Preliminary Draft 

For the Mound Work Group Review 

MOUND INTERNAL DOSIMETRY DATA ADEQUACY 

AND COMPLETENESS 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

June 2010 

Disclaimer 

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

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

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

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

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

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

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

interpretations regarding its conclusions are unwarranted.
TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................3 

1.0 Introduction..........................................................................................................................4 

2.0 Summary of NIOSH Position on Dose Reconstruction.......................................................6 

3.0 Radiological Hazards and Exposure Potential.....................................................................8 

3.1 Potential for Exposure............................................................................................12 

3.1.1 Engineering Controls.................................................................................13 

3.1.2 Work Practice Controls and PPE...............................................................16 

3.1.3 Safety Culture ............................................................................................19 

3.1.4 Explosions and Fires..................................................................................20 

4.0 Radium, Actinium, and Thorium Usage Beyond February 28, 1959 ................................22 

5.0

................................................................................................................................26 

Uranium and Transuranics (Am-241, Cm-244, Np-237, U-233, U-234, U-235, and 

U-238)

5.1 Americium, Curium, and Neptunium ....................................................................27 

6.0 Fission and Activation Products and Other Radionuclides................................................29 

7.0 Use of Gross Alpha as a Surrogate for Radionuclide-Specific Bioassay ..........................34 

7.1 Gross Alpha Determination (aka Plutonium Bioassay).........................................34 

7.2 Anion Exchange.....................................................................................................35 

7.3 Alpha Spectroscopy and Anion Exchange Chemistry...........................................37 

7.4 Air Sampling..........................................................................................................38 

7.5

.....................................................39 

Item of Clarification from the NIOSH Evaluation of Data Adequacy and 

Completeness Issues at the Mound Laboratory

7.5.1 .......................................................................................................39 Item #1

7.5.2 .......................................................................................................39 Item #3

7.6 Summary................................................................................................................40 

References......................................................................................................................................51 

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ABBREVIATIONS AND ACRONYMS 

ABWRH Advisory Board on Radiation and Worker Health 

ANL Argonne National Laboratory 

CEDE Committed Effective Dose Equivalent 

D&D Decontamination and Decommissioning 

DOE U.S. Department of Energy 

Dpm disintegrations per minute 

EEOICPA Energy Employee Occupational Illness Compensation Program Act 

ER Evaluation Report 

MCC Monsanto Chemical Company 

Mrem millirem 

MWP Maintenance Work Permit 

NIOSH National Institute for Occupational Safety and Health 

ORAUT Oak Ridge Associated Universities Team 

ORNL Oak Ridge National Laboratory 

PAAA Price Anderson Amendment Act 

pCi picocurie 

PMC Plutonium Molybdenum (pg. 47) 

POC Probability of Causation 

PPE Personal protective equipment 

R&D Research and Development 

RAM Radiation Assessment and Measurement 

RCG Radioactivity Concentration Guideline 

rem roentgen equivalent man 

RWP Radiation Work Permit 

SEC Special Exposure Cohort 

SC&A S. Cohen and Associates (SC&A, Inc.) 

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1.0 INTRODUCTION 

In its Draft Mound SEC Issues Matrix (SC&A 2008a, March 17, 2008), SC&A noted that the 

National Institute for Occupational Safety and Health (NIOSH) Evaluation Report (ER) has not 

adequately addressed how dose reconstruction would be accomplished for exotic radionuclides 

(i.e., other than plutonium, polonium, elemental tritium, and tritiated gas). Concerns have been 

raised regarding data adequacy for internal dosimetry; specific bioassay data are non-existent for 

many of the years when exotic radionuclides were handled at Mound. 

The matrix items related to “exotic radionuclides” include: 

 Matrix Item 1 – Exposure to radium, actinium, and thorium starting March 1, 1959 

 Matrix Item 3 – Exposure to transuranium radionuclides (Am-241, Cm-244, Am-243, 

Np-237) other than plutonium 

 Matrix Item 4 – Exposure to U-232, U-233, U-234, U-235, U-236, and U-238 

 Matrix Item 7 – Fission and activation products 

 Matrix Item 8 – Other radionuclides (Pa-231, La-140, Ba-140, Ca-45, Fe-55, Fe-59, Co60, Zn-65, Sc-46, Hg-203, Ag-110m, Bi-210, Cs-137, Xe-131, Kr-85, I-131, etc.) 

