

releases of RTG plutonium focuses on the isotopic ratio of 80% by weight Pu-238 

and 16% by weight Pu-239. Pu-238 and Pu-239 have not been found in these 

ratios in environmental samples, therefore, no releases from Pinellas Plant 

operations have been detected in the environment. [“First Plutonium,” n.d., 

PDF p. 2] 

Since (1) the plutonium radiological hazard issue has been discussed and is considered resolved 

by the Pinellas WG and (2) the current further investigation supports that conclusion, SC&A 

believes the potential for plutonium intakes has been adequately addressed and resolved. No 

further discussion is necessary unless new information becomes available. 

3.3.4 Carbon-14

Table 4-2 of the occupational environmental dose TBD, ORAUT-TKBS-002904, revision 01 

(ORAUT, 2011d, pp. 12–13), gives radionuclides released from Pinellas Plant exhaust stacks for

the years 1957–1997. C-14 emissions are denoted as “no recorded release” for all years except 

1979–1983, which total 0.000435 Ci. Note c of the table explains that the releases are based on 

the amount of C-14 labeled solvent used each year. 

According to the State of Florida Department of Health and Rehabilitative Services (HRS), 

approximately 0.00034 Ci of C-14 were released from plant stacks from 1979 through 1983 

(DOE, 1994b, PDF p. 42). SC&A previously identified C-14 as a potential exposure pathway in 

its initial TBD review as part of issue 7 and secondary issue 2. The issues were discussed with 

the Pinellas Work Group during the June 11, 2009, meeting (ABRWH, 2009). The quantity of 

material was determined to be “negligible” and contributed less than a mrem per year dose when 

modeled in the Integrated Modules for Bioassay Analysis (IMBA) program (PDF pp. 57–58). 

Since these issues have been discussed and are considered resolved by the Pinellas WG, SC&A 

believes the potential for C-14 intakes raised in the ER petition has been resolved. C-14 does not 

contribute significantly to the internal dose hazard on site. No further discussion is necessary 

unless new information becomes available.

3.3.5 Krypton-85

According to the State of Florida Department of Health and Rehabilitative Services, a total of 

846 Ci of Kr-85 was released from plant stacks from 1963 through 1992 (DOE, 1994b, PDF

p. 42). Kr-85 is a colorless, tasteless, radioactive noble gas that decays by beta emission to 

rubidium-85, a stable isotope. As a noble gas, it does not react chemically within the body when 

it is breathed in and out. Although a minute amount of decay can be expected in the lungs 

(10.8-year half-life), Kr-85 primarily represents only a potential external hazard. As stated in an 

Argonne National Laboratory (ANL) fact sheet for krypton (ANL, 2005, PDF p. 2): 

The main health concern [of Kr-85] is the increased likelihood for cancer 

induction, and the exposure pathway of most concern is external exposure in a 

cloud of gas. The radiation dose for krypton-85 (the primary isotope of concern) 

from an external cloud of gas is more than 130 times higher than the dose from 
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any gas in the lungs and more than 200 times higher than that from any gas in 

body organs and tissues after being taken into the body. . . . much of the dose for 

krypton-85 is from beta particles, and the skin is the primary tissue of concern. 

The ANL krypton fact sheet also states that there haven’t even been lifetime mortality risk 

coefficients developed for inhalation/ingestion, only for external exposure from immersion in a 

cloud. 

SC&A concurs with NIOSH’s assessment in section 5.2 of the ER that this isotope does not pose 

a significant internal hazard. 

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

The petition requests that Pinellas be added to the SEC based upon the claim of incomplete 

radiological characterizations of Sr-90, Co-60, Tl-204, and beryllium (uranium is discussed in 

section 3.3.2 of this review). SC&A notes that beryllium is an element, not a radionuclide, and 

while it may present a health hazard, it is not a source of radiological exposure at the site. The 

other three radionuclides were present on site according to inventory records. 

SC&A reviewed the justification provided in the petition concerning the presence of 

radionuclides requiring bioassay monitoring. SC&A does not find that the presence of the 

radionuclides Sr-90, Co-60, and Tl-204 in inventory presented an internal exposure risk that 

should have been monitored for by Pinellas. Among other isotopes, Sr-90, Co-60, and Tl-204 

were listed as nonproduction radioactive sources in the site inventory (DOE, 1994b, PDF p. 117).

All Co-60 and Tl-204 sources were listed as sealed sources, thereby not constituting an internal 

radiation hazard. SC&A is aware of a 100 millicurie (mCi) Co-60 source that was found to be 

leaking in 1961 (Forest, 1961, PDF p. 4). Sealed sources are typically kept under control and 

undergo routine testing to ensure the integrity of the seal. The leak was detected as part of these 

routine surveys and was corrected immediately; as such, it did not pose a sitewide internal 

exposure risk. Sr-90 was present in both sealed and unsealed sources listed in inventory; 

however, the unsealed sources were small (0.013 microcurie (μCi) and 0.25 μCi) and did not 

pose a sitewide internal risk. While these isotopes can be used as a power supply for RTGs, 

SC&A has not found evidence that they were used in this capacity at Pinellas.

Additionally, the petition provided workers’ heavy metal testing results for elements via 

urinalysis. However, this type of test is not a valid means of determining occupational exposure 

to radionuclides. The tests looked for elemental forms of strontium, cobalt, thallium, and 

uranium. In general, the lab results showed these elements were not detected or were below the 

detection limits of the test. Hence, these tests do not provide evidence of elemental or 

radiological intakes. These elements are found naturally in the environment, and their presence 

in urine cannot be used to establish occupational exposure to radioisotopes. The results of the 

heavy metals tests are discussed further with the petitioner concerns later in this report (refer to 

sections 6.1 and 6.2). 
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4 Radiation Monitoring

4.1 Monitoring during the SEC period 1957–1990

The NIOSH SEC ER defined and evaluated the SEC period as January 1, 1957, through 

December 31, 1990, and concluded:

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

extend beyond 1981. In addition, NIOSH has found that claimant records 

provided by DOE generally include both internal and external dosimetry results 

for potentially exposed workers. NIOSH finds that the Pinellas Plant did monitor 

potentially exposed personnel and did not find indications of lack of monitoring 

for the class under evaluation. NIOSH concludes that it has sufficient data to 

perform dose reconstructions. [NIOSH, 2021a, p. 82] 

The NIOSH ER asserts that only tritium is important for internal exposure and that there are

sufficient tritium bioassay data and also external monitoring data for DR for the SEC period 

(NIOSH, 2021a, p. 7): 

• NIOSH reviewed the internal radiation exposure potential from other 

radionuclides used at the Pinellas site including plutonium, uranium, 

carbon-14, nickel-63, and krypton-85. NIOSH confirmed previous 

discussions by the Advisory Board on Radiation and Worker Health 

(ABRWH) Pinellas Plant Work Group that these radionuclides were not 

internal exposure concerns for the Pinellas Plant workers. 

• NIOSH has access to the in vitro urinalysis monitoring records for Pinellas 

Plant workers with the potential for internal exposures including tritium 

urinalysis results, termination bioassay sample results, bioassay tabulation 

forms, exposure record cards, dose adjustment forms, bioassay dose 

summary reports, dosimetry cards for individuals, and individual 

plutonium in vitro bioassay results. NIOSH reviewed the NIOSH DCAS 

Claims Tracking System (referred to as NOCTS) claimant files and found 

over 20,000 tritium bioassay results for 230 individuals. 

SC&A does not currently have access to the searchable NOCTS database to analyze claimant 

files for this ER review. Therefore, SC&A manually reviewed the list of approximately 2,500 

documents made available by NIOSH. SC&A selected and reviewed documents that could 

potentially contain workers’ bioassay and/or external dose data. Among those reviewed, SC&A 

located 13 PDF collections of personnel monitoring records (SRDB IDs 183490 through 183502) 

of approximately 2,500 pages each that covered employees with last names starting with A 

through W. The recorded data contained tritium bioassay results (and some plutonium bioassays) 

by urinalysis and external dose monitoring of photons, neutron, and betas, as applicable, on a 

badge exchange basis in the form of handwritten cards or computer printouts. SC&A followed 

one long-term employee who started in 1957 and had many years of service and found 73 pages 

of monitoring-related data consisting of bioassay results and external dose monitoring (Pinellas 

Plant, 1950s–1990s, PDF pp. 652–724). Other examples of long-term monitoring can be found in 

these dose records. 
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4.2 Period of SEC evaluation excluded from SEC petition, 1991–1997

The petition requested that the SEC cover the period January 1, 1957, through December 31, 

1997. However, NIOSH evaluated only through December 31, 1990, justifying in the ER: 

The Tiger Team report focused on the 1988–1989 period and is not directly 

applicable to the time period that followed it because documentation shows that 

the Pinellas Plant responded to the finding. After the Tiger Team assessment, the 

Pinellas Plant began tracking individual compliance with bioassay sampling and 

had success in improving bioassay compliance. The Pinellas Plant documented 

this success in improving compliance in site As Low As Reasonably Achievable 

(ALARA) reports. Prior to these tracking efforts, it was unclear how widespread 

the non-compliance might have been. [NIOSH, 2021a, p. 6] 

The Pinellas Plant action plan for fiscal years 1990–1994 concerning tritium bioassay sampling 

resulting from the Tiger Team assessment of 1990 (DOE, 1990a) is summarized in the “Pinellas 

Plant Final Action Plan” of December 3, 1990 (DOE, 1990b, pp. 273–274). This includes five 

activities to be implemented to improve compliance and tracking of tritium bioassay sampling, 

most to be completed in fiscal year 1990 (October 1, 1989, through September 30, 1990). 

To support NIOSH’s assumption that tritium bioassay compliance and tracking were adequate 

for the period 1991–1997, the ER states (NIOSH, 2021a, p. 20): 

During the qualification assessment, NIOSH reviewed available documentation 

and information related to the site follow-up to determine if the issue identified in 

the report continued. In response to the Tiger Team assessment, the Pinellas Plant 

Health Physics Department began tracking individual compliance with bioassay 

sampling and had success in improving the compliance. The Pinellas Plant 

ALARA reports document the Plant’s success in improving compliance. The 

1990 Annual ALARA Program Report for Ionizing Radiation [Weaver 1991, PDF 

p. 38] shows the bioassay program average participation was 78%, which is 2% 

short of the 80% target. NIOSH concluded, based on the bioassay compliance 

published in the 1990–1995 ALARA reports, that it is reasonable and prudent to 

consider 1990 a transition year to a more rigorous program. 

4.3 Internal monitoring records

The ER provides a summary of tritium monitoring data in table 6-1 (NIOSH, 2021a, p. 43), 

reproduced here as table 2. These data represent the NOCTS monitoring results. Therefore, they

include only claimant monitoring results and represent a subset of the Pinellas workforce.
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Table 2. Pinellas claimants with tritium results

Year

Number of Pinellas 

claimants (all job 

titles) in NOCTS

Number of Pinellas

claimants with 

tritium results

Number of 

“Maintenance” 

claimants (by job 

title)

Number of 

“Maintenance” 

claimants with 

tritium results

1957 110 12 10 1

1958 162 21 14 5

1959 178 42 19 9

1960 199 52 19 15

1961 212 56 20 12

1962 218 54 20 11

1963 218 45 21 10

1964 224 52 22 15

1965 219 47 21 12

1966 241 60 22 16

1967 248 57 22 16

1968 260 56 24 14

1969 259 56 24 11

1970 263 47 26 9

1971 264 41 26 12

1972 268 38 26 9

1973 271 32 25 8

1974 267 44 25 11

1975 264 37 24 7

1976 274 40 26 10

1977 282 29 29 8

1978 297 33 31 11

1979 314 29 32 9

1980 320 35 31 11

1981 329 34 35 10

1982 343 31 34 10

1983 345 38 36 8

1984 349 35 37 8

1985 354 25 37 6

1986 343 26 36 7

1987 330 21 36 6

1988 310 8 34 1

1989 299 3 0 0

1990 288 10 32 1

1991 280 14 32 2

1992 268 37 34 4

1993 190 9 0 0

1994 162 19 0 0

1995 127 1 17 4

1996 89 12 6 1

Source: NIOSH (2021a), table 6-1.

SC&A located SRDB 188333, which is an Excel workbook containing the data NIOSH used to 

generate table 2 of this report (ER table 6-1) (NIOSH, 2021c). While performing its review of 

the ER, SC&A requested that NIOSH provide the actual monitoring data supporting table 2, 

which NIOSH then supplied. The data provided are similar but represent the most current 

available data; therefore, they are not identical to the information used by NIOSH to generate 
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table 2. SC&A compared the bioassay results to the historical reporting levels from table 5-3 of 

the internal dose TBD (ORAUT, 2016). Figures 3 and 4 show that, through the mid-1970s, most 

tritium urine bioassays were below the historical reporting levels of TBD table 5-3, which 

changed in April 1974 from 0.67 microcuries per liter (μCi/L) to 0.10 μCi/L. The minimum 

detectable concentration (MDC) reduced to 0.01 from 1987 through 1989 and again dropped to 

0.006 μCi/L from 1990 through 1997. These reduced thresholds explain the increase in reported 

samples above the reporting level. SC&A has not found evidence that the increase in positive 

samples corresponds to an increase in dose or exposure risk. 

Figure 3. Comparison of tritium bioassays as a fraction of annual total
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Figure 4. Comparison of tritium bioassays as annual counts

Observation 4: Lack of bioassay records for 1988–1990

From analyzing these results, the bioassay records from 1988 through 1990 stand out. Despite 

between 129 and 201 employees (table 3 and ER table 6-1) reportedly monitored by bioassays 

during these years, NIOSH only has monitoring records for 3–10 claimants per year (table 2 and 

ER table 6-2). According to the 1990 Tiger Team report, approximately 1,750 people were 

employed in 1989, suggesting that monitoring records are missing. 

SC&A analyzed tritium inventories and throughput as an explanation of changes in bioassay

monitoring. Biedermann (1994) provides an estimate of the historical tritium inventory at 

Pinellas. Inventory estimates for the period 1957–1993 were compiled by an Environmental 

Health Scientist for the National Center for Disease Control as part of an epidemiology 

feasibility study in September 1993 using plant tritium receipts, waste management disposal, and 

environmental monitoring records. These records were corrected to account for radioactive 

decay. Additionally, the scientist documented the tritium leaving the plant from product 

shipments, waste, air, and wastewater. These results are reproduced in figure 5 and compared 

with the monitoring data from table 2. As shown in figure 5, it is not clear that any correlation 

exists between the number of individuals monitored (per NOCTS) and the inventory or tritium 

throughput. 
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Figure 5. Comparison of tritium onsite to bioassayed individuals

The ER summarizes tritium monitoring data for the period 1986–1995 in table 6-2 (NIOSH, 

2021a, p. 45), reproduced here as table 3. This table summarizes the information contained in 

ALARA reports rather than claimants and NOCTS data.

Table 3. Summary of Pinellas internal monitoring data for tritium 1986–1995

Year Number 

monitored

Total dose 

(person-mrem)

Average dose 

(mrem)

Highest 

individual dose 

(mrem)

1986 194 699 3.6 86

1987 139 358 2.58 105

1988 129 565 4.38 130

1989 201 557 2.77 97

1990 b 177 184 1.04 31

1991 202 390 1.93 101

1992 164 150 0.91 35

1993 134 103 0.77 21

1994 217 17 0.08 6.3

1995 215 224 a 1.04 93 a

Sources: Weaver (1993), PDF pp. 20, 23; Weaver (1996), PDF p. 15. 

a. Includes dose from a single incident in which one individual received an exposure of 93 mrem. The total site dose 

and highest individual dose (excluding this one individual) were 131 and 23 mrem, respectively.

b. The 1990 row is NIOSH’s assumed year of transition and last year of SEC evaluation.

SC&A located semiannual and quarterly compliance records from the 1990 and 1991 tritium 

bioassay programs (Weaver, 1990–1991). These reports were started following the deficiencies

identified by the Tiger Team report. Individuals who were on a routine (weekly or monthly) 
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tritium bioassay program were tracked for compliance with the bioassay program on a 

semiannual basis. The reports list individuals by name and indicate the number of tritium 

bioassays required and those that the individuals submitted. Each report stresses a goal of 

maintaining 80 percent minimum participation for all monitored employees. The ultimate goal 

was 100 percent participation, but the goal of 80 percent allowed for absences and other work 

interruptions. The reports show between 58 and 62 individuals on routine monitoring in each 

period. After the initial tracking began, the reports show between 7 and 12 individuals falling 

below the goal in each monitoring period. Four of these individuals appear on each report as 

noncompliant. 