At the July 14, 2008, work group meeting, in response to Mound Matrix Items 1, 3, 4, 5, 7, and 

8, NIOSH/Oak Ridge Associated Universities Team (ORAUT) compiled the Major Isotopes, 

Process, Material, and Bioassay Road Map for the Mound Laboratory (hereafter, referred to as 

the “roadmap;” ORAUT 2009) to characterize radionuclide usage and associated bioassay 

coverage. Information for the roadmap was derived from the Mound Site Radionuclides by 

Location (King 1995), supplemental incident reports, and decontamination and decommissioning 

(D&D) era Radiation Work Permits (RWPs). Although considerable effort was put into the 

roadmap, NIOSH indicated during the January 5–6, 2010, Mound Work Group meeting that the 

King document (King 1995), and thus the roadmap, conservatively lists all radioisotopes that 

might have been used in an area, for the purpose of determining bioassay requirements in the 

D&D era. The roadmap was not intended as a tool for dose reconstructors, but was prepared to 

assist the Work Group in evaluating the SEC petition (ABWRH 2010). According to NIOSH’s 

statements at the work group meeting, the roadmap should not be construed as representative of 

the episodic nature of radionuclide handling, and they were aware of no situations where a 

potential exposure existed without the availability of bioassay. 

At the January 5–6, 2010, work group meeting, SC&A was asked to provide specific examples 

of intervals in which a potential for exposure to radionuclides existed in the absence of internal 

monitoring. Several examples of such scenarios have been provided herein and are summarized 

in Table 1 of this report. Clarification on the purpose of the King document (King 1995; Mound 

2001) is also provided, since this is a critical part of the characterization effort at the Mound 

Plant. Finally, additional information supporting radionuclide presence and potential exposure 

are provided for exotic radionuclides. 

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 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

POINT OF CLARIFICATION: As a significant source of information for SC&A’s Mound 

Matrix items and for NIOSH’s roadmap (ORAUT 2009), Technical Manual MD-22153, Mound 

Site Radionuclides by Location, and its appendices have been referenced throughout the Special 

Exposure Cohort (SEC) petition evaluation and technical review, but with some inconsistency. 

The current version of the manual in SC&A’s possession is Issue 3, approved by D. Morris on 

March 22, 2001. Changes incorporated with this revision are relatively minor; major sections of 

the document retain their identity, authorship, and effective dates from prior issues. For 

example, the Introduction retains its effective date of February 11, 1998, and Section 1, “Primary 

Research and Production Buildings,” remains intact as Section Issue 1, Wayne C. King, effective 

date June 22, 1995. Within this paper, SC&A references Mound 2001 as representative of the 

entire manual (including Appendices). Since NIOSH/ORAUT references the document as King 

1995 in the roadmap, SC&A retains this reference only when referring to its role as a roadmap 

source. Because the original section authorship, issue number, and effective date are retained in 

the current issue, SC&A assumes that the contents of “Eckman and King 1995” and Section 1 of 

“Mound 2001” are equivalent.
2.0 SUMMARY OF NIOSH POSITION ON DOSE RECONSTRUCTION 

The NIOSH Evaluation of Data Adequacy and Completeness Issues at Mound Laboratory

(NIOSH 2009) provides a detailed response to SC&A’s concerns regarding the presence of 

exotic radionuclides at Mound and gaps in personnel monitoring data. NIOSH’s position is 

summarized in NIOSH Response 1-1 of the document: 

The presence of various radionuclides at Mound is not sufficient to establish an 

exposure potential for each radionuclide. Several conditions must be met to 

constitute and [sic] exposure potential, including but not limited to: 

(1) the radionuclide must be present in sufficient quantity to present a 

dosimetrically significant hazard; 

(2) the radionuclide must have a sufficiently long effective half-life to present 

a dosimetrically significant hazard; 

(3) the radionuclide must be in physical and chemical forms that presents an 

exposure potential; 

(4) the radionuclide must be handled in a way that presents the potential for 

intake (e.g., access to the breathable atmosphere). 

The predominant internal exposure at Mound was to alpha emitters and tritium. 

Beta and gamma emitters played a very minor role in Mound activities, and for 

the most part exist in trace quantities in research and production-scale 

operations. 

Furthermore, NIOSH indicates that SC&A’s concerns are at odds with the History of Mound 

Bioassay Programs (Meyer 1992). NIOSH/ORAUT (NIOSH 2009) provided the following 

quote, attributed to Sheehan (2009b), as a description of the dose monitoring practices of the 

health physics group: 

For each of the radionuclides involved, Mound’s RAM section had an internal 

radiation dose assessment support program. All of these programs employed 

urinalysis as the source of data to estimate internal radiation exposure and 

evaluate the integrity of nuclear work station containment systems, process, 

procedures, techniques, ventilation management as well as employee job training 

and work attitudes. Radiological safety was made a pervasive, controlled 

atmosphere in which radioactive material was handled.” (Sheehan 2009, 

emphasis added).

SC&A has noted that the document referenced by NIOSH/ORAUT does not include this 

statement. Further conversations with Sheehan indicated that the only document provided to 

NIOSH from him in 2009 was Mound’s 24-Hour Urinalysis Program (Sheehan 2009b). Either 

NIOSH/ORAUT has misquoted Sheehan, or their reference is incorrect. 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

NIOSH also maintains that gross alpha results can be used to bound the dose for all alpha 

emitters at Mound where radionuclide-specific data are not available. Using the gross alpha 

result, NIOSH would attribute dose to the radionuclide that gives the most claimant-favorable 

organ dose for the organ in question (the one with cancer for which a claim is being submitted), 

with case-specific information being considered when available (e.g., where a worker worked). 

This approach would be used to bound doses for all isotopes of actinium (via daughters), 

americium, curium, protactinium, neptunium, radium, thorium, and uranium. 

Where bioassay procedures are unavailable for radionuclides handled at Mound, NIOSH 

repeatedly argues (NIOSH 2009): 

... processes with these materials were episodic in nature, not ongoing, therefore 

monitoring would only be required when activity was ongoing, or a significant 

residual exposure potential existed. 

At the work group meeting in January 2010, NIOSH stated that they are aware of no specific 

examples in which Mound operations posed a potential for exposure to radionuclides outside the 

scope of the Mound bioassay capabilities, and that such an assertion on SC&A’s part is 

contradictory to Meyer’s first-hand description of Mound’s radiation protection program. They 

referred meeting participants to their written response, specifically Attachment A, “Major 

Mound Source Terms and Radionuclides of Concern” (NIOSH 2009), and the table on page 24 

of NIOSH 2009, “Response to Items in ‘Application of Bioassay Methods by Radionuclide’ 

Table in ‘Data Completeness’ Not Covered in the Discussion of Gross Alpha/RadionuclideSpecific Alpha Bioassay.” Attachment A lists major Mound source terms, constituent 

radionuclides, and the major radionuclides of concern for each source term; it does not identify 

the locations or time periods in which these source terms produced exposure potential at Mound. 

The second document responds to specific issues or source terms raised in Mound Internal 

Dosimetry Data Completeness (SC&A 2009b). 

The current position held by NIOSH is that they can reconstruct dose received by all workers at 

Mound who were potentially exposed to exotic radionuclides, with the exception of radium, 

actinium, and thorium exposures from October 1, 1949, to February 28, 1959. Additional 

consideration is being given to radon exposures in R-Building and SW-Building; however, a 

formal determination was not issued as of the date of this report. NIOSH maintains that gross 

alpha analysis can be used in lieu of radionuclide-specific bioassay for all alpha emitters present 

at Mound. For other radionuclides, they maintain that they were only handled in small quantities 

and/or that there was no potential for exposure. 
3.0 RADIOLOGICAL HAZARDS AND EXPOSURE POTENTIAL 

NIOSH/ORAUT’s roadmap (ORAUT 2009) was compiled primarily to characterize radionuclide 

usage and associated bioassay coverage in response to SC&A’s Mound Matrix items. 

Information for the roadmap was derived from the Mound Site Radionuclides by Location (King 

1995), supplemental incident reports, and D&D-era RWPs. An additional source, History of 

Mound Bioassay Programs (Meyer 1992), was used to link potential exposures with bioassay 

techniques available at Mound, taking into consideration the quantities of radioactive material 

and established engineering and administrative controls. The roadmap columns include Location 

(building and/or room number), Program/Process, Time Frame, Radionuclides and Related 

Compounds, Quantity, Material Characteristics/Information, Bioassay Method, Exposed 

Individuals (number of individuals exposed), and Ref [Reference]. Incidents and other process 

information are listed under Material Characteristics/Information. RWPs from the D&D era 

(1995–2001) are listed as separate line items. 