Observation 5: Bioassay schedule noncompliance by the plant

One of the principal Tiger Team findings relevant to the SEC petition was noncompliance with 

the plant’s own requirements for termination, monthly, and weekly bioassays. Appropriate 

bioassay compliance (data completeness levels) in general is a subjective judgment to be made 

by the Board. In addition, the level of compliance with the bioassay program is unknown before 

the findings of the Tiger Team. It is SC&A’s opinion that at a minimum, NIOSH should 

demonstrate that an appropriate co-exposure model can be constructed to address apparent 

incompleteness in the tritium bioassay program (likely throughout its relevant operating history). 

Despite concerted efforts by the site to rectify the compliance issues, nearly one-fifth of worker 

bioassay requirements were still not met. Bounding co-exposure values would certainly appear 

warranted during this latter period (1991–1997). 

4.4 Additional Tiger Team findings about internal dosimetry 

Appendix A to this SC&A review consolidates in list form some of the information in the Tiger 

Team report (DOE, 1990a) that SC&A finds particularly relevant to a review of the Pinellas SEC 

ER. As stated in appendix A, the focus of all DOE Tiger Team investigations was environmental 

safety and health compliance issues and less so radiation exposure issues. Some of the issues 

related to internal dosimetry are highlighted in this section: Overall, the Tiger Team report 

represents a balanced assessment of the radiation protection program and its implementation, 

presenting both positive and negative observations and findings. 

Section 3.5.8.2 (p. 3-75) of the Tiger Team report observes that, 

Although the dose equivalents to the maximally exposed individual reported by 

the Pinellas Plant have consistently been well below the NESHAP [National 

Emission Standards for Hazardous Air Pollutants] limit of 10 mrem/year for 

whole body irradiators (no target organ irradiators are released in detectable 

quantities), the program as it exists today is not capable of defending the quality 

aspects required by existing and draft DOE Orders.

Observation 6: Radiological protection program commended by Tiger Team

On a positive note, commending the radiological protection program, section 4.5.11.1 (p. 4-90) 

of the 1990 DOE Tiger Team report states, “The overall assessment is that all levels of the 

GEND organization are receiving adequate radiological protection. This is primarily due to a 

GEND staff that appears willing to accept line responsibility for radiological safety along with a 

technically strong health physics staff providing direction.” 
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Observation 7: Bioassay sampling frequency requirements not followed as noted by the 

Tiger Team

Section 4.5.11.1 (p. 4-91) of the 1990 DOE Tiger Team report compliments the plant for 

maintaining low overall internal dose exposures but also makes an important finding on 

noncompliance issues related to the plant not following bioassay sampling frequency 

requirements. This is one of the bases given in the SEC petition: “Occupational internal 

exposures are low compared to other DOE sites. This accomplishment results from a 

conservative approach to working with tritium and through the extensive use of engineering 

controls. However, compliance with the rules on providing bioassay samples at specified 

frequencies has not been satisfactory.” 

Observation 8: Contamination controls found generally good by Tiger Team

Section 4.5.11.1 (p. 4-91) of the 1990 DOE Tiger Team report discusses the effectiveness of

contamination controls at Pinellas and notes that while it is generally good, there are instances 

when it is not: “Contamination controls are generally good. Contamination levels within the 

work areas are kept low and generally confined to the source. Indications were found that proper 

contamination control techniques are not always being followed, in some areas causing 

contamination spread to the general areas of the facility.”

Section 4.5.11.2 (p. 4-101) continues the discussion of contamination controls with a negative 

statement: “Proper contamination control techniques are not being followed by personnel when 

working in and exiting from Contaminated Areas.” The report (p. 4-102) noted that a contractor 

disagreed that workers were inadequately protected given the extremely low contamination 

levels detected and that “radiation exposures from these contamination levels are not measurable, 

as supported by bioassay sampling.” 

Observation 9: Bioassay sampling program implementation inadequacies noted by the 

Tiger Team

Section 4.5.11.2 (p. 4-98 ff.) of the 1990 DOE Tiger Team report contains several radiological 

protection findings and concerns related to internal dosimetry that are relevant here. Of particular 

importance, finding RP.7 (p. 4-98) claims that “Procedural requirements have not been 

established for an employee’s termination bioassay, nor a system developed to identify and 

address those individuals who fail to provide a bioassay sample.” Additionally, “GEND 

estimated that 20 percent of the personnel that terminated in 1988 did not provide a termination 

bioassay,” and that “Individual workers, their supervisors, and management are not ensuring that 

required bioassay samples are provided. In 1989, bioassay samples were not submitted in 

accordance with GEND procedures. Seventy percent of the required monthly samples and 

35 percent of the required weekly samples were not submitted.” NIOSH cited these Tiger Team 

findings as sufficient to qualify the SEC petition for further evaluation (refer to section 2 of this 

report).

Observation 10: Tiger Team assessment of deficiency root causes: emphasis on 

production and mindset that Pinellas poses no unusual radiological risks

Section 5.7 (p. 5-33) of the 1990 DOE Tiger Team report covers management assessments. It 

opines the following on the probable root causes of some of its deficiency findings and lists the 

following two: “First, emphasis on production has traditionally overshadowed interest in fully 

complying with environment, safety and health requirements”; and “Second, there is a wideset 

mindset that the Pinellas Plant poses no unusual or unique risks.” 
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4.5 External monitoring

The ER summarizes external monitoring data for the period 1986–1995 in table 6-4 (NIOSH, 

2021a, p. 51), shown here as table 4. 

Table 4. Summary of Pinellas external monitoring data for 1985–1995

Year Number 

monitored

Total dose 

(person-mrem)

Average dose 

(mrem)

Highest individual 

dose (mrem)

1985 Not reported 5,525 Not reported 411

1986 Not reported 2,837 Not reported 550

1987 Not reported 2,102 Not reported 321

1988 171 1,712 6.7 170

1989 187 1,847 4.9 180

1990 b 185 2,104 a 8.3 280

1991 107 830 3.9 40

1992 117 350 1.7 30

1993 88 270 2.3 50

1994 80 60 0.5 20

1995 72 243 0.28 10

Sources: Weaver (1992), PDF pp. 9, 15, 20; HRS (1995); Pinellas Plant (1996); Weaver (1996), PDF pp. 12–13. 

a. Most external exposures were from RTG operations, which moved offsite in early calendar year (CY) 1991.

b. The 1990 row is NIOSH’s assumed year of transition and last year of SEC evaluation. 

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

reduced exposures 

The Tiger Team assessment took place in January and February 1990, and the Pinellas Plant 

initiated corrective action during fiscal year 1990 (October 1, 1989, through September 30, 

1990). While data indicate a significant decrease for external doses from 1990 to 1991 (table 4), 

there was an increase in internal doses from tritium from 1990 to 1991, then a gradual decreasing 

trend during the years 1992–1995 (table 2). The number of workers bioassayed for tritium 

remained reasonably consistent during the period 1986–1995, and the number of workers 

monitored for external exposure gradually decreased during the period 1985–1995. According to 

the “1991 Annual ALARA Program Report for Ionizing Radiation” (Pinellas Plant, 1992), the 

increase in internal dose was due to the “T” box incident and recovery operations in Area 182C 

conducted in late December 1991. To date, SC&A has not found indications that there are issues 

with exposure records that would prevent DR feasibility for the SEC period 1957–1990, nor for 

the period 1991–1997. 

As presented in more detail in section 5.1 of this report, SC&A reviewed the available CATI 

reports of employees and/or their survivors, representing 490 EEs, and compiled information on 

external and internal radiation monitoring. That section discusses the frequency of internal 

exposure monitoring (urinalysis) following incidents as reported in the CATIs. SC&A’s review 

of the external monitoring information provided by the Pinellas claimants in the CATIs found 

that 40 percent (198) reported having either intermittent or routine external monitoring during 

employment. 
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5 Interviews, Incidents, and Other Information Associated with 

Claimants and/or Former Workers

5.1 Computer-aided telephone interview information

NIOSH provided SC&A with access to the 490 interviews (employees and survivors) available 

at the time of this review. SC&A examined these interviews for indications of internal 

monitoring, external monitoring, and incidents and followup. However, as noted in section 4.1, 

at the time of this review, SC&A does not have access to individual claimant monitoring files to 

compare CATI statements to relevant dosimetry records and/or included incident reports. 

SC&A’s review of the 490 CATI reports noted that 16 percent indicated that the EE was

involved in some type of radiological incident, with 38 percent (185) stating that the EE received 

urinalysis monitoring following the event. Of the CATIs that were completed with the EE 

themselves, 46 percent (160) recalled being internally monitored and 45 percent (154) recalled 

being externally monitored. It should be noted that 27 percent of the claimants reported in their 

CATIs that they did not know if they were involved in an incident. Therefore, the number of EEs 

involved in incidents may be underestimated if using the CATI information alone.

5.2 Previously reviewed Pinellas dose reconstruction cases

As part of SC&A’s ongoing work with the Subcommittee for Dose Reconstruction Reviews, 

SC&A reviewed five Pinellas cases. Full case records were not initially available due to the 

previously mentioned cybersecurity modernization initiative5

; however, the DR review reports 

were available for the five cases evaluated. SC&A summarized the monitoring history of each 

individual and compared it in table 5 with the CATI reports and internal monitoring NOCTS 

history. Due to the limited currently available data, this comparison cannot be used to tell if 

records are complete, but it can be used more broadly to identify the presence or absence of 

records in an EE’s files. Table 5 shows, at least for the limited sample, that internal monitoring 

records currently match the claimant recollections reported in the CATI. The external monitoring 

results are less conclusive: Two claimants reported being externally monitored, while the results 

were not available at the time of DR. SC&A does not have access to NOCTS to check if these 

records have since been located.

5 Full case records became available just prior to publication of this review. This review looks only at the DR

report and associated CATI reports.
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Table 5. Comparison of monitoring records used in DR vs CATI reported monitoring history in previously reviewed cases

Tab

DR 

completion 

year

Start year Stop year Occupation

DR included 

internal 

monitoring 

records

CATI 

indicated 

internal

monitoring

NOCTS 2022 

internal 

records

DR included 

external 

monitoring 

records

CATI 

indicated 

external

monitoring

80 Not specified 

(est. 2005)

[Redacted] [Redacted] [Redacted] Monitored Monitored Monitored Single 

dosimeter

Unmonitored

233 2004 [Redacted] [Redacted] [Redacted] Unmonitored Unmonitored Termination 

only

Unmonitored Unmonitored

299 2008 [Redacted] [Redacted] [Redacted] Monitored Monitored Monitored Unmonitored Intermittent

138 2005 [Redacted] [Redacted] [Redacted] Unmonitored Monitored Monitored Monitored—

monthly

Monitored—

monthly

139 2005 [Redacted] [Redacted] [Redacted] Unmonitored Monitored Monitored Monitored Unmonitored
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5.3 Recordkeeping procedures

SC&A reviewed the procedure used for obtaining exposure records for DR purposes for Pinellas 

claimants. SC&A found that occasionally all the claimants’ records and other information are not 

contained in the files that DOE forwards to NIOSH following a record request from NIOSH. In

2006, NIOSH found that its data captures provided additional data not always contained in the 

files sent by DOE. NIOSH has placed, and is still placing, these documents in the SRDB system. 

As briefly summarized on pages 80 and 81 of the ER, NIOSH uses the following procedure to 

obtain claimant exposure records, which include both external dosimetry and bioassay results. 

• NIOSH uses the SPEDELite search system to query the SRBD using claimant identifiers, 

such as name, social security number, and employee badge number. 

• The data from the search of the SRDB are entered into a file for the claimant. 

• NIOSH uses both the DOE files and the personnel exposure files during the claimant’s 

DR process.

• A Post Approval Dosimetry Evaluation Tracker System routinely identifies claims with 

new information. 

• NIOSH reviews the information to determine if the SPEDELite-linked information has 

any impact on the previously completed DR. If the new information has the potential to 

increase the previously reconstructed doses, NIOSH reworks the noncompensable DR. 

5.4 Documented communications with former workers

SC&A evaluated available documented communication (i.e., interview) summaries to determine 

if information existed pertinent to this SEC evaluation. These interviews were conducted by 

NIOSH and SC&A representatives in support of the TBD review. Appendix C to this review 

summarizes these interviews.

Observation 12: ER is consistent with interview records

SC&A reviewed all available documented communication (i.e., interview) records. The 

interviews reflect the full date range of work at Pinellas and encompass a broad range of 

professions. From the interviews, it is clear that site employees had a different experience with 

the health and safety policies at the site based on their role and job function. In general, the 

interviewed workers in physics, engineering, chemistry, and lab-related professions had 

experience with the site internal and external monitoring program. The recollections reported in 

the interviews, in general, are consistent with the NIOSH SEC ER. 
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6 Petitioner Concerns

The ER identifies and addresses nine different concerns extracted from the SEC petition. SC&A 

also examined the petition and categorized the same set of petitioner concerns into 12 different 

areas. Finally, the petitioners or their representatives made several additional submittals after the 

petition was received up to the time during which SC&A was preparing this review. The 

following subsections cover the entire set of petitioner concerns submitted to date and assess to 

what extent the ER adequately addresses each of them.

6.1 SC&A summary of petitioner concerns

SC&A reviewed the SEC petition and identified 12 general petitioner issues:

1. Former Pinellas workers were not monitored for all the radionuclides described in the 

table, “Pinellas Plant radioactive source material inventory status,” in Pinellas Plant

(c1994, PDF pp. 6–11).

2. Only a small fraction of the workers was monitored for radioactive exposures, and there 

was a failure to monitor all workers for all radionuclides, as described in the 24-hour

heavy metals urine tests.

3. Incidents described in the Tiger Team report (DOE, 1990a), the “Historical Report of 

Radiation Protection at GEND” (n.d.), and the labor site exposure matrices are not 

explicitly addressed in the ER, particularly the leaking Co-60 source.

4. Employees falsely identified urine samples.

5. The Tiger Team found deficiencies in detecting plutonium in the air and soil, and the 

majority of workers were never monitored for Pu-238/239.

6. Building 100 rooms were not self-contained, which could allow contaminated air to 

circulate.

7. The majority of the workers were not afforded occupational x-ray exams.

8. No comprehensive radiological surveys were done of areas with radioactive 

contamination, including certain rooms in Building 100, several hoods in Buildings 200 

and 800, and areas of Buildings 550 and 1000, as described in “Independent Technical 

Review of the Pinellas Plant” (DOE, 1994a).

9. There were insufficient environmental monitoring and recordkeeping, as described in 

“Pinellas Plant Feasibility Study” (DOE, 1994b).

10. DRs only reflect one location, job category, and work process and not the full range of 

employment locations held by workers.

11. Dosimetry records after 1981 were missing from all the DOL and DOE files.
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12. There were inconsistent monitoring and dosimetry recordkeeping, as described in the 

Tiger Team report (DOE, 1990a). 

SC&A found that each of these issues was addressed by NIOSH to various extents in the ER, 

although not always explicitly point by point, and are reviewed and discussed by SC&A 

throughout this SC&A review. The issues related to DR were not explicitly addressed, but the 

common practice employed by NIOSH for DR is to assign job titles, work location, and work 

processes for any given year or dosimetry exchange period based on the information provided by 

the claimant in the CATI or information in the EE’s employment records. If there is any 

uncertainty, the dose reconstructor often assigns the job title, work location, or work process that 

yields the highest doses. 

6.2 NIOSH response and SC&A review comments

SC&A examined the nine issues NIOSH summarized from the petition in sections 7.4.1 through 

7.4.9 of the ER as well as material subsequently submitted to assess if the petitioner issues are 

adequately addressed. Note that petitioners have been submitting additional material subsequent 

to the release of the ER and SC&A has been reviewing it as it came in up to the beginning of 

March 2023. 