A revision to the roadmap, provided to the work group in July 2009, includes or references 

information contained in Mound Site Radionuclides by Location, Appendix B (hereafter referred 

to as Appendix B, King 1998). Information regarding classified operations and activities for R, 

SW, SM, T, WD, and WDA buildings is discussed only in Appendix B of the King document 

(King 1998). Appendix B describes the extent of radionuclide processing activities, the chemical 

forms handled in processes and programs, and the impact of weapons program-related activities 

on worker exposure. This information is a significant factor in fully appreciating the processes 

occurring in R, SW, SM, T, WD and WDA buildings, but it is only accessible to individuals 

possessing appropriate clearance and a need-to-know. Information in Appendix B (King 1998), 

as summarized in the roadmap, has direct relevance to the handling, research and development 

(R&D), and processing of exotic radionuclides at the Mound Plant. 

During the January 5–6, 2010, Mound work group meeting, NIOSH indicated that the King 

document (King 1995) listed all isotopes that might possibly have been present in specific areas 

in order to support appropriate monitoring of D&D operations. NIOSH repeatedly emphasized 

that an isotope’s presence is not sufficient to constitute an exposure potential. They offered 

several examples in which activity could be present without posing a potential for internal 

exposure (e.g., sealed sources, fixed and painted contamination, drums in a burial ground). This 

approach essentially dismisses Mound Site Radionuclides by Location and the roadmap as 

evidence of exposure potential, and serves to mitigate, on their part, SC&A’s concerns about the 

adequacy of internal monitoring data. As evidenced in the following discussion, NIOSH 

maintains that gaps in bioassay data simply reflect intervals when there was no exposure 

potential, and requests that SC&A identify specific situations in which potential exposures were 

not appropriately monitored (ABRWH 2010, pp. 82–83): 

MS. ROBERTSON-DEMERS: Bioassay capabilities do not equate to actually 

collecting samples. 

DR. ULSH: So you're saying that there were situations where they should have 

collected samples and they didn't? 

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MS. ROBERTSON-DEMERS: Yes. 

DR. ULSH: Okay. Let's talk about those. Give me some examples. 

MS. ROBERTSON-DEMERS: I've given you an entire table where these things 

were noted as being handled in the Road Map, and there's no coverage of 

bioassay. 

DR. ULSH: Okay. So we're talking about the Road Map now. Again, as we 

discussed earlier, the Road Map lists any element, any radionuclide that could 

have possibly been in a particular room, not that there was a confirmed presence 

of it, but just that it was possible. 

And again, the piece that you are not considering is the exposure potential. If I 

walk through -- I'll use the same example again -- if I walk through a room, if I 

even stored in a room sealed sources, that does not equate to an exposure 

potential and it does not equate to a need to do bioassay. 

If the Road Map is your basis, you are misinterpreting the Road Map. 

In contrast to the statement above, the introduction to Mound Site Radionuclides by Location (the 

primary data source supporting the roadmap) outlines the following objectives (Mound 2001, 

emphasis added). 

There are three major objectives of this document. The first is to identify the 

radionuclides used in each of the rooms for each of the buildings at Mound. This 

will include a listing of all compound forms of each radionuclide for specific time 

frames because of specific programs, which are also identified. 

The second objective is to determine information about a given radionuclide 

which would facilitate internal dose assessment. This includes the compound 

forms with which the radionuclides are associated, information to indicate the 

probable lung solubility class, the relative abundance of radioisotopes in each 

room for a given time frame, and the particle size. 

The third objective is to compile all information about ground surveys and core 

sample results to indicate possible intakes at specific locations as a result of 

D&D and other work performed. 

When doing either a historic or current internal dose assessment for an 

individual, the records do not always indicate the details of an incident or a 

chronic condition. By knowing the approximate date and location of an 

exposure, this document can be used to determine which radioisotopes existed 

in the area. Since chemical, temperature and processing, and particle size all 

can affect the lung solubility class, this information is of great help in determining 

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the parameters used in the biokinetic model which predicts the internal dose from 

lung deposition. This information is also valuable for uptakes resulting from 

ingestion or wounds.

Furthermore, the overview for each building within Mound (2001) indicates that dates provided 

in the document are representative of usage of radionuclides and not necessarily residual 

radioactivity (Mound 2001, emphasis added). While not every usage of radionuclides poses a 

potential for internal exposure, SC&A maintains that dates listed in the King document (Mound 

2001) represent actual usage of radionuclides in active programs. 

All dates represent the duration of actual usage of radioisotopes in their 

respective projects. It is clearly understood that residual amounts of all 

radioisotopes referred to in each room may still be found in floors, walls, and 

ceilings and should be considered, up to the present, in every case for 

decontamination work.

During a recent interview with former workers, SC&A had the opportunity to discuss Mound 

Site Radionuclides by Location with one of the document contributors. This individual 

reaffirmed that the dates listed in the document represented the time period in which 

radionuclides were used, as opposed to being present as residual radioactivity. This individual 

clarified that the designation of major and minor radionuclides in the Mound Site Radionuclides 

by Location was determined based on the relative amount (i.e., quantity) of each radionuclide 

handled or processed. Although efforts have been made to contact the primary author, SC&A 

has been unable to locate him. However, the interviewee’s interpretation may be supported by 

considering the following assessments of hazards present in Room SW-22, the “New Cave:” 

 Describing the Cotter Concentrate program, King states, “Thorium-230 was the major 

radionuclide of concern with over 95% of the activity” (Mound 2001, Section 1, p 146 of 

320). 

 Another author reached a different conclusion, based on considerations other than 

activity: “Of all Cave Area radionuclides Pa-231 is of greatest concern. Although only a 

few milligrams are produced and stored each year a potential for exposure exists because 

of an RCG of 1 × 10-12 μCi/ml in air, only half that of Pu-238, and operations that do not 

provide for continuous containment” (Stought 1979). 

NIOSH’s characterization of the information in the King document (King 1995) seems to 

contradict statements drawn directly from the document. Interpreting King (King 1995) as 

listing all isotopes that “could have possibly been in a particular room” (ABRWH 2010) 

disregards the compilers’ efforts to associate active projects with specific dates, locations, and 

chemical forms in support of historic and current internal dose assessment. Furthermore, SC&A 

has found additional references that substantiate process descriptions and time periods provided 

in King (Mound 2001). NIOSH maintains that exotic radionuclides (other than plutonium, 

polonium, and tritium) were handled episodically. In contrast, King (Mound 2001) identifies 

ongoing operations and research involving exotic radionuclides over extended periods of time; 

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their usage in processes, research, and analytical programs extended from the 1940s to closure of 

the Mound facility. Since Mound Site Radionuclides by Location claims to represent actual 

usage in specific rooms associated with specific programs, and since several of these programs 

can be substantiated through other sources, it seems unreasonable to dismiss the information on 

the basis of an unsubstantiated interpretation. 

Table 1 lists several examples of programs and processes in which unencapsulated exotic 

radionuclides were handled or released in multiple locations throughout the Mound site. The 

table specifically identifies radionuclides and intervals for which no personnel monitoring data 

have been located to date. In some cases, there was a total absence of bioassay; in other cases, 

there were personnel who were not monitored handling material. Regardless of the bioassay 

capabilities available at Mound to detect internal uptakes, the availability of monitoring data

more accurately represents the adequacy of personnel monitoring at Mound and the feasibility of 

dose reconstruction. 

Furthermore, “dosimetric significance” must be considered in the context of worker 

compensation, rather than an operational internal dosimetry program. SC&A acknowledges that 

factors such as the activity of material handled (pCi, mCi, Ci, etc.), the established engineering 

and administrative controls, and the physical and chemical forms of material impact the 

dosimetric significance of an exposure potential. These factors must be taken into account 

through all stages of operations and handling, from receipt of radioactive material at the site 

through final disposal of radioactive and mixed waste. Processes which result in the separation 

of radionuclides and subsequent concentration of particular radionuclides, either intentionally or 

unintentionally, must also be considered. At times, separated material in the waste stream may 

contain higher concentrations of radionuclides than those identified for active process and 

operations activities, as outlined in Mound Site Radionuclides by Location (Mound 2001; King 

1995), and thus in the roadmap (ORAUT 2009) prepared by NIOSH. 