6.2.1 Unmonitored exposures to Sr-90, Co-60, Tl-204, and uranium

The petitioners identify the radionuclides that are discussed in the TBD as potential sources of 

exposure for Pinellas workers, which include tritium, plutonium, depleted uranium, natural 

uranium, nickel-63, C-14, and Kr-85. The petitioners are concerned that this list of radionuclides 

is not complete and that Pinellas workers, particularly those workers who were not included in 

the monitoring program during employment, could have been exposed to additional 

radionuclides that were listed in exhibit 1, “Radioactive Material Inventory at the Pinellas Plant,” 

of the August 2020 revised petition ([Redacted], 2020b). This concern prompted a sample of 

former workers to undergo 24-hour urine tests in 2019 and 2020, the results of which are 

reproduced in appendix 1, “24-Hour Urine Heavy Metals Tests,” to the revised August 2020 

petition ([Redacted], 2020b). Regarding these test results, the petition states that several former 

employees tested positive for Sr-90, Co-60, Tl-204, uranium, and beryllium. The petitioners 

concluded the following from these test results: 

1. These exposures could have only come from employment at the Pinellas Plant. 

2. These positive results indicate that the “radiological characterization of the Pinellas Plant 

is incomplete and insufficient” ([Redacted], 2020b, p. 24). 

3. Employees who were not part of the monitoring program were not aware of their 

exposures. 

NIOSH responded by referencing the documents (exhibits 1–5) included with the petition: 

Exhibits 1 through 3 are excerpts from documents that note the presence of 

radioactive materials in and around the Plant, including strontium check sources, 

and sampling results from five Pinellas County sampling locations for radium, 

tritium, strontium. The presence of radioactive materials at Pinellas is not an 
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indication of an unmonitored exposure condition. Exhibits 4 and 5 are general 

references not specific to the Pinellas Plant that provide information about space 

isotopic-power systems and other isotopes useful for power generation. NIOSH 

found no indication of an unmonitored exposure condition at the Pinellas Plant 

related to strontium-90, cobalt-60, thallium-204, or uranium in these excerpts. . . . 

The metals urine analysis, purported to represent exposures to strontium-90, 

cobalt-60, and thallium-204, was not specific to these radionuclides; rather, the 

results were for elemental strontium, cobalt, and thallium, all of which occur in 

nature in a non-radioactive form. The presence of these elements, as indicated by 

chemical analysis, is not indicative of occupational exposure to the radioactive 

isotopes. The results of the uranium analysis were reported as either ‘none 

detected’ or <1.0 ng/ml. . . . 

Although the Pinellas Plant used other radionuclides, as discussed in Section 5.2.3 

[of the ER], they were mostly limited to sealed and plated check sources (Pinellas 

Plant radioactive, no date) and would not have presented a significant internal 

exposure hazard. The site used strontium and cobalt sealed sources that were kept 

under control and some level of radiological surveillance to ensure that the 

materials were well fixed, as indicated by the identification of the leaking Co-60 

source and indicated in routine health physics reports (Jech 1963, PDF p. 8). 

NIOSH’s review of Pinellas Plant records suggests Pinellas addressed such 

incidents of contaminated sources immediately when found, including assessing 

involved personnel. Consequently, contaminated sources are not evidence of 

unmonitored exposures [emphasis added]. [NIOSH, 2021a, p. 74] 

SC&A reviewed the petition exhibits, particularly the individual laboratory reports for the 24-

hour urine heavy metal tests, and found that eight former Pinellas employees participated in the 

screening. All the results for the elements of concern showed that they were either not detected 

or were within normal range. SC&A agrees with NIOSH’s comment that, in the case of cobalt, 

thallium, and uranium, the urine tests were screening for the elemental forms and not for the 

presence of the specific radioisotopes. Therefore, they do not indicate a known or assumed 

radiological exposure,6 and this result was within the normal background range. These 

conclusions were previously discussed in section 3.3.6 of this SC&A review. Refer to 

section 6.2.2 for a further discussion of other Pinellas health physics reports. 

6 The version of this screening report found in the petition for this individual shows Sr-90 results; however, the 

unredacted version of this screening report shows only elemental strontium. Otherwise, the reports appear to be 

identical. The source of this discrepancy could not be identified. Both reports show screening levels consistent with 

elemental strontium ([Redacted], 2020b, unredacted version).

6.2.2 Radiological incidents

The petition ([Redacted], 2020b, pp. 30–31) includes a list of incidents that occurred at Pinellas 

between 1963 and 1995 taken from the site exposure matrices (DOL, 2020). In addition, based 

on “information taken from microfilm records and the recollections of [Redacted], GEND

Health Physicist” (p. 31), the petitioners raised the concern that numerous incidents that occurred 
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during the years 1972 through 1982 were not documented in the site exposure matrices. The list 

of these incidents is included in appendix 2 of the petition. The petition also cites conclusions 

from the Tiger Team report, which describes various health and safety concerns at the Pinellas 

Plant.

NIOSH (2021a, pp. 75–76) responded as follows to the concerns raised by the petitioners 

regarding documented and undocumented radiological incidents:

Based on NIOSH’s review of available documentation, indications are that the 

Pinellas Plant was diligent about following-up on contamination-related incidents 

and personnel exposures, as documented in incident reports [GE 1972, PDF 

pp. 2–10; Holliday 1970–1979; Pinellas Plant 1976–1979; Pinellas Plant 1971–

1975] and Health Physics Investigation Reports [Jech 1963; GE 1963[a]; GE 

1983[a,b]; Holliday 1982a,b]. . . . 

The petition specifically cited three resources related to incidents:

• Tiger Team Assessment of the Pinellas Plant by the U.S. Department of 

Energy, Environment, Safety and Health [DOE 1990a]

• Health Physics Report: Historical Report of Radiation Protection

[Historical report of radiation, no date]

• Department of Labor’s Site Exposure Matrices: Incident Search by 

Related Item – Pinellas Plant by the U.S. Department of Labor [DOL, 

2020]

None of the three resources identified by the petitioners provided documentation 

of incidents that were unmonitored, unrecorded, or inadequately monitored or 

recorded. . . . 

The petitioners cited an event listed in Appendix A of the report Historical Report 

of Radiation Protection at GEND [Historical report of radiation, no date, PDF 

pp. 9–12] related to a leaking Co-60 source in 1961 as an example of an incident 

involving potential unmonitored exposure. The full citation was: “100 mCi . . . 

Co-60 source found leaking was corrected” [Historical report of radiation, PDF 

p. 10; Burkhart 1990]. A review of monthly health physics reports for 1961 

identified the source of the summarized information as the July 1961 report, 

which contained the following entry: “A routine survey revealed leakage of 

Health Physics’ 100 mc [sic] cobalt source. Corrective action was taken 

immediately” [Forest, 1961, PDF p. 4] 

Regarding radiological incidents, NIOSH (2021a, p. 76) concluded: 

The source documents do not provide any indication or evidence to indicate that 

the identified condition, which Pinellas immediately corrected, precipitated an 

unmonitored exposure condition to site personnel.
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SC&A reviewed the available incident and health physics investigation reports along with the 

site exposure matrices (DOL, 2020) and compiled a list of all documented events that involved a 

potential or actual radiological release, contamination, and/or personnel exposure, shown in 

appendix B to this review. SC&A also included the incident information given in Burkhart 

(1990, p. 3), which includes “a list of unusual events involving environmental releases or 

personnel or area contamination” for the years 1957 through 1989. Burkhart (1990, p. 1) 

explained that the source of the unusual event information was “obtained from microfilm records 

and also from the personal recollection of [Redacted], GE Neutron Devices (GEND) Health 

Physicist from [Redacted].” 

SC&A reviewed “Historical Report of Radiation Protection at GEND” and confirmed the 

description of the 100 mCi Co-60 source, which was “found leaking” and “was corrected”

(“Historical Report of Radiation,” n.d., PDF p. 10). SC&A also confirmed the statement in 

Forest (1961) that the leaking Co-60 source was detected in routine swipes and immediately 

corrected. SC&A agrees with NIOSH’s conclusions that these incidents were detected and 

immediately remedied and, therefore, did not result in a sitewide source of employee exposure. 

SC&A reviewed the CATI reports for information on EE involvement in radiological incidents, 

which is summarized in section 5.1 of this review. 

Observation 13: Pinellas Plant diligent in following up on contamination-related incidents 

and personnel exposures

Based on its review of the available incident information, SC&A concurs with NIOSH’s

conclusion that Pinellas Plant was diligent about following up on contamination-related incidents 

and personnel exposures. The reports show investigations into the causes of various incidents, 

and most (1) indicate that followup monitoring was performed for employees involved in the 

incidents and (2) provide recommendations to prevent the incidents from reoccurring. However, 

given the lack of bioassay records for the years 1988–1990 described in observation 4 

(section 4.3) and the issues surrounding bioassay noncompliance described in observation 5 

(section 4.3), observation 7 (section 4.4), and observation 9 (section 4.4), it is possible that the 

program may not have captured all the internal exposures related to contamination incidents. 

6.2.3 Plutonium

The plutonium exposure issue is discussed in depth in section 3.3.3 of this review. The following 

is a summary of the specific plutonium issue discussed in section 7.4.3 of the ER. The ER quotes 

the petition issue related to plutonium (NIOSH, 2021a, p. 76):

Despite encapsulation, levels of plutonium 238 and 239 were detected in both air 

and soil samples. While the Department of Energy noted that the levels of 

plutonium were at environmental background levels, it is important to note that 

the Tiger Team found sampling deficiencies where plutonium was concerned. 

([DOE, 1990a]) The majority of workers WERE NEVER monitored for 

plutonium 238/239 exposures ([redacted] 2020b, PDF p. 22). 
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NIOSH responds: 

The stack-sampling equipment monitors concentrations of radionuclides in 

effluent leaving the facility and is unrelated to the concentrations within the 

facility work areas. Accordingly, the finding has no bearing on the radiation 

exposure monitoring program associated with site employees. [NIOSH, 2021a, 

p. 76] 

SC&A does not necessarily agree with the blanket posit that stack-sampling results from plant 

effluent are unrelated to workplace conditions. However, SC&A documented the final resolution 

in the March 15, 2016, update to the issue resolution matrix (SC&A, 2016a, p. 4), which 

summarizes the plutonium issue as follows:

This was a concern early in the issues resolution process, when some potential 

exposure to plutonium (Pu) was not ruled out. Based on discussions at the 

October 2011 WG meeting [ABRWH, 2011], it was determined that the only 

source of potential intake was from handling of newly received triple 

encapsulated radio-thermal generators (RTGs). However, there was no surface 

contamination greater than 200 dpm (the rejection level), and NIOSH calculations 

show that to receive even 1 mrem annual dose would require handling thousands 

of RTGs in a year. Therefore there is no credible source of exposure [refer also to

Section 3.3 of this report]. In Revision 2 of TBD 5 [ORAUT, 2012; occupational 

internal dose], all Pu discussion was removed based on discussion at the October 

2011 WG meeting. If evidence of a positive exposure is discovered, NIOSH will 

need to develop a dose reconstruction (DR) methodology. 

In section 5.2.2 of the ER, NIOSH (2021a, p. 35) describes how the issue of plutonium exposure 

at Pinellas was closed by the Board’s Pinellas WG:

Out of an abundance of caution, workers assigned to the RTG project submitted a 

pre-operational 24-hour urine sample [Internal dosimetry practices 1983, PDF 

p. 2]. Those working with RTG sources submitted annual samples while assigned 

to the work [Internal dosimetry practices 1983, PDF p. 2]. The plutonium urine 

sampling program concluded in 1992. During meeting discussions [[ABRWH, 

2011, 2012, 2016]], the ABRWH Pinellas Plant Work Group determined there 

was no credible potential for personnel internal dose from activities involving 

plutonium [ORAUT [2016], PDF p. 12; [ABRWH] 2016]. 

SC&A reviewed the October 2011 (ABRWH, 2011) and February 2016 (ABRWH, 2016) 

transcripts of the Pinellas WG meetings and confirmed that the WG concluded that there is no 

potential internal plutonium exposure at Pinellas. As is discussed in section 3.3.3, environmental 

samples taken at Pinellas did not contain any plutonium results corresponding to the RTG 

characteristic isotopic ratio, indicating that plutonium releases from Pinellas operations had not 

been detected. Unless additional information becomes available, since the Pinellas WG has 

previously evaluated the issue and determined that there is no credible source of plutonium 

exposure, SC&A considers this issue resolved. 
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6.2.4 Duplicate samples

As quoted in the ER (NIOSH, 2021a, p. 77), the petitioners raised concerns of inaccurate 

monitoring results: “Health Physicist Holliday also reported that accurate monitoring was 

impacted by the fact that ‘Employees were found falsely identifying urine samples’ [[redacted] 

2020b, PDF p. 22].” 

NIOSH thoroughly researched this issue and found the source from a 1963 monthly health 

physics report: 

“During the past month it was discovered that some personnel were falsely 

identifying urine samples submitted for radioactivity analysis. This condition was 

brought to the attention of responsible supervision and efforts are being made to 

develop a technique to positively identify duplicate samples” (Forest 1963a, 

PDF p. 4). [Quoted in NIOSH, 2021a, p. 77] 

The ER states (NIOSH, 2021a, p. 77): 

The response to the “condition” was to develop a technique to positively identify 

duplicate samples. This indicates the condition did not impact the actual 

individual sample results [i.e., the results derived from the samples were not 

falsified or otherwise impacted]. The September Health Physics Report 

identifying the condition states “some personnel” were falsely identifying 

samples, which leads NIOSH to believe a simple misunderstanding by workers of 

the bioassay-sampling requirements is the most likely scenario. If the issue of 

“falsely identifying urine samples” was related to deliberately and incorrectly 

associating individual samples to a particular person and/or sample date, such a 

circumstance would not likely impact the overall population of sample results 

(which NIOSH has access to).

NIOSH believes that this issue came about as a misunderstanding and misdating of urine 

samples. For example, an employee could have provided two samples and submitted them both 

on the same day. In the case of duplicate samples, NIOSH stated that they would include the 

higher of the two results in a DR. Regarding duplicate samples, NIOSH (2021a, p. 78) concludes 

the following: 

The Pinellas Plant bioassay program records show that results seldom reached or 

exceeded the site action levels for the radionuclides under assessment. Therefore, 

it is unlikely that the Pinellas Plant failed to monitor any significant worker 

exposures. Because individual duplicate results won’t affect the population of 

results, NIOSH can use tritium bioassay data from this time period to determine 

an unmonitored dose approach, if needed. NIOSH concludes that the issue does 

not impact its ability to perform individual dose reconstructions for all 

members of the NIOSH-evaluated class [emphasis added]. 

SC&A reviewed the September 1963 health physics report (Forest, 1963a) and confirmed the 

concerns raised by the Pinellas Health Physics department during this month regarding “falsely 

identified” urine samples. In the same discussion, Forest (1963a, PDF p. 4) refers to these as 
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“duplicate samples.” Therefore, NIOSH assumes that the samples were not deliberately 

associated with the wrong individual but rather duplicate measurements from the same 

individual. SC&A also reviewed the October 1963 health physics report (Forest, 1963b) and 

found that the falsely identified urine sample issue was not discussed again. Therefore, it is 

difficult to interpret and assess the potential effect the issue has on DR feasibility. If the samples 

were, in fact, duplicates, SC&A agrees that those samples would not affect NIOSH’s ability to

perform DRs for members of the SEC class nor their ability to construct a co-exposure model. 

6.2.5 Radioactive materials in Building 100

The petition discusses several concerns with emissions in Building 100, the “main” building, 

which contained many of the radioactive areas ([Redacted], 2020b, p. 22): 

In the US Department of Energy (June 1997) Environmental Baseline Report

[DOE, 1997], mention is made of the potential for unconfined radioactive 

materials or emissions, resulting from Radioactive Materials Management Area 

(RMMA) located in Building 100 [DOE, 1997, p. 3-1]. . . . 

Also not taken into consideration is the fact that the rooms within Building 100 

were not self-contained. In other words, the rooms were wide open so any 

radioactive materials that were in the air, would be circulated throughout the 

entire plant. 

The ER addresses RMMA designation of various areas of the plant, particularly Building 100 

(NIOSH, 2021a, p. 78): 

The reference to the RMMA designation in Building 100 comes from the 1995 

report, Moratorium Documentation Manual for the Pinellas Plant. The purpose of 

this document is to identify areas where dispersible radioactive material is present 

in order to control the generation of mixed hazardous and radioactive waste 

[Ohlweiler, 1995, PDF p. 16]. Designation as an RMMA in and of itself does not 

relate to the potential for unmonitored radiological exposure to site personnel. 