Although NIOSH has identified several factors that influence the potential for intake, they have 

not provided adequate information that would support an objective determination of the 

“dosimetric significance” of exotic radionuclides. Without this information or clear guidance 

from NIOSH, SC&A found it necessary to establish a working definition of “dosimetric 

significance” for evaluating exposure scenarios at Mound. The following factors were taken into 

consideration. 

 Neither the Act nor the associated rules for the EEOICPA program define a de minimus

dose for the compensation program. 

 The DOE presently requires bioassay submission based on a 100-mrem dose criteria for 

an operational dosimetry program. 

 During the Pre-1989 Dose Assessment Project, MJW Corporation identified H-3, Po-210, 

Ra-226, Ac-227, Th-228, Th-230, Pa-231, Th-232, U-233, U-234, U-235, U-238, Pu-238, 

Pu-239, Am-241, and Cm-244 as nuclides of dosimetric concern. This determination was 

based on a review of the bioassay data and procedures available at Mound, with a focus 

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on those workers potentially receiving an internal dose of 20 rem Committed Effective 

Dose Equivalent (CEDE) or greater (MJW 2002a). 

 Doses of less than 100 mrem can impact the compensability of some claims, taking them 

from non-compensable to compensable. 

Since Po-210, Ra-226, Ac-227, Th-228, Th-230, Pa-231, Th-232, U-233, U-234, U-235, U-238, 

Am-241, and Cm-244 were considered of importance in evaluating collective internal doses of 

20 rem or more, these isotopes are clearly of “dosimetric concern” at dose levels effecting 

compensation. A number of radionuclides that were present at Mound and lack monitoring data 

were not considered in the Pre-1989 Dose Assessment Project. Many of the beta- and gammaemitting radionuclides fall in this category. NIOSH has provided no objective evidence 

supporting their statement that these and other secondary and impurity radionuclides are of 

dosimetric insignificance, as NIOSH has claimed throughout NIOSH Evaluation of Data 

Adequacy and Completeness Issues at Mound Laboratory (NIOSH 2009) and repeatedly stated 

in work group meetings. Essential information for these exposure scenarios would include the 

relative activity of radioactive material handled, the ratios of “secondary radionuclides” to 

“primary radionuclides” in process and waste streams, and the engineering and administrative 

controls utilized to prevent exposure to “secondary radionuclides.” NIOSH responses to 

SC&A’s concerns regarding these issues have not been adequate to date. 

From SC&A’s perspective, a technical review involves a critical investigation of a program’s 

effectiveness based on available documentation. The task is to evaluate the program, not to 

presume that it was comprehensive and effective. NIOSH appears to take a different approach. 

They have dismissed Mound Site Radionuclides by Location as insufficient evidence of exposure 

potential, not by offering new documentation that more clearly defines specific times and 

processes, but by re-interpreting the document’s intent in direct contradiction of its internal 

claims. Data adequacy cannot be assessed without working definitions of exposure potential and 

dosimetric significance, along with mutually acceptable evidence defining when these 

circumstances were present. SC&A contends that Mound Site Radionuclides by Location

(Mound 2001) is the best available comprehensive characterization of radionuclide usage at 

Mound over its operational period. SC&A sees no reason to waste further time and resources 

searching for documentation to substantiate or replace it. “Episodic use” could certainly explain 

fluctuations in the number of bioassay samples for a particular radionuclide from month to 

month or year to year, but this argument cannot explain away years (even decades) without 

specific bioassay data when available evidence indicates active usage of the isotopes. 

3.1 POTENTIAL FOR EXPOSURE 

During the January 5–6, 2010, meeting, NIOSH indicated that they see no evidence of potential 

exposures from exotic radionuclides during years when personnel monitoring was absent. 

Further information is provided in NIOSH Evaluation of Data Adequacy and Completeness 

Issues at the Mound Laboratory (NIOSH 2009). SC&A was asked to provide specific examples 

where there were potential exposures in the absence of internal monitoring. As with “dosimetric 

significance” in the preceding section, SC&A was obligated to adopt their own working 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
definition of “exposure potential” in the absence of specific direction from NIOSH or the work 

group. The operational exposure potential, as defined in this review, is exposure to 

unencapsulated radioactive material. Other considerations taken into account include: 

 Positive contamination surveys 

 Positive air sampling results 

 Radionuclide quantities (where available) 

 Bioassay monitoring requirements in the 1990s/2000s for the same area 

 Radionuclides with half-lives >30 days 

The effectiveness of administrative and engineering controls is another significant factor in 

defining potential exposures. As with other sites, Mound had numerous incidents indicating 

insufficient engineering and administrative controls. Repetitive incidents and poor radiological 

control design are indicative of a potential for exposure. Mound has a demonstrated history of 

radiological control failures site wide. Concerns regarding glovebox design and materials are 

discussed in detail under the polonium impurities section. Several additional examples are 

provided below. SC&A’s purpose in citing these examples is to demonstrate weaknesses in the 

general radiological controls implemented at the Mound plant. The examples demonstrate 

inadequacies affecting facilities, procedures, containment, contamination control, 

implementation of corrective actions, and respect for posted hazards. While many of these 

examples took place within “primary” programs, such as plutonium production, where routine 

internal monitoring was in place, SC&A has no reason to assume that controls for “secondary” 

separations, research, and waste programs were so superior as to eliminate exposure potential for 

the workers involved. 

3.1.1 Engineering Controls 

Problems with hoods at Mound being improperly exhausted were discovered as late as 1977 

(Kosuszek et al. 1977). 

On October 17, 1977 Safety was notified by Engineering of their discovery that an 

exhaust duct from two fumehoods located in E-l07 was tied into the building's 

general recirculating room air system. This could be a risk of potential exposure 

to building occupants. From the facts found in this investigation, the committee 

also recognizes that other improper tie-ins may exist, especially wherever 

building ventilation systems have been modified, and therefore, recommend that 

an inspection program be implemented. 

At times, dryboxes became pressurized, which could lead to loss of containment and spread of 

contamination. Such an incident occurred in R-120 after workers changed an argon tank used to 

provide an inert atmosphere in the drybox. Pressurization of this drybox caused a glove to be 

blown off, resulting in the contamination of workers, as well as five visitors in the room. “In 

addition to Room 120, Room 120B, the west corridor, and Rooms 155 through 159 became hot” 

(Freeman et al. 1960). 

 

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Airflow at Mound was not always towards the area of maximum contamination potential. This 

was shown by a 1963 incident in R-149. The investigation into this incident found that an argon 

supply change pressurized a drybox and blew off a glove. In this event, “a slight positive 

pressure in room 149” caused some contamination spread to Room l50-5l and corridor 5 (Butz et 

al. 1963). 

The flow control of Mound’s dryboxes does not appear to be up to modern standards, as 

indicated by the following incident (again in R-120). In response to an internal uptake of 

approximately 15 rem that occurred during routine operations, the investigating committee 

concluded that the incident likely occurred when personnel were using a fumehood to introduce 

samples into a drybox line. The committee’s findings included the following concerns 

(Wainwright 1973): 

 This fumehood is serviced by a forced air ventilation supply line, and the 

airflow rate into the hood from the room was observed to be substandard and 

variable. The supply line valve was found to be partially opened. These 

factors probably combined to provide a short reversal of airflow in the 

fumehood which resulted in a release of fine radioactive particulates to the 

laboratory. 

 A second possible source was a small hole found in one of the glovebox 

gloves. 

 A contributing factor to the exposure of the personnel was the turbulent 

airflow patterns caused by the room air supply systems which tended to 

spread the airborne contamination throughout the room. 

At times, facilities did not undergo adequate re-design to accommodate new materials being 

handled. According to an investigation report of a spill in R-149 (Bigler et al. 1960): 

It was obvious from this investigation that the facilities for performing the work 

done in R-149 are inadequate. Contamination levels have been high in this lab at 

various times since this program began. It has been standard practice to require 

the wearing of respirators. The closed hoods used in this lab were not designed 

for the material being handled in them and do not afford proper protection or 

permit good handling techniques.

Lessons learned from incident investigations did not necessarily result in effective, 

comprehensive corrections. A pressurized drybox incident in SW-13 in 1970 prompted the 

following observation (Madding and Carfagno 1970): 

There is a striking similarity between this incident and one that occurred on the 

R-l27, 149 inert system on February 27, 