NIOSH is aware of the designation of areas within Building 100 as RMMAs and 

has documented this in Table 2-3 of Pinellas Plant – Site Description [ORAUT

2011b, PDF p. 31]. The document does not provide any information specific to a 

lack of containment of radiological materials or a lack of radiological monitoring 

within the area identified as an RMMA within Building 100. 

The ER responds to the issue of emissions and proper ventilation in Building 100 and notes the 

presence of adequate ventilation and hoods in the building (NIOSH, 2021a, p. 79): 

Pinellas designed and constructed buildings with ventilation systems, fume hoods, 

and gloveboxes to minimize inhalation uptakes by workers [[SC&A, 2006], PDF 

p. 28]. The Pinellas Plant conducted routine surface and air monitoring in work 

areas containing radioactive material [ORAUT [2016], PDF pp. 14–16], as 

discussed in Sections 6.1.2 and 6.2.2. Design features (e.g., ventilation systems 

and fume hoods), in conjunction with the radiological monitoring program in 
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place, would preclude unidentified and unmonitored exposure of general 

employees in areas that were “not self-contained” [emphasis added]. 

SC&A reviewed Ohlweiler (1995), which identifies the areas of the Pinellas Plant that have been 

designated as RMMAs, several of which are in Building 100. Ohlweiler (1995, p. 7) defines 

RMMA as follows: 

An area in which the potential exists for contamination because of the presence of 

unencapsulated or unconfined radioactive material, or of beams or other sources 

of particles (neutrons, protons, etc.) capable of causing activation. 

Ohlweiler (1995, p. 1) summarizes the handling of potentially radioactive waste as follows: 

The Pinellas Plant is dedicated to the goals of the DOE-led Performance 

Objective for the Certification of Hazardous Waste. The procedures following 

will be applied to all wastes that originate or have been stored in a Radioactive 

Materials Management Area (RMMA). These procedures effectively demonstrate 

the Pinellas Plant’s ability to correctly determine whether a waste has DOE-added 

radioactivity.

SC&A reviewed the TBDs referenced by NIOSH regarding the issue of adequate ventilation in

Building 100. The following description of RMMAs is taken from section 2.6.1 of the site 

description TBD (ORAUT, 2011b, p. 28):

Radioactive materials in Building 100 were used in the production, manufacture, 

storage, and testing of various weapons components. Multiple areas were 

considered Radioactive Material Management Areas (RMMAs), which indicated 

the possible presence of unconfined radioactive materials or emissions. 

The following is a description of contamination control at Pinellas from section 5.4.1 of the 

internal dose TBD (ORAUT, 2016, pp. 13–14):

The monthly Health Physics Reports for the Pinellas Plant indicate that 

contamination monitoring for tritium was performed on a routine basis from the 

beginning of operations at the Pinellas Plant [GE 1957–1967, GE 1957–1973, 

GE 1963[b], GE 1967). Work areas and personnel were checked for 

contamination on a routine basis. Any significant personnel contamination that 

could have gone undetected from contamination surveys would most likely have 

been identified through the tritium bioassay program. The monthly reports also 

indicated that whenever contamination levels were greater than the contamination 

control limits, decontamination of those areas was initiated.

In addition, section 5.4.2 of the internal dose TBD summarizes air monitoring as follows 

(ORAUT, 2016, p. 14): “Monitoring for airborne tritium radioactivity was performed on a 

routine basis from the beginning of operations at the Pinellas Plant (GE 1957–1973).” 
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SC&A agrees with NIOSH’s conclusion that the routine air and surface monitoring at Pinellas, 

including in Building 100, would have identified airborne contamination. Observation 8 in 

section 4.4 discusses the issue of contamination controls presented by the Tiger Team.

6.2.6 Employer-required chest x-rays

The petition raises concerns that the majority of the former Pinellas employees were not given 

annual chest x-rays. NIOSH (2021a, p. 79) responded to the concern as follows: 

DOE provides records of medical X-rays performed for individual claimants. 

NIOSH detailed the interpretation of, and assumptions related to medical X-rays 

in ORAUT-TKBS-0029-3, Pinellas Plant – Occupational Medical Dose. Current 

NIOSH dose reconstruction guidance assigns medical doses based on individual 

X-ray examinations recorded in the submitted medical records. When no X-ray 

examination records are available for an individual, the dose reconstructor 

assumes that an annual PA [posterior-anterior] chest X-ray was administered, in 

accordance with the Pinellas Plant – Occupational Internal Dose[7] site profile 

document [ORAUT 2011c, PDF p. 10]. NIOSH notes that if employees were 

not given chest X-rays, the approach described above would overestimate 

radiation doses to those employees [emphasis added]. 

7 “Internal” in the TBD title appears to be an error, as the document referenced is the medical dose TBD. 

SC&A notes that medical x-rays are a source of occupational exposure rather than a monitor of 

it. SC&A agrees with NIOSH’s conclusion that the guidance in the occupational medical dose 

TBD (ORAUT, 2011c)—that if there are no x-ray examination records for an employee then the 

DR would include occupational medical doses from annual chest X-rays—would provide an 

overestimate of occupational medical doses.

6.2.7 Lack of radiological surveys

The petition references the “Independent Technical Review of Pinellas Plant” (DOE, 1994a) and 

indicates that this report notes that certain rooms and buildings were contaminated and that 

radiological surveys had not been performed for these areas: 

Certain rooms in Building 100, several hoods in Buildings 200 and 800, and areas 

of Buildings 550 and 1000, have some radioactive contamination. No 

comprehensive radiological surveys have been completed for these buildings. . . . 

Building 100 laboratories and processes handle or have handled radioactive 

isotopes. There is radioactive contamination in some hoods and associated duct 

work. A precise, accurate survey of location, quantity and type of radiological 

contamination does not exist. [[Redacted], 2020b, p. 22] 

NIOSH (2021a, p. 79) responded in the ER by citing the intended purpose of the referenced 

document: 
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The purpose of the cited Independent Technical Review of the Pinellas Plant

document is to document the transition of the Pinellas Plant from operations to 

either community-developed reuse or safe deactivation leading to 

decontamination and decommissioning [DOE 1994[a], PDF p. 6]. The cited 

Technical Review is unrelated to the potential for unmonitored worker 

exposure during Pinellas Plant activities [emphasis added]. 

SC&A reviewed the cited “Independent Technical Review of the Pinellas Plant” (DOE, 1994a) 

and concurs with NIOSH that the purpose of the document is for either community-developed 

reuse or safe deactivation leading to decontamination and decommissioning. The petitionerquoted sections of this report are in reference to establishing a comprehensive baseline to 

minimize DOE liabilities. SC&A agrees that is unrelated to establishing the exposure potential of 

unmonitored workers. 

6.2.8 Environmental monitoring record keeping

The petitioners ([Redacted], 2020b, p. 22) quoted “Pinellas Plant Feasibility Study: Final 

Report” (DOE, 1994b) on environmental monitoring deficiencies: “Typical of many DOE 

facilities, meticulous environmental monitoring and records keeping did not take place until the 

early to mid 1970’s. Prior to that, monitoring and records keeping was not very thorough.” 

NIOSH (2021a, p. 80) responded: 

The complete citation includes the following statement: “However, after 

reviewing plant publications, interviewing key personnel, and checking the 

existence, accessibility, and quality of documents important to dose 

reconstruction at the plant, we have concluded that a dose reconstruction is 

feasible” [[DOE, 1994b], PDF p. 124]. The scope of the document relates to the 

reconstruction of exposure to members of the public, not site employees, and 

is unrelated to the potential for unmonitored worker exposure during site 

activities [emphasis added]. 

SC&A reviewed the “Pinellas Plant Feasibility Study” (DOE, 1994b) and confirmed that the 

report is an analysis of the available environmental data in the vicinity of the Pinellas Plant. The 

report states that environmental monitoring of site radiological emissions has been performed 

and recorded since 1975. DOE (1994b, p. 1) concludes: 

The United States Public Health Service Centers for Disease Control and 

Prevention (CDC), in assisting HRS, has determined that sufficient radiological 

data exist by which a dose reconstruction can be done. A dose reconstruction can 

provide an estimate of how much radiological exposure someone living in the 

vicinity of the Pinellas Plant may have suffered from environmental releases. 

SC&A agrees with NIOSH’s conclusions that this document pertains to exposure to the general 

public and not to employee occupational exposures. 
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6.2.9 Missing dosimetry records

The ER quotes the SEC petition as follows (NIOSH, 2021a, p. 80): 

“A small number of workers were monitored for radiologic exposures, although 

inconsistently, and some were never monitored for such exposures. For those that 

were monitored, their dosimetry records only included information until 1981. 

Dosimetry records beyond 1981 were missing from all of their DOL and DOE 

files that were examined [[redacted] 2020b, PDF p. 24].” 

NIOSH’s (2021a, pp. 80–81) ER responded as follows: 

NIOSH reviewed ALARA reports, which are available from 1986 through 1995, 

and that review showed the site monitored 1,772 workers over those 10 years. 

NIOSH has estimated an average workforce size of 1,500 for all of those ten 

years, primarily from reviewing the annual site environmental reports and 

counting the number of employees listed on rosters. Dividing the number of 

employees monitored by the number of workers for 10 years indicates that the site 

monitored approximately 12% of employees for tritium intakes from 1986 

through 1995. Therefore, in response to the claim the Pinellas Plant 

monitored a small number of workers for radiological exposures, NIOSH 

agrees that this could be considered a small number of workers but finds that 

the monitoring practices at the Pinellas Plant were based on exposure 

potential rather than plant population and that adequate dosimetry records 

are available for dose reconstruction [emphasis added]. . . . 

In 2006, NIOSH became aware it was not receiving all of the dosimetry records 

from DOE for some Pinellas Plant claimant files. Following this discovery, 

NIOSH worked with DOE to locate additional dosimetry records at archival 

locations across the DOE complex; NIOSH uploaded that additional data to the 

SRDB. NIOSH has completed linking this captured dosimetry data in the SRDB 

to individual NOCTS claimant files via the SPEDELite process.

It should be noted that NIOSH found that compliance with the bioassay program did increase 

following the publication of the DOE Tiger Team report in 1990 (DOE, 1990a). However, 

neither the total measured internal dose nor the average individual internal dose increased 

following the increase in compliance, which indicates that most of the exposures have been 

accounted for in the bioassay data during this timeframe. In addition, NIOSH states the following 

in section 7.1.3 of the ER regarding the internal dosimetry data (NIOSH, 2021a, p. 65): 

The Plant monitored those with the highest internal-exposure potential the most 

often, i.e., on a daily or weekly frequency. This group of workers was more 

compliant with the sampling program, according to the 1990 Tiger Team report. 

Therefore, the dataset available to NIOSH for determining an unmonitored dose 

approach would likely be biased high. 

SC&A currently does not have access to the NOCTS database to review individual claimant files 

for this ER review. A review of the dosimetry data in the claimant files would allow SC&A to 
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confirm the presence of sufficient dosimetry data for the SEC period. However, as described in 

section 4.1 of this review, SC&A has reviewed dosimetry data from 13 SRDB documents and 

has not found indications that there are issues with exposure records that would prevent DR 

feasibility for the SEC period 1957–1990. 

6.3 Additional petitioner concerns submitted following the December 2022 

Board meeting

The December 2022 Board meeting had a session on the Pinellas petition, the ER, and SC&A’s 

progress in evaluating the ER. The petitioners submitted additional materials after that meeting, 

which were reviewed by SC&A and are addressed in the following subsections.

6.3.1 “Leaking plutonium” submitted January 16, 2023

The petitioners’ representative submitted (Petitioners’ Representative, 2023a) a one-paragraph

Tampa Bay Times article from December 9, 1994 (updated October 8, 2005), “Department of 

Energy Says Don’t Worry About Plutonium Leak from Plant.” The article references plutonium 

being stored poorly at other weapons production facilities but quotes a DOE representative who

indicates that Pinellas “used relatively little plutonium and has nearly none left” (“Department of 

Energy Says Don’t Worry,” 1994/2005). 

In addition to this article, the representative’s memorandum (Petitioners’ Representative, 2023a) 

cites two documents, DOE (1992) and Weaver (1996), indicating that plutonium heat sources 

were removed from the site in February 1991. Because the DOE representative quoted in the 

Tampa Bay Times article indicated that there was “nearly none left” on site, the memorandum 

draws the erroneous conclusion that there was leaking plutonium on site because there was a 

non-zero quantity of plutonium remaining in 1994. This conclusion is not justified. The presence 

of “poorly stored and at risk of leaking” plutonium at other DOE facilities is not evidence of 

these conditions existing at Pinellas. Both references cited by the petitioners’ representative 

indicate that plutonium was removed in 1991 when the RTG product line was discontinued. This 

reference is to the production quantities of plutonium. As alluded to in the memorandum, DOE

(1992, p. 4-8) indicated that “There still exists on-site standards used to calibrate ECL 

[Environmental Chemistry Laboratory] analytical instrumentation and used in calorimetry.” 

Additionally, elevated external doses during RTG production are not indicative of leaking 

plutonium. Elevated external doses in this instance were caused from being near plutonium. If 

plutonium were leaking, evidence of plutonium contamination would have been found in swipe 

samples, bioassay sampling, or environmental monitoring. 

6.3.2 Letter in reference to multiple myeloma study

The petitioners’ representative submitted a second memorandum to the Board on January 16, 

2023, taking issue with Pinellas not being included in a 1997 University of North Carolina at 

Chapel Hill (UNC) study of multiple myeloma in nuclear workers (Petitioners’ Representative, 

2023b). The memorandum included a copy of the study (UNC, 1997). This was not new 

information, since the petitioners had previously provided the study to NIOSH on December 9, 

2020, according to the ER (p. 29). 
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The UNC (1997, p. 3) study indicates that “there was no documented evidence of radiation 

exposures” at Pinellas. This statement is based on UNC’s (1997) cited personal communication 

with Donna Cragle in 1993, who was an ORAUT Senior Vice President and Director. SC&A 

agrees with the petitioners’ representative (2023b) that this statement is inaccurate. SC&A was 

not able to locate a copy of this personal communication to verify the cited statement. Without 

this communication, it is not possible to verify the author of the UNC study correctly interpreted

statements made by Ms. Cragle. 

In any event, Pinellas not being included in the 1997 UNC study has no impact on the SEC 

feasibility determination.

6.3.3 History of radiologic incidents

The petitioner’s representative provided a copy of the “Historical Report on Radiation Protection 

at GEND” (n.d.). This copy was a duplicate of SRDB 12026. SC&A discusses these incidents 

and others at the site in appendix B. 

6.3.4 Supplemental information provided December 8, 2022

In conjunction with the December 2022 Board meeting, a worker advocate submitted a letter 

with supplemental information related to the “petitions that did not qualify and the petition that 

did qualify” for evaluation (Worker Advocate, 2022, p. 2). The letter cites 42 USC § 7384o(b)

and 42 USC § 7384q(a) to argue that “the Advisory Board must be assured that the data from the 

Pinellas Plant is sufficient and accurately addressing the maximum dose received at the facility. 

The Advisory Board must be assured that the guidelines and the methods that are in the 

regulations are followed” (Worker Advocate, 2022, p. 1). 

NIOSH and the Advisory Board are governed by the requirements of the Energy Employees 

Occupational Illness Compensation Program Act of 2000, as amended, 42 USC § 7384-7385 

(EEOICPA), and 42 CFR Part 83. The regulation at 42 CFR 83.13(c)(1)(i) states that “Radiation 

doses can be estimated with sufficient accuracy if NIOSH has established that it has access to 

sufficient information to estimate the maximum radiation dose, for every type of cancer for 

which radiation doses are reconstructed, that could have been incurred in plausible circumstances 

by any member of the class, or if NIOSH has established that it has access to sufficient 

information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose” (emphasis added).

The letter presents seven exhibits as supplemental evidence (Worker Advocate, 2022). The 

following sections 6.3.4.1–6.3.4.7 discuss each exhibit. 

6.3.4.1 Exhibit 1

This exhibit is a quote from Dr. Graham F. Peaslee, Professor of Physics at the University of 

Notre Dame, that gives an opinion on DR feasibility. This is not a technical comment and, 

therefore, is not within the scope of SC&A’s purview for this review. 

6.3.4.2 Exhibit 2

This exhibit quotes finding 2 from SC&A’s (2006) site profile review, which was discussed 

extensively by the Pinellas WG. NIOSH had developed a new process for assigning dose to 
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metal tritide exposures. It was evaluated by SC&A (2016c) and discussed by the Pinellas WG

during their February 11, 2016, meeting. During that meeting, the Pinellas WG accepted 

NIOSH’s proposed method (ABRHW, 2016, p. 114). The methodology for assigning doses from 

metal tritides is discussed extensively in section 3.3.1 of this ER review. 

Additionally, the exhibit quotes from several places in SC&A’s (2016c) review of NIOSH’s DR 

methodology for SMTs. SC&A notes that additional Pinellas records, including health physics 

reports, have been located since the issuance of SC&A (2016c). The exhibit concludes that

“Maximum accumulated radiation exposure in 1962 was greater than 300 mrem, not 100 mrem” 

(Worker Advocate, 2022, p. 2). SC&A agrees that the December 1962 health physics report 

shown in appendix A to SC&A (2016c) shows that the maximum annual external dose was 

>300 mrem (p. 32). It also shows the average annual dose was approximately 20 mrem. The 

NIOSH justification for the 100 mrem default annual dose is in attachment B to ORAUT-TKBS0029-6, revision 02 (ORAUT, 2017). Workers who were monitored for external exposures are 

assigned dose based on their monitoring records. 

6.3.4.3 Exhibit 3

This exhibit quotes from several places in earlier revisions of ORAUT-TKBS-0029-6, the 

occupational external dose TBD. The current version is revision 02, dated December 11, 2017 

(ORAUT, 2017). No new information is provided. Attachment B to ORAUT-TKBS-0029-6, 

revision 02, provides a basis for the 100 mrem default external dose assumption for unmonitored 

workers. The Pinellas WG previously approved this methodology. 

6.3.4.4 Exhibit 4

This exhibit quotes from several places in the “Pinellas Plant Environmental Baseline Report”

(DOE, 1997) on known radioactive materials on site. This reference is already cited by NIOSH 

in the SEC ER and provides no new information. 

6.3.4.5 Exhibit 5

This exhibit provides critical opinions about a former NIOSH employee. This is not a technical 

comment and, therefore, is outside the scope of SC&A’s purview for this review. 

6.3.4.6 Exhibit 6

This exhibit indicates that the DOL Division of Energy Employees Occupational Illness & 

Compensation Site Exposure Matrix (DOL DEEOIC SEM) lists 17 radionuclides and associates

uranium with processes and areas that uranium was located in and used at Pinellas. No new 

information is contained in this material. Uranium is discussed in section 3.3.2 and throughout 

this SC&A review. 

6.3.4.7 Exhibit 7

This exhibit makes the following two statements (Worker Advocate, 2022, p. 4): 

..... Pinellas encapsulated products as well as received encapsulated products. 

NOTE NRC states that radiation can still come from encapsulated products.
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..... The radioactive heat source (RTG) is produced by Los Alamos National 

Scientific Lab while the thermal-to-electric energy converter is produced 

entirely within the Pinellas Plant

This exhibit contains no new information. SC&A agrees that radiation can come from 

encapsulated products. In the case of Pinellas, the plutonium was triply encapsulated. This poses 

an external exposure hazard, which NIOSH accounts for in the SEC ER. 

6.3.5 Requested review of cancer incidence study of Pinellas County included in 

appendix 5 to DOE 1994b

A petitioner representative sent an email on January 31, 2023, requesting that the Board review 

appendix 5, “Cancer Incidence Patterns in Pinellas County: 1981–1990,” to the “Pinellas Plant 

Feasibility Study” (DOE, 1994b). The following is an excerpt from the abstract of that appendix: 

The cancer incidence patterns among the Pinellas County population where a 

DOE facility is located were examined for the period 1981 to 1990 using the 

Florida Cancer Data System. During this period, there were a total of 60,522 cases 

of cancer diagnosed in Pinellas County. . . . 

Consistently high incidence rates among all four race-gender groups were found 

for colorectal cancer including colon cancer and rectal cancer separately. 

Consistently low incidence rates among all four race-gender groups were found 

for liver cancer. Some reproductive organ cancers (female breast, cervix uteri, 

testes) were high in their gender groups. These results should be interpreted with 

caution because of the limitations of this type of study. [DOE, 1994b, p. 127] 

Limitations of this study described by the authors include:

• lack of cancer incidence data prior to 1981 

• dramatic demographic changes in Pinellas County, Florida, since 1956 

• lack of environmental monitoring information, which could include effects of other 

industrial contamination to the Pinellas population over the years 

• no information on socioeconomic status, smoking history, or resident history 

• possibility the observed cancer incidence rates of Pinellas population are due to stochastic 

effects

The study does not specifically include employees of the Pinellas Plant and does not draw any 

conclusions about cancer incidence and radiation exposure to the population. Regardless, the 

cancer incidence rates of Pinellas County residents from this study would not affect NIOSH’s 

ability to reconstruct doses with sufficient accuracy. 

The petitioners’ representative requested special attention be paid to the following points, as 

quoted by the Designated Federal Official (DFO) in the March 3, 2023, email transmitting the 

request to the Board: 
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• “The report shows the overall cancer rates are slightly increased in 

Pinellas County; however, cancer rates are significantly elevated in certain 

populations for the thirty-eight (38) cancers examined. 

• “In Appendix 5, one (1) potential limitation of the study and of importance 

to the Pinellas SEC is limitation identified by the authors involving 

radiation exposure, ‘ ... lack of radiation exposure data and other chemical 

exposure information, and lack of knowledge concerning’ (27).

• “ ... there is an acknowledgement in the report of lack of data regarding 

radiation exposure in the facility which has a significant impact on the 

ability of DCAS to reconstruct doses. 

• “Moreover, the document provides data showing there were indeed 

releases of radioactive materials from the plant during its operation – 

releases that have been denied as having occurred,” according to [name 

redacted].

It is not possible to draw causality conclusions from the study (DOE, 1994b). There is no 

evidence supporting a conclusion that the elevated cancer incidences rates were caused by 

radiation exposure from Pinellas Plant. Table 5-9 of the Pinellas Plant feasibility study (DOE, 

1994b) estimates that the highest annual dose (1973–1991) to a member of the public from 

releases of radioactive material from the plant at the site boundary was 0.098 mrem from 1990. 

This dose is significantly less that the minimum dose of 1 mrem annual dose considered in DRs

under EEOICPA. 

SC&A notes that the NIOSH ER, the Pinellas TBDs, and this review all acknowledge releases of 

tritium and krypton gas. These releases are documented. 
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7 References

Advisory Board on Radiation and Worker Health, Work Group on the Pinellas Plant SEC. 

(2009). Thursday, June 11, 2009 [Transcript]. SRDB Ref. ID 183079 

Advisory Board on Radiation and Worker Health, Work Group on Pinellas. (2011). Thursday 

October 13, 2011 [Transcript]. SRDB Ref. ID 183137 

Advisory Board on Radiation and Worker Health, Work Group on Pinellas. (2012). Monday 

November 19, 2012 [Transcript]. SRDB Ref. ID 183138 

Advisory Board on Radiation and Worker Health, Pinellas Plant Work Group. (2016). Thursday 

February 11, 2016 [Transcript]. SRDB Ref. ID 187124 

Advisory Board on Radiation and Worker Health, Subcommittee for Procedure Reviews. 

(2021a). Wednesday, November 3, 2021 [Transcript of teleconference meeting]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2021/sctr110321-508.pdf

Advisory Board on Radiation and Worker Health. (2021b). 143rd meeting Wednesday, 

December 8, 2021 [Transcript of teleconference meeting]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2021/tr120821-508.pdf

Argonne National Laboratory. (2005). Krypton [Human Health Fact Sheet, August 2005]. 

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Biedermann, C. (1994, March 9). Historical tritium inventory [Memorandum, Martin Marietta 

Specialty Components]. SRBD Ref. ID 012020 

Burkhart, R. A. (1990). Historical report on radiation protection at GE Neutron Devices (GEPPEV-1126). SRDB Ref. ID 012026 

Burkhart, R. A. (1995, March 23). Status of standard leak contamination incident investigation

[Interoffice memorandum, Martin Marietta]. SRDB Ref. ID 013503 

Department of Energy says don’t worry about plutonium leak at plant. (1994, December 9; 

updated 2005, October 5). Tampa Bay Times. 

Department of Health and Rehabilitative Services (HRS), State of Florida. (1995). Department of 

Energy oversight program Pinellas Plant: Environmental radiological measurements, January 

1994 - December 1994 annual report. SRDB Ref. ID 187491 

First plutonium delivered onsite. (n.d.). [Single page scanned from project box number 

ATL000604, folder title “Support of HRS [illegible],” Document 240000764]. SRDB Ref. 

ID 012022 

Forest, E. P. (1961). Health physics’ report July - 1961. SRDB Ref. ID 182941 

Forest, E. P. (1963a). Health physics report September - 1963. SRDB Ref. ID 182940 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Forest, E. P. (1963b). Health physics’ report [November 22,1963]. SRDB Ref. ID 182939 

General Electric Company. (1957–1967). Collection of health physics reports for 1957–1967. 

SRDB Ref. ID 015179 

General Electric Company. (1957–1973). Collection of health physics reports for 1957–1973. 

SRDB Ref. ID 027095 

General Electric Company. (1963a). Radioactive incident investigation report no. 3 [Pinellas 

Plant, April 17, 1963]. SRDB Ref. ID 187682 

General Electric Company. (1963b). Collection of health physics reports for 1963. SRDB Ref. 

ID 133580 

General Electric Company. (1967). Health Physics report for December 1967. SRDB Ref. 

ID 133582 

General Electric Company. (1972). Radiation exposure [name redacted] May 15, 1972. 

Compilation of correspondence relating to exposure incident. SRDB Ref. ID 013196 

General Electric Company. (1983a). Report of investigation tritium release incident January 5, 

1983. General Electric Company Neutron Devices Department. SRDB Ref. ID 187685 

General Electric Company. (1983b). Tritium release Area 108. General Electric Company 

Neutron Devices Department. SRDB Ref. ID 187686 

General Electric Company Neutron Devices Department (GENDD). (1986). Pinellas Plant facts

(GEPP-CB-986). SRDB Ref. ID 088851 

Harder, U. M. (1991). 1990 annual ALARA program report for ionizing radiation. Pinellas 

Environmental Health & Safety Programs. SRDB Ref. ID 182932 

Historical report of radiation protection at GEND. (n.d.). [Document included as part of the

August 2020 SEC-00256 petition application]. SRDB Ref. ID 019647 

Holliday, J. N. (1970–1979). 1970s incident reports involving tritium. Compilation of incident 

reports, Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron Devices 

Department. SRDB Ref. ID 012804 

Holliday, J. N. (1982a). Status report – recommendations tritium release – Area 108, September 

1, 1982. General Electric Company Neutron Devices Department. SRDB Ref. ID 187684 

Holliday, J. N. (1982b). Tritium release Area - 108, September 1, 1982. General Electric 

Company Neutron Devices Department. SRDB Ref. ID 187683 

HP incidents at GEND. (1965–1975). Compilation of incident reports. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. SRDB Ref. ID 026399 
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NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

HP investigation reports. (1980–1986). Compilation of incident reports. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. SRDB Ref. ID 012808 

Internal dosimetry practices. (1983). SRDB Ref. ID 012177 

Jech, J. J. (1963, March 25). Health physics report - 1962 [Correspondence to R. F. Wilson].

SRDB Ref. ID 187681 

National Institute for Occupational Safety and Health. (2015). Review of NIOSH’s current 

approach to reconstruction of insoluble tritium particulate at the Pinellas facility (rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/dps/dc-pinellastrit-r0.pdf

National Institute for Occupational Safety and Health. (2007). External dose reconstruction 

implementation guideline (OCAS-IG-001, rev. 3). SRDB Ref. ID 038864 

National Institute for Occupational Safety and Health. (2021a). Petition SEC-00256, Pinellas 

Plant: Special Exposure Cohort (SEC) petition evaluation report (ER). 

https://www.cdc.gov/niosh/ocas/pdfs/sec/pinellas/pinellaser-256-r0-508.pdf

National Institute for Occupational Safety and Health. (2021b). SEC-00256 Pinellas Plant 

evaluation report [PowerPoint presentation at December 8, 2021, ABRWH meeting]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/pres/2021/dc-pinellassec256-120821-508.pdf

National Institute for Occupational Safety and Health. (2021c). Number of Pinellas claimants by 

year and those with tritium data [Excel workbook, August 13, 2021]. SRDB Ref. ID 188333 

Oak Ridge Associated Universities Team. (2005a). Pinellas Plant – Introduction (ORAUTTKBS-0029-1, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine1.pdf

Oak Ridge Associated Universities Team. (2005b). Pinellas Plant – Site description (ORAUTTKBS-0029-2, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine2.pdf

Oak Ridge Associated Universities Team. (2005c). Pinellas Plant – Occupational environmental 

dose (ORAUT-TKBS-0029-4, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine4.pdf

Oak Ridge Associated Universities Team. (2005d). Pinellas Plant – Occupational internal dose 

(ORAUT-TKBS-0029-5, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine5.pdf

Oak Ridge Associated Universities Team. (2005e). Pinellas Plant – Occupational external dose 

(ORAUT-TKBS-0029-6, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine6.pdf

Oak Ridge Associated Universities Team. (2006). Pinellas Plant – Occupational medical dose 

(ORAUT-TKBS-0029-3, rev. 00 PC-1). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine3a.pdf

Oak Ridge Associated Universities Team. (2011a). Pinellas Plant – Introduction (ORAUTTKBS-0029-21, rev. 01). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine1-r1.pdf
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Oak Ridge Associated Universities Team. (2011b). Pinellas Plant – Site description (ORAUTTKBS-0029-2, rev. 02). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine2-r2.pdf

Oak Ridge Associated Universities Team. (2011c). Pinellas Plant – Occupational medical dose 

(ORAUT-TKBS-0029-3, rev. 01). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine3-r1.pdf

Oak Ridge Associated Universities Team. (2011d). Pinellas Plant – Occupational environmental 

dose (ORAUT-TKBS-0029-4, rev. 01). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine4-r1.pdf

Oak Ridge Associated Universities Team. (2012). Pinellas Plant – Occupational internal dose

(ORAUT-TKBS-0029-5, rev. 02). https://www.cdc.gov/niosh/ocas/pdfs/arch/pine5-r2.pdf

Oak Ridge Associated Universities Team. (2013). Documented communication with [redacted], 

June 18, 2013. SRDB Ref. ID 127111 

Oak Ridge Associated Universities Team. (2016). Pinellas Plant – Occupational internal dose 

(ORAUT-TKBS-0029-5, rev. 03). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine5-r3.pdf

Oak Ridge Associated Universities Team. (2017). Pinellas Plant – Occupational external dose 

(ORAUT-TKBS-0029-6, rev. 02). https://www.cdc.gov/niosh/ocas/pdfs/tbd/pine6-r2.pdf

Oak Ridge Associated Universities Team. (2020). Calculation of dose from intakes of special 

tritium compounds (ORAUT-OTIB-0066, rev. 01). 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t66-r1-508.pdf

Ohlweiler, F. (1995). Moratorium documentation manual for the Pinellas Plant. (MMSCESH-0016, rev. G, January 12, 1995). SRDB Ref. ID 013505 

[Petitioners’ Representative]. (2023a, January 16). New information for your consideration

[Memorandum to Advisory Board on Radiation and Worker Health]. 

[Petitioners’ Representative]. (2023b, January 16). New information for your consideration: 

Pinellas Plant not included in study of multiple myeloma because expert claims there was no 

radiation at plant [Memorandum to Advisory Board on Radiation and Worker Health]. 

Phillips, D. (1975, May 19). Suggestion no. 10582 [Internal GEND memorandum on uranium 

bed incident, Pinellas Plant]. SRDB Ref. ID 013125 

Pinellas Plant. (1950s–1990s). Dose records for [redacted] through [redacted]. SRDB Ref. 

ID 183490 

Pinellas Plant. (1971–1975). 1970s incident reports. Compilation of incident reports with 

different dates. SRDB Ref. ID 012805 

Pinellas Plant. (1976–1979). Contamination and exposure incidents at GEND. Compilation of 

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

GE Neutron Devices. (1990). Pinellas Plant facts (GEPP-SP-1157, November 1990). SRDB Ref. 

ID 009967 

Pinellas Plant. (1992). 1991 Annual ALARA program report for ionizing radiation. SRDB Ref. 

ID 182933 

Pinellas Plant. (1992–1994). Natural uranium glass concerns and related material. SRDB Ref. ID 

013204 

Pinellas Plant. (c1994). Historical radionuclides and sources inventory. SRDB Ref. ID 012023 

Pinellas Plant. (1996). CY 1995 quarterly report on employee’s dose [February 9, 1996]. SRDB 

Ref. ID 187620 

Pope, L. E. (2007). Neutron generator production mission in a National Laboratory

(SAND2007-3261). SRDB Ref. ID 088823 

[Redacted]. (2019). Special exposure petition Pinellas Plant. Received by NIOSH December 16, 

2019. SRDB Ref. ID 182952 

[Redacted]. (2020a). Special exposure petition Pinellas Plant (Revised edition, May 20, 2020). 

SRDB Ref. ID 182963 

[Redacted]. (2020b). Special Exposure Cohort petition Pinellas Plant (Revised edition, 

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Sandia National Laboratories. (2002). Building the bombs: A history of the Nuclear Weapons 

Complex (SAND2002-0307P). SRDB Ref. ID 073734 

SC&A, Inc. (2006). Review of the NIOSH site profile for the Pinellas Plant site (SCA-TRTASK1-0015, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-pinesp-r0.pdf

SC&A, Inc. (2016a). Issue resolution matrix for Pinellas Plant [Updated March 15, 2016]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-pinellasim-031516.pdf

SC&A, Inc. (2016b). Pinellas site profile review final Status report [PowerPoint presentation to 

the Advisory Board on Radiation and Worker Health, Idaho Falls, ID, August 9, 2016]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/pres/2016/bd-pinesp-080916.pdf

SC&A, Inc. (2016c). Review of proposed stable metal tritide dose reconstruction methodology at 

Pinellas (SCA-TR-2016-SP001, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scapinetritmeth-r0.pdf

SC&A, Inc. (2021, April 28). Focused review of ORAUT-OTIB-0066, revision 01, for resolution 

of issues [Memorandum to Subcommittee for Procedure Reviews]. 

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Tritium incident Building 400. (1969). Pinellas Plant, General Electric Company Neutron 

Devices Department. SRDB Ref. ID 012810 

U.S. Department of Energy. (1982). Safety analysis report: Expansion of Building 400 RTG 

facility. SRDB Ref. ID 013264 

U.S. Department of Energy. (1983). Environmental assessment, Pinellas Plant site, St. 

Petersburg, Florida (DOE/EA-0209). SRDB Ref. ID 009971 

U.S. Department of Energy. (1990a). Tiger Team assessment of the Pinellas Plant (DOE/EH0126). SRDB Ref. ID 046090 

U.S. Department of Energy. (1990b). Pinellas Plant final action plan (DOE/EH-0126-Final). 

SRDB Ref. ID 088853 

U.S. Department of Energy. (1992). Pinellas Plant site environmental report for calendar year 

1991 (MMSC-EM- 92047). SRDB Ref. ID 012025 

U.S. Department of Energy. (1994a). Independent technical review of the Pinellas Plant (LAUR-94-3662). SRDB Ref. ID 181753 

U.S. Department of Energy. (1994b). Pinellas Plant feasibility study: Final report

(DOE/AL/66151-1). SRDB Ref. ID 006501 

U.S. Department of Energy. (1997). Pinellas Plant environmental baseline report (MMSC-EM97013). SRDB Ref. ID 048197 

U.S. Department of Labor. (c1994). Pinellas Plant overview (DOL-06-02424). SRDB Ref. 

ID 108180 

U.S. Department of Labor. (2020). EEOICPA site exposure matrices website—DOL site 

exposure matrices: Incident search by related item [Search results for Pinellas Plant dated 

August 25, 2020]. SRDB Ref. ID 182695 

University of North Carolina at Chapel Hill (UNC), School of Public Health, Department of 

Epidemiology. (1997). Case control study of multiple myeloma among workers exposed to 

ionizing radiation and other physical and chemical agents (200-93-2628). SRDB Ref. 

ID 187538

Weaver, A. S. (1989). GEND personnel dosimetry report [Attachment to Pinellas Plant

procedure HPO3, rev. 4.0, May 30, 1989]. SRDB Ref. ID 012989, PDF pp. 7–9 

Weaver, A. S. (1990–1991). Memo- review of bioassay program [Collection of memos from

Petersburg, FL, General Electric Neutron Devices Department, April 12, 1990, through 

September 10, 1991]. SRDB Ref. ID 012740 

Weaver, A. S. (1991). 1990 annual ALARA program report for ionizing radiation. SRDB Ref. 

ID 013008 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Weaver, A. S. (1992). 1991 annual ALARA program report for ionizing radiation. General 

Electric Neutron Devices. SRDB Ref. ID 182933 

Weaver, A. S. (1993). 1992 ALARA report in DOE/AL 5480.11 attachment B format. Martin 

Marietta Specialty Components. SRDB Ref. ID 012852 

Weaver, A. S. (1996). 1995 annual ALARA program report for ionizing radiation. Lockheed 

Martin Specialty Components. SRDB Ref. ID 179210 

[Worker Advocate]. (2022, December 8). Supplemental information based on legal factual 

substantial evidence to grant Pinellas Plant SEC petition and add class from 1956-1997 due to 

the internal dose from the five metal tritides cannot be sufficiently accurately calculated at the 

maximum radiation level [Correspondence to Advisory Board on Radiation and Worker Health]. 
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Appendix A: DOE Tiger Team Report

As discussed elsewhere in this review, the SEC petition cites the DOE Tiger Team report (DOE, 

1990a) as a basis for the request to grant an SEC, and the NIOSH ER (NIOSH, 2021a) also cites 

the Tiger Team report to support qualifying the petition but terminating the period under 

consideration at the end of 1990. Since the Tiger Team report is a pivotal document dividing 

Pinellas’s history into two periods, pre- and post-1990, SC&A has reviewed it thoroughly and 

extracted some information relevant to petition qualification and to feasibility of dose 

reconstruction. This information is presented in list form in this appendix. Tiger Team report 

sections and page numbers are included for convenience. A more complete picture of the Tiger 

Team’s charter, practices, and findings is found in the report itself.

It should be understood that, as was the focus of all DOE Tiger Team investigations across the 

DOE complex in the early 1990s, the 403-page Pinellas report is largely concerned with 

environmental safety and health compliance issues—including regulatory compliance, 

organizational, and documentation—but less so with radiation exposure issues. The Pinellas 

Tiger Team report is based on an onsite assessment conducted from January 15 to February 2, 

1990. All page citations in the following list are to DOE (1990a). 

• Executive Summary, p. ES-1: “The assessment did not identify any problems at the 

Pinellas Plant which present an undue risk to public health or the environment.” 

• Executive Summary, pp. ES-2–ES-3: The Environmental Subteam identified six key 

findings (see also section 2.1.1, p. 2-1): 

1. the addition of small quantities of radioactive waste to nonradioactive classified 

waste to solve a classified waste disposal problem

2. incomplete documentation of dose assessments, not fully documenting 

methodologies and actual dose assessment calculations 

3. lack of adequate characterization of inactive waste sites

4. deficiencies in the sitewide environmental monitoring program 

5. on- and offsite groundwater contamination

6. failure to apply for air pollution permits (National Environmental Policy Act) 

• Section 1.3.3, p. 1-5: “This assessment reflects a fixed point in time. As a result, 

improvements in the environment, safety and health areas that were planned, but were not 

completed at the time of the assessment, are identified as findings or concerns if the Tiger 

Team judged that failure to complete these improvements would have a significant 

impact.”

• Section 3.5.1.1, p. 3-8: “Tritium gas and tritium oxide are discharged from the Bldg. 100 

laboratory (west main stack), the Bldg. 200 stack and the Bldg. 800 stack, while tritium 

gas, tritium oxide and krypton-85 gas are discharged from the Bldg. 100 main exhaust 
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stack (east main stack), all of which are monitored.” One of the findings was that “air 

pollution and air radiological programs need further attention.” 

• Section 3.5.1.2, p. 3-13: Finding A/CF-2, “Tritium Stack Releases – Procedure 

Deviations and Sampling Deficiencies”: Lists some deficiencies in equipment calibration, 

probe locations, and procedure. 

• Section 3.5.1.2, p. 3-15, Finding A/CF-5, “Kane Chamber Calibration Inadequacies”:

“Kane Chambers which are used to monitor tritium stack releases from Bldgs. 100W and 

200, and tritium plus krypton stack releases from Bldg. 100E have not all been verified 

using tritium gas.” 

• Section 3.5.1.2, p. 3-16, Finding A/CF-6, “Plutonium Stack Sampling Deficiencies”:

“The stack sampling equipment for Bldg. 400 which has been installed for the purpose of 

detecting potential releases of particulate Pu-238 and 239 is not of an isokinetic design. 

. . . Failure to properly sample particulate effluent streams can lead to inaccurate 

estimates of doses to the public. The site is aware of this situation and has an approved 

project budgeted for fiscal year 1990 . . . to correct this situation.”

• Section 3.5.1.3, p. 3-18, Finding A/BMPF-1, “Ambient Air Monitoring Deficiencies”:

“The siting and design of the radionuclide ambient air sampling stations do not provide 

measurements that are representative of public exposure conditions in the vicinity of the 

Pinellas Plant. . . . Ambient air monitoring is carried out in the vicinity of the Pinellas 

Plant to measure air concentrations of tritium and plutonium. All five of the offsite air 

monitor locations, and all seven onsite locations were visited during the Tiger Team 

Assessment. None of the air samples were collected at the recommended breathing zone 

height of 2.0 meters.” 

p. 3-19: Other deficiencies were present at different monitoring stations. However, the air 

sampling measurements are substantially below U.S. Environmental Protection Agency 

(EPA) and DOE radionuclide health criteria. There are variances from guidance, but the 

conclusion holds that the plant is in compliance with applicable health criteria for air 

pathways. 

• Section 3.5.1.2, p. 3-22, Finding A/BMPF-5, “Lack of Silica Gel Tritium ‘Breakthrough’ 

Documentation”: “Documentation does not exist demonstrating that sample exchange 

frequency precludes breakthrough on silica gel tritium columns for daily stack, monthly 

stack, and monthly ambient air tritium samples. . . . Failure to document breakthrough 

conditions . . . may lead to unwanted loss of sampled material and subsequent 

underestimation of doses to the public.” 

• Section 3.5.2.3, p. 3-27, Finding SS/BMPF-1, “Lack of Background Plutonium Soil 

Sampling Location”: “The site has not established a background plutonium soil sampling 

location . . . collocated with a background ambient air monitoring station (see related 

Finding A/BMPF-1).” 
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• Section 3.5.3.1, p. 3-28: “The low-level contaminated tritium waste is collected from 

Health Physics . . . drains and dedicated piping within the facility and pumped to [Health 

Physics] holding tanks where the wastewater is tested to determine tritium 

concentrations. The facility discharges industrial (Metal Finishing), sanitary, and lowlevel radioactive wastewaters to the POTW [Cross Bayou Publicly Owned Treatment 

Works].” 

• Section 3.5.5.1, p. 3-53: 

o “The Pinellas Plant has generated in the past, and is currently storing 38 drums of 

mixed radioactive and hazardous waste (mixed waste).” 

o “Radioactive wastes at the Pinellas Plant are generated from the use of tritium in 

manufacturing and engineering of neutron generators, from the destructive and 

nondestructive testing of neutron generators, and duct work from 

decommissioning of certain areas. Radioactive wastes are stored onsite prior to 

periodic shipment offsite to the DOE Savannah River Plant for disposal.” 

• Section 3.5.7.1, p. 3-65: “The Pinellas Environmental Health and Safety Program 

(EH&SP) department is responsible for administering the site environmental monitoring 

program. All radiological analyses are performed on site by the Environmental Chemistry 

Laboratory (ECL). Radiological analyses include tritium in air and water (surface water 

and plant effluent to the POTW) samples, and plutonium in air and soil samples.”

• Section 3.5.8, “Radiation”: 

o Section 3.5.8.1, p. 3-70: “The Environmental Subteam found no processes or 

operations which pose an immediate and unacceptable radiation safety risk to the 

environment or public. . . . The radiological environmental monitoring program at 

the Pinellas Plant evaluates stack air effluents for tritium, krypton and plutonium; 

ambient air for tritium and plutonium; water effluents for tritium and soil samples 

for plutonium.” 

o Section 3.5.8.2, p. 3-74, Finding R/CF-1, “Deficiencies in Dose Assessment 

Methodologies”: “Dose assessment methodologies are not sufficiently 

documented to demonstrate full compliance with Federal and DOE 

requirements”: 

 Overall, written site dose assessment plan does not exist. 

 Written procedures for dose assessment computer programs do not exist. 

 Computer programs used to perform dose assessment calculations are not 

periodically benchmarked. 

 Plutonium and krypton source term inputs are not completely documented. 

 Default values used in the dose assessment program are not documented 

as being appropriate for Pinellas. 
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p. 3-75: “Although the dose equivalents to the maximally exposed individual 

reported by the Pinellas Plant have consistently been well below the NESHAP 

limit of 10 mrem/year for whole body irradiators (no target organ irradiators are 

released in detectable quantities), the program as it exists today is not capable of 

defending the quality aspects required by existing and draft DOE Orders.”

• Section 4.5.1.1, “Safety and Health Assessment Findings and Concerns, Organization and 

Administration, Overview,” p. 4-5: “In the past the Pinellas Plant has been acknowledged 

as a moderate hazard, non-nuclear, and non-critical facility. However, recently the 

General Manager requested an official determination regarding the hazard level and 

nuclear status of the plant. This official determination had not yest been made. Currently 

there are few in depth and technically competent safety analyses of product lines, 

activities and operations at the Pinellas Plant. In addition, there has been no detailed 

evaluation or risk assessment regarding offsite hazards effects upon the plant.” 

• Section 4.5.7.2, p. 4-66, Finding EP.6, “Emergency Assessment and Notification”: “A 

catalogue of pre-determined consequences from likely accidents (other than plutonium 

releases) is not available to the emergency response cadre. One of the plant health 

physicists has performed 50-year dose commitment calculations for plutonium releases 

using extremely conservative assumptions.” 

• Section 4.5.11, “Radiological Protection”: 

o Section 4.5.11.1, “Overview”: 

 p. 4-90: “The overall assessment is that all levels of the GEND 

organization are receiving adequate radiological protection. This is 

primarily due to a GEND staff that appears willing to accept line 

responsibility for radiological safety along with a technically strong health 

physics staff providing direction.” Several procedural caveats are noted 

after this statement.

 p. 4-90: “External exposure, both individual and integrated plant 

personnel, at GEND is generally kept very low. GEND has taken adequate 

measures to continue the reduction of personal external exposure. 

Accreditation of the dosimetry system needs to be completed along with 

the formalization of employee exposure investigations. Radiation workers 

were observed not to wear their personnel dosimeters consistently, or 

failed to ensure that they were properly located on their body.” 

 p. 4-91: “Occupational internal exposures are low compared to other DOE 

sites. This accomplishment results from a conservative approach to 

working with tritium and through extensive use of engineering controls. 

However, compliance with the rules on providing bioassay samples at 

specified frequencies has not been satisfactory.”
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 p. 4-91: “Contamination controls are generally good. Contamination levels 

within the work areas are kept low and generally confined to the source. 

Indications were found that proper contamination control techniques are 

not always being followed, in some areas causing contamination to spread 

to the general areas of the facility.”

 p. 4-91: “GEND’s strength lies in its commitment to an ALARA 

philosophy that prevails across all departments. Commitments to ALARA 

are demonstrated by installation of the new Tritium Recovery System 

(TRS) and the conservative approach to performing work.” SC&A notes 

that a formalized ALARA program was a fairly new concept to the nuclear 

profession in 1990 and did not apply in the earlier years of Pinellas 

operations. 

o Section 4.5.11.2, p. 4-96, Finding RP.5, “External Radiation Dosimetry”:

 “GEND’s dosimetry program is not accredited as required by 

DOE 5480.11.” GEND determined that it had to switch from 

Landauer G-1 film dosimeter to Landauer Z-1, 3-chip TLD 700. 

 “There is no formal documentation of investigations into personnel 

exposure anomalies.” 

 “Radiation workers do not consistently wear their personnel dosimeters as 

required or ensure proper placement on their body.” 

 “Personnel indicated that they wear their dosimeters only when 

performing work involving the exposure to radiation.” 

o Section 4.5.11.2, p. 4-98, Finding RP.7, “Internal Radiation Dosimetry”: 

 “Procedural requirements have not been established for an employee’s 

termination bioassay, nor a system developed to identify and address those 

individuals who fail to provide a bioassay sample.” 

 “GEND estimated that 20 percent of the personnel that terminated in 1988 

did not provide a termination bioassay.” 

– “Individual workers, their supervisors, and management are not 

ensuring that required bioassay samples are provided. In 1989, 

bioassay samples were not submitted in accordance with GEND 

procedures. Seventy percent of the required monthly samples and 

35 percent of the required weekly samples were not submitted.”

o Section 4.5.11.2, p. 4-99, Finding RP.8, “Fixed and Portable Instrumentation”: 

“Numerous deficiencies associated with instrumentation calibration and use were 

noted during the appraisal.” 
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o Section 4.5.11.2, p. 4-101, Finding RP.10, “Radiation Monitoring/Contamination 

Control”:

 “Proper contamination control techniques are not being followed by 

personnel when working in and exiting from Contaminated Areas.” 

 Note: The contractor disagreed that workers are inadequately protected 

given the extremely low contamination levels detected and stated that 

“radiation exposures from these contamination levels are not measurable, 

as supported by bioassay sampling.” 

• Section 5.7, p. 5-33, “Probable Root Causes”: “There are at least two probable root 

causes for the deficiencies observed at the Pinellas Plant.”

o “First, emphasis on production has traditionally overshadowed interest in fully 

complying with environment, safety and health requirements.” 

o “Second, there is a wideset mindset that the Pinellas Plant poses no unusual or 

unique risks.” 
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distribution. 

Appendix B: Radiological Incidents

SC&A reviewed the available incident and health physics investigation reports along with the site exposure matrices (DOL, 2020) and 

compiled a list of all documented events that involved a potential or actual radiological release, contamination, and/or personnel 

exposure. 

Table B-1. Radiological incidents at Pinellas Plant

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

December 10, 1957 “Operator error in manometer 

use (Room 18),” 458 Ci 

released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB

12026)

February 11, 1958 “Error in estimating the amount 

of T2 remaining in the system 

(Room 18),” 1,253 Ci released.

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

July 8, 1958 “Glass system breakage 

(Room 22),” 280 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

March 7, 1958 “Glass system breakage 

(Room 18),” 567 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

August 16, 1958 “Operator error in loader valve 

position (Room 21),” 780 Ci 

released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

August 18, 1958 “Glass breakage [bed] (Room 

21),” 1,180 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

February 10, 1959 “Operator error in stopcock use 

(Room 8),” 286 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

February 20, 1959 “Hand contamination –

operator not wearing gloves.” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

February 21, 1959 “Area contamination – operator 

broke glass system 

(Room 18).” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

March 12, 1959 “[Redacted] contaminated 

during system cleaning by 

another worker [redacted].” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB

12026)

June 4, 1959 “GEL personnel error working 

on SECS test (Room 21),” 753 

Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

June 5, 1959 “Area contamination – diffusion 

pump exploded in Hood 14.” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

June 18, 1959 “Near miss explosion on glass 

system – operator error.” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

June 18, 1959 “Air in loading system 

[explanation questioned] 

(Room 20),” 423 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

September 11, 1959 “Tritium in holding tank H2O,

possibly from drum washing,” 

6.5 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

October 5, 1959 “Stopcock blew out of glass 

system (Room 15).” 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

January 1960 “Operator left stopcock open,” 

40 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

February 5, 1960 “Glass bed broke from strain,” 

72 Ci released. 

No additional information No additional information Burkhart (1990), p. B-3 (SRDB 

12026)

February 11, 1960 “Operator left stopcock open,” 

308 Ci released. 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

March 25, 1960 “Operator error caused 

exposure to [redacted].” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

May 14, 1960 “Broken flask caused area 

contamination (Room 10).” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

June 21, 1960 “Ion gage exploded 

(Room 18).” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

July 8, 1960 “Sample bulb dropped (Room 

23),” 6.8 Ci released. 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

July 13, 1960 “Manifold shattered, exposing 

worker (Room 23).” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

August 12, 1960 “Contamination spread (TiH2) 

in Area 108 from broken flask.” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

April 1961 “Area contamination from 

system breakage.” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

July 1961 Routine survey revealed 

leakage of 100 μCi Co-60 

source. 

No additional information “Corrective action was 

taken immediately.” 

Forest (1961), quote on p. 3

(SRDB 182941) 
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

December 1962 “Breathing air supply line 

connected to Area108 exhaust 

duct.” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

April 5, 1963 Uncontrolled spread of tritium 

air contamination from open 

valve of uranium tritide bed 

into glove box interior. 

All personnel were evacuated, 

adjacent areas surveyed and found 

to be normal. 

Urine samples taken from all 

involved personnel and no 

significant body deposition found. 

Gloveboxes flushed and 

valves sealed. 

Jech (1963) (SRDB 12221); listed 

in EEOICPA site exposure 

matrices for Pinellas Plant 

(sem.dol.gov)

February 4, 1965 Removal of 81 Ci of Kr-85 from 

Radiflo Unit #1 in preparation 

for maintenance. Plastic line 

ruptured, releasing 

radioactivity into Rooms 1 and 

5. 38 Ci of Kr-85 released. 

Entire Radiflo area was evacuated 

and surveys performed to 

determine extent of contamination. 

Maximum exposure received 

during transfer operation and 

associated release was 160 mR. 

Investigation committee 

formed to review 

procedures and develop 

corrective actions. 

HP Incidents at GEND (1965–

1975), PDF p. 2 (SRDB 26399); 

Burkhart 1990 (SRDB 12026)

March 10, 1965 “Worker exposed when x-ray 

interlock failed (XRE shutter).” 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

March 30, 1965 “Broken flask (Room 9).” No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

May 20, 1965 “Flask explosion (Room 12).” No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

May 1966 “SECS col water removal 

problem,” 252 Ci released. 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

January 27, 1967 “Glove box pump oil degassed 

(Area 182C),” 32 Ci released. 

No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

October 12, 1967 “Personnel contamination – Oring mishandled (Room 18).” No additional information No additional information Burkhart (1990), p. B-4 (SRDB 

12026)

January 17, 1968 129 Ci of Kr-85 was released 

from Radiflo Unit #1. 

Personnel in room received 5 mR

exposure. 

Equipment malfunction 

corrected. 

HP Incidents at GEND (1965–

1975), PDF p. 5 (SRDB 26399); 

Burkhart 1990 (SRDB 12026)

June 18, 1968 Explosion occurred in a hood 

in Area 81 involving solutions 

used to chemically clean 

molybdenum parts. 

[Redacted]

No mention of radiation exposure. No additional information HP Incidents at GEND (1965–

1975), PDF p. 7 (SRDB 26399); 

Burkhart 1990 (SRDB 12026)

February 1969 “Leaking flange at sorb pump 

(Area 108),” 8 Ci released. 

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

February 1969 “Area contamination when 

pump exhaust lines were cut 

during hood removal 

(Room 2).”

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)

February 3, 1969 “Equipment failure – value did 

not seal properly,” 20 Ci of Kr85 released. 

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)

August 11, 1969 ‘Holding tank overflow after 

pump failure.” 

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)

September 29, 1969 [Redacted] from a deuterium 

flask in [Redacted]. 

Urine sample taken 2 hours after 

injury. 

Whole body exposure of [redacted]. 

No additional information HP Incidents at GEND (1965–

1975), PDF p. 14 (SRDB 26399)

November 5, 1969 Deuterium bed in Area 108 

developed a leak, and the bed 

had to be moved to Building 

400 in order to seal the leak. 

[Redacted] Shoes were 

decontaminated and the steps 

were retraced along the route 

to determine extent of 

contamination. 

High contamination of tritium in Cell 

3 Building 400, airborne tritium 

contamination detected. Next day, 

Building 400 personnel submitted 

bioassay samples that showed 

increases. Air supply redirected to 

Building 200 and those personnel 

put on weekly bioassay schedule. 

Maximum personnel exposure was 

50 mrem.

No additional information Tritium Incident Building 400 

(1969) (SRDB 12810); listed in 

site exposure matrices for 

Pinellas Plant (sem.dol.gov); 

Burkhart (1990) (SRDB 12026)

January 1970 “Area contamination/personnel 

exposure from flaking tube part 

in gas lab.” 

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)

February 1970 “Area contamination from 

pressurized sorb pump [air 

expansion] (Room 2).”

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)

April 21, 1970 [Redacted] with probe used on 

a contaminated tube loading 

system. 

[Redacted]

Bioassay records included in the 

file. 

No additional information HP Incidents at GEND (1965–

1975), PDF p. 14 (SRDB 26399)

November 20, 1970 “Area contaminated when 

operator used vacuum cleaner 

on ScH2 dust (Area 182D).” 

No additional information No additional information Burkhart (1990), p. B-5 (SRDB 

12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

December 29, 1970 Between 12/27/1970 and 

12/28/1970, 117 Ci of tritium 

oxide was detected in exhaust 

monitoring data. 

“The discharge occurred when the 

SECS absorption columns became 

saturated with moisture” (PDF p. 

5). Tritiated water in the columns 

exchanged with the moisture and 

was release to the stack. No 

personnel exposures noted.

Various corrective actions 

recommended, formation 

of investigative committee 

to track implementation of 

corrections. 

Holliday (1970–1979), PDF pp.

3–5 (SRDB 12804); Burkhart 

(1990) (SRDB 12026)

March 12, 1971 Worker exposed to tritium 

while cleaning out hood, 

exhaust monitor went off scale. 

Release of 7.3 Ci. 

Worker submitted urine samples for 

several days following. 

No additional information Holliday (1970–1979), PDF p. 2 

(SRDB 12804); Burkhart (1990) 

(SRDB 12026)

June 14, 1971 “Area 108 Wallace Tiernan 

Gage repair – high internal 

dose.” 

No additional information No additional information Burkhart (1990), p. B-5

October 9, 1971 Krypton release and discovery 

of the deteriorated condition of 

the storage tank on Radiflo 

Unit 2. Release of 6.1 Ci.

No mention of employee exposure Contacted vendor.

Checked integrity of other 

storage units and new 

program for cleaning and 

maintaining storage tanks. 

Pinellas Plant (1971–1975), PDF

pp. 5–8 (SRDB 12805); Burkhart 

(1990) p.B-5 (SRDB 12026)

October 21, 1971 129 Ci of tritium was released 

in Building 100/Area 182 from 

an improperly baked 

evaporator system. 

No additional information No additional information Site exposure matrices for 

Pinellas Plant (sem.dol.gov); 

Burkhart (1990) (SRDB 12026)

November 10, 1971 A [redacted] accidently spilled 

tritium sample onto the floor 

while trying to fit them into a 

spectrometer. 

[Redacted] reported incident, area 

was surveyed for contamination 

and [redacted]. 

No additional information Pinellas Plant (1971–1975), PDF

pp. 2–4 (SRDB 12805); listed in 

site exposure matrices for 

Pinellas Plant (sem.dol.gov); 

Burkhart (1990) (SRDB 12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

November 23, 1971 [Redacted] reported hood 

exhaust monitor went off scale 

after removing a bed from the 

system. 

“The [redacted] was instructed to 

tighten the blank which is installed 

on the system when the bed is 

removed” and was reminded “to 

exercise caution in order to avoid 

exposure and to wear gloves, 

laboratory coat and a fresh air 

mask while performing the 

operation.” Health and Safety was 

confused as to why there was an 

exposure if protective gear was 

used. Next day, a bioassay sample 

showed a tritium deposition, which 

will result in a whole body exposure 

of [redacted]. 

Discussion with the 

[redacted] to determine 

how to prevent future 

exposures.

HP Incidents at GEND (1965–

1975), PDF pp. 36–37, quotes on 

PDF p. 36 (SRDB 26399); 

Burkhart (1990) (SRDB 12026)

April 1972 “Area contamination/liquid 

discharge from flaking fixture 

(Area 182D),” 1.5 Ci released. 

No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

May 15, 1972 Scattered radiation from GE xray emission unit, [redacted]

and was not wearing badge, 

[redacted]. 

“reflects an inadequacy in the 

Department’s safety orientation/

education effort.” 

Worker using equipment outside of 

their area. 

Recommendations 

include educating 

employees on safety 

program, creating a 

system to help 

supervisors with training, 

and reducing response 

time in the radiation alarm 

system.

GE (1972), quote on PDF p. 3

(SRDB 13196); Pinellas Plant 

(1971–1975), PDF pp. 17–20

(SRDB 12805); Burkhart (1990) 

(SRDB 12026)

August 3, 1972 “Leaking sorb pump,” 12 Ci 

released. 

No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

January 4, 1973 “Water leak in Area 182D.” No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

May 11, 1973 Fire in Building 200 occurred 

during destructive testing. 

No mention of employee 

exposures. 

Wood portion of device to 

be replaced with 

noncombustible material. 

Pinellas Plant (1971–1975), PDF 

pp. 22–24 (SRDB 12805); 

Burkhart (1990) (SRDB 12026)
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Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

May 29, 1973 Building 100 routine 

contamination survey revealed 

floor and surface 

contamination in Area 158B; 

shoes of the area personnel 

also contaminated. 

Decontamination followed.

Environmental health should have 

been notified when the radioactive 

material was dropped. 

Poor judgment was exercised in

removing the sources from the 

shield assemblies in Area 157. 

Provide instrumentation,

increase frequency of 

routine surveys to daily

Pinellas Plant (1971–1975), PDF

pp. 10–16 (SRDB 12805)

November 1973 Tritium-containing boom box 

fire in Building 200. 

No tritium released. No additional information Site exposure matrices for 

Pinellas Plant (sem.dol.gov)

March 17, 1974 Water leak occurred in Area 

109, and there was water 

leakage into Rooms 19 and 20. 

Safety employee was in 

Rooms 19 and 20 in Area 108 

and directed the water to the 

floor drains so only those 

rooms were affected.

Floor smears showed no significant 

contamination.

No mention of personnel 

exposures. 

Investigation conducted. HP Incidents at GEND (1965–

1975), PDF p. 58 (SRDB 26399); 

Burkhart (1990) (SRDB 12026)

April 11, 1974 Unusual rise in tritium oxide 

discharged in laboratory stack 

effluent from [Redacted]. 

Indicates high concentration in 

the hood in the exhaust 

system. 

“If the [redacted] performing the 

work did not adhere strictly to 

radiological safety procedures 

[fresh air mask and gloves], a 

significant exposure could be 

expected.” 

[Redacted] mask contaminated. 

[Redacted]

Environmental Health and 

Safety (EHS) will be 

notified before opening 

any metal exhaust or 

loading system in 

[Redacted]. 

HP Incidents at GEND (1965–

1975), PDF p. 72 (SRDB 26399); 

Burkhart (1990) (SRDB 12026)

October 1974 Investigation of contaminated 

valve shipment: Gate valve 

used at GEND became 

contaminated with tritium, 

confusion as to the level of 

contamination and valve was 

not properly labelled before 

shipment. 

Comprehensive investigations 

followed, Extensive surveys, 

analysis performed to determine 

maximum possible exposures to 

personnel. Possible dose very low, 

no health hazard.

No additional information Pinellas Plant (1976–1979), PDF

p. 2 (SRDB 12806) 
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Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

January 31, 1975 Tritium-deuterium gas release 

to atmosphere and 

surroundings in Room 4 and 

the west side of Area 108.

Release due to improper valve 

closure on uranium beds. 

No mention of personnel 

exposures. 

Investigation conducted, 

various preventative 

measures implemented. 

Phillips (1975) (SRDB 13125); 

Burkhart (1990) (SRDB 12026)

February 10, 1975 “Sorb pump leak – Area 182D,” 

42 Ci released. 

No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

May 10, 1975 Rain water pouring in Area 8 

from roof leaks. 

Surveyed area and found water did 

not present a significant 

contamination problem. 

No additional information HP Incidents at GEND (1965–

1975), PDF pp. 76–77 (SRDB 

26399)

January 31, 1976 “Contaminated 6-inch valve 

shipped”

No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

April 13, 1976 “During the low temperature 

bake operation, the oven fan 

blade disengaged from the fan 

motor shaft and struck the 

array of ten (10) MC 1451B

tubes being processed," 

shattering one tube in metal 

exhaust system #503, 

Area 108. 

No injury or exposure to personnel. Installation of protective 

screens. 

Pinellas Plant (1976–1979), PDF

p. 89–91, quote on PDF p. 89

(SRDB 12806); Burkhart (1990) 

(SRDB 12026)

June 1976 7,100 Ci of tritium gas that 

came from a tritium tank during 

bed loading process in Room 

18, Area 108. 

“This gas accidently was slowly 

absorbed in the stack effluent 

control system columns through the 

bed loading system rough pump.”

“The accidental discharge and the 

accountability of the loss were not 

recognized or acted on soon 

enough.” 

No mention of personnel 

exposures. 

Many suggestions 

involving record keeping, 

monitoring, and alarm 

systems.

Pinellas Plant (1976–1979), PDF

pp. 98–103, quotes on PDF 

p. 103 (SRDB 12806) 

February 1977 “Packaging of fixtures in Area 

182D glovebox,” 28 Ci of 

tritium released. 

No additional information No additional information Burkhart (1990), p. B-6 (SRDB 

12026)

May 23, 1977 “Radiflo valve failure during 

cold trapping,” 16 Ci Kr-85 

released. 

No additional information No additional information Burkhart (1990) p. B-6 (SRDB 

12026)
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Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

September 11, 1979 Release of tritium oxide from 

the [redacted]. 5.7 Ci released.

Release was larger than 

anticipated. 

Worker exposure was avoidable 

and resulted from “techniques 

which were less than adequate.” 

[Redacted]. 

Improved “planning and 

instruction when 

performing non-routine 

operations.” 

Upgrade health physics 

monitoring equipment. 

Holliday 1970–1979, PDF pp. 20–

38, quotes on PDF pp. 21, 30

(SRDB 12804); also listed in site 

exposure matrices for Pinellas 

Plant (sem.dol.gov); Burkhart 

(1990) (SRDB 12026)

April 1980 “Area contamination from film 

flaking (Area 158B).” 

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

May 14, 1980 Cooling water hose rupture in 

Room 13, Area 108. 

No personnel were present in 

Room 13 and no injuries reported. 

Investigation conducted. HP Investigation Reports (1980–

1986), PDF pp. 2–12 (SRDB

12808) 

July 1980 Disposition of scanning 

electron microscope that had 

some tritium contamination. 

No health hazard to personnel.

“External surfaces of all 

components indicated radiation 

levels below the standards for 

unconditional release.”

No additional information HP Investigation Reports (1980–

1986), PDF pp. 15–28, quote on 

PDF p. 17 (SRDB 12808) 

April 29, 1981 “SECS overpressure when 

purge valve left open.”

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

February 25, 1982 Memo to file: east stack tritium 

monitor showing two

discharges totaling 8.6 Ci of 

tritium. 

No mention of personnel exposure. No additional information HP Investigation Reports (1980–

1986), PDF p. 46 (SRDB 12808) 

April 20, 1982 Memo to file: 48 Ci tritium 

release from mass 

spectrometer in Room 20, 

Area 108. 

Valve in discharge line directed to 

stack instead of the SECS. 

No additional information HP Investigation Reports (1980–

1986), PDF p. 47 (SRDB 12808) 

May 24, 1982 9.5 Ci discharge from east 

stack, vacuum maintenance 

personnel working and system 

discharge valve was turned 

from tritium recovery system to 

the stack. 

No additional information No additional information HP Investigation Reports (1980–

1986), PDF pp. 48–49 (SRDB 

12808) 

September 1, 1982 Tritium release in Area 108, 

alarm went off but personnel 

confused because it is hard to 

identify location. 3.0 Ci 

released.

“Most often alarms occur when 

personnel are performing work with 

a high potential for tritium release 

in a hoodroom. In this instance, 

evacuation of the general area is 

not required.” 

Change the sound of the 

various alarms so workers 

can determine location of 

release.

HP Investigation Reports (1980–

1986), PDF pp. 52–55, quote on 

PDF p. 53 (SRDB 12808); 

Holliday (1982a) (SRDB 187684), 

(1982b) (SRDB 187683); 

Burkhart (1990) (SRDB 12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

January 5, 1983 Release of 130 Ci of tritium in 

[Redacted] during routine 

procedure to unload and 

oxidize a tritium bed. 

“The results of the investigation 

indicate that improper equipment 

usage resulted in the gas leakage, 

and that installations exist in the 

plant that could result in similar 

tritium release events.”

[Redacted]. 

Investigation conducted. HP Investigation Reports (1980–

1986), PDF pp. 57-67, quote on 

PDF p. 57 (SRDB 12808) 

January 19, 1983 9 Ci of tritium released from a 

sorption pump into the 

manufacturing section of Area 

108, Building 100 and exhaust 

to the environment through the 

Building 100 east exhaust 

stack. 

No personnel exposures or area 

contamination.

No additional information HP Investigation Reports (1980–

1986), PDF pp. 68–82 (SRDB 

12808) 

April 5, 1983 “Bed heater control failure 

(Area 108).”

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

April 3, 1984 “SECS blockage when Trichlor 

was introduced in Area 182D.”

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

July 25, 1984 “Sorb pump sieve dumped into 

drum in Area108 [Unusual 

occurrence report (UOR) 84-

07],” 67 Ci released. 

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

December 9, 1985 “Sorb pump overheat – area 

contamination [UOR 86-01].” 

No additional information No additional information Burkhart (1990), p. B-7 (SRDB 

12026)

June 5, 1986 “Waste drum removed from 

Area 108 without survey.”

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

June 24, 1986 “Mass spectrometer oil change 

workers exposed to T2 gas 

[UOR 86-04],” 1.5 Ci released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

November 24, 1986 “Tracerflo maintenance,” 3.6 Ci 

Kr-85 released. 

No additional information No additional information Burkhart (1990), p. B-8 9SRDB 

12026)

February 5, 1987 “270 Ci pumped from Room 18 

to SECS.” 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

June 16, 1987 “SECS pressurization by argon 

(Ar) purge in Area 108.” 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

August 1987 “Cold trapping,” 26 Ci Kr-85 

released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)
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distribution. 

Date of incident Incident description Personnel exposures/ comments Corrective actions Citation (SRDB ID)

September 8, 1987 “ELDS No. 6 sorb pump 

leakage (bad weld at neck),” 

0.7 Ci released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

November 4, 1987 “Test of O2 regeneration need 

by SEC system,” 12 Ci 

released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

February 11, 1988 “Leaking sample bulb from 182 

in Area 108,” 8 Ci released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

March 7, 1988 “E-Beam welder shield failure 

– workers exposed [UOR 88-

03].” 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

May 5, 1988 “Purge left on over third shift in 

Area 108 – SECs 

overpressure,” 2.7 Ci released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

May 27, 1988 “Leakage from Radiflo system 

No.2,” 0.4 Ci Kr-85 released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

September 1988 “Lab area release over twoweek period,” 16.2 Ci released. No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

January 6, 1989 “Water in SECS line (Area 

182D) [UOR 89-02],” 1 Ci 

released. 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB

12026)

September 7, 1989 “Loss of control of radioactive 

material [UOR 89-08].” 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

December 15, 1989 “Work performed in Area 109 

without permit [UOR 89-12].” 

No additional information No additional information Burkhart (1990), p. B-8 (SRDB 

12026)

1995 Investigation meeting held 

March 22, 1995. 

• Total of 175 leaks located in plant 

have been surveyed and 

analyzed. 

• External tritium levels were very 

low and would not be predictive 

of internal contamination levels. 

• The internal tritium contamination 

appears to be from Area 108 and 

Area 158A, and possibly from 

mass spectrometer in Area 157. 

Continue surveys to 

isolate contamination 

sources.

Personnel informed of 

best practices to minimize 

contamination. 

Burkhart (1995) (SRDB 13503);

listed in site exposure matrices 

for Pinellas Plant (sem.dol.gov)
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distribution. 

Appendix C: Former Worker Interview Notes

SC&A evaluated available documented communication (i.e., interview) summaries to determine if information existed pertinent to this 

SEC evaluation. These interviews were conducted by NIOSH and SC&A representatives in support of the TBD review. Table C-1 

summarizes these interviews. 

Table C-1. Summary of interview notes with former workers

SRDB No. Employment 

period Occupation Interview information

37343 [Redacted] [Redacted] The EE remembers taking both posterior-anterior (PA) and lateral (LAT) chest 

x-ray exposures. The films would then be sent out to a radiologist to be read. 

Does not recall any photofluorography (PFG) or any abdominal x-rays. The EE 

does remember doing some back (lumbar spine) x-rays. They did not do any 

pre-employment lumbar spine x-rays. 

37342 [Redacted] [Redacted] Provided information on the Radiflo systems used at the plant.

127111, 

185745

[Redacted] [Redacted] Indicated that they knew where tritide contamination would likely occur, which 

was typically limited to 2–3 areas within the operation line. The EE thought 

there might be more causes of tritium contamination in destructive testing. 

Another HP discovered that tritide exposures were occurring in an unexpected 

area via the bioassay results of a worker that was off site for a long enough 

period of time for any (soluble) tritium to be eliminated from their body. When 

that worker returned to work, their urine still had tritium in it, which could have 

only been from a (less soluble) metal tritide exposure. Once they figured out 

the cause of the metal tritide exposure, they moved the operation that was 

causing it into a fume hood and eventually into a glove box, to help prevent 

further exposures to tritides.

Neutron doses were only estimated for the RTG workers if one of the 

individuals lost a badge. They almost always relied on the dosimetry data only, 

and rarely had to estimate doses for RTG workers. The workers were required 

to leave their badges in the area. The results were not based on a photon 

dosimeter reading. They always had a separate badge for neutron exposures.

Building 100 was basically one building within a larger building. One area in 

Building 100 had aluminum walls. The walls for the process areas went all the 

way to the ceiling. There were walls separating process areas from nonprocess areas. The building contained elaborate ventilation systems.
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distribution. 

SRDB No. Employment 

period Occupation Interview information

129125 [Redacted] [Redacted] The focus of this interview was to confirm whether or not the tritium 

contamination smears were routinely rinsed and filtered through a Whatman 

#1 filter. An undated and unsigned Health Physics procedure that was 

previously captured indicates that the sample rinsate from the tritium 

contamination smears was filtered prior to adding an aliquot of the sample to a 

vile of liquid scintillation cocktail.

The interviewees recall rinsing the cotton balls used to collect the tritium 

contamination smear samples. However, neither recalls filtering the rinsate 

through any filter. Filtering the rinsate through a filter was not part of the 

routine analysis procedure when they were at the Pinellas Plant. They suspect 

that procedure that involved filtering the rinsate may have been a nonroutine 

procedure. There weren’t any routine procedures for analyzing the tritium 

contamination smears when metal tritide contamination was suspected, and 

they were not aware of any nonroutine procedures for doing that.

185748 [Redacted] [Redacted] According to EE, the EE’s department was asked to participate in urine 

bioassays; they were not required. The EE states that everyone but 

secretaries and management gave samples in the EE’s department.

185752 [Redacted] [Redacted] EE visited site on three occasions in the 1990s. As [redacted], the EE felt 

Pinellas HPs had a good program and were responsive. In the 1990s, the EE

felt that the plant had good participation in the bioassay program. 

185809 [Redacted] [Redacted] “We filled neutron tubes with radioactive gasses. I believe people gave routine 

samples, complied with the requests on a regular basis. I was assigned a film 

badge but didn’t use it very often because I was not near equipment and not in 

rad areas very long (the tube exhaust area with tritium that went into tubes). 

We were testing tubes to generate neutrons. The personnel were not exposed 

to tritium sealed in the tubes, but neutron exposure was possible. The test 

area and floor were marked off with tape into zones not to enter.

The RTGs were built in another area. They contained highly radioactive pellets 

with plutonium. The RTGs had doubly encased pellets (2 layers of metal on 

receipt). This was in its own building, in a contained area. The rules were 

followed in handling the RTG pellets.” 
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SRDB No. Employment 

period Occupation Interview information

185753 [Redacted] [Redacted] The site developed corrective actions for the Tiger Team process. These were 

submitted to Albuquerque for review and approval. The corrective action plan 

was signed-off on by the plant manager and the DOE area office. The EE 

recalled that there were reasonable explanations for the lack of management 

followup on mission bioassay samples. Recalled there being a delay in 

analysis of some submitted samples and people being off site as some 

reasons.

Pinellas HPs actively tried to collect samples should a sample not be 

submitted. They had a list of people to collect samples from.

185749 [Redacted] [Redacted] The EE participated in both the dosimetry and bioassay program. Selection for 

bioassay sampling was based on the work assignment with potential for 

exposure. The EE does not recall ever being in a high-exposure environment.

185754 [Redacted] [Redacted] As a supervisor, the EE never was contacted about workers not leaving a 

bioassay sample. All that was handled by Health & Safety/Health Physics 

people. The EE reported the Tiger Team came in 1989 and required signs be 

put up and carcinogens be specified in the operating instructions. There were 

no materials safety data sheets “until 22 years after we started working with all 

these chemicals” (p. 3). 

185929 [Redacted] [Redacted] According to the EE, an HP told the EE that the equipment for bioassay 

sample analysis was down frequently, once for up to a couple of months. The 

[redacted] just filled in the blanks (gun-decked) when the equipment was 

down.

The EE was on and off the bioassay program for their first [redacted] of 

employment and submitted weekly samples. Was given a dosimeter when the 

EE worked with the accelerator. The EE remembers weekly safety meetings 

around someone’s desk with rotating industrial safety concerns. Recalls 

[Redacted] (HP) giving a presentation and saying, “if you were married you 

would get more radiation from your spouse, then being at the plant” (p. 2).

185747 [Redacted] [Redacted] The EE recalled they had Health Physics Technicians who did routine surveys 

and collected bioassay samples. The primary contaminant of concern was 

tritium, not on the scale of Mound, but there were lots of tritium beds. 

Exposures to radiation workers was from tritium. There was one large building 

with several smaller outbuildings. The plant had a good radiation protection 

program and was a well-run facility, with high security standards. Conduct of 

operations was taken seriously. The EE did not recall things being done ad

hoc.
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distribution. 

SRDB No. Employment 

period Occupation Interview information

185813 [Redacted] [Redacted] If you were a radiation worker/wore a radiation badge, you gave a urine 

sample every Friday. If it was close to quitting time and you hadn’t given a 

sample, by 3:30 p.m. they were paging you over the intercom. Everyone in the 

whole building knew what they were paging you for: to come and give a 

sample. If you were given a dosimeter, it was understood that you were 

expected to give urine samples. Workers in Building 400 did not have to give 

urine samples. The plutonium was stored in the walled-off half of the building.

185751 [Redacted] [Redacted] The EE operated [redacted], to determine what compounds were available 

(nondestructive testing). The EE recalls monitoring at times and wore a badge 

after the Tiger Team audit. The EE does not recall generally wearing a badge 

or being in bioassay program. The EE was unaware of pushback on the 

bioassay program and doesn’t recall hearing any comments about people not 

wanting to participate.

185810 [Redacted] [Redacted] The EE did not participate in the bioassay program and “was never assigned a 

dosimeter. I believe the workers were compliant and followed instructions. I 

think if a worker didn’t provide a bioassay sample it is likely because they 

didn’t know they were supposed to” (p. 2).

185812 [Redacted] [Redacted] The EE recalled the plant was very compartmentalized and information was 

shared on a need-to-know basis. The EE had never heard of the bioassay 

program but recalled everyone did what was asked of them at the Pinellas 

Plant. The atmosphere was one of compliance with management instructions.

185811 [Redacted] [Redacted] The EE worked on nonradiation hazardous waste issues related to 

groundwater contamination. The EE does not recall radiation safety issues and 

thought it was a well-run plant.

185814 [Redacted] [Redacted] The EE had 5-7 direct reports in the bioassay program. As [redacted], they 

tried to be good stewards of the program and were reliable participants.

“The Tiger Team did not discover a new problem. The plant was aware, had 

self-identified the issues with not always getting samples returned. The site 

was working on it prior to and continued to work on it after the Tiger Team 

audit. The problem ebbed and flowed over time. Who knows why? Laziness? 

Lack of mgmt. focus? In the processing end I know we always had samples to 

run. There may have been pockets of non-compliance but we never had a 

shortage of samples to run” (p. 2).

The EE does not recall there ever being followup samples required. If you 

missed a weekly sample, you were told not to miss it next time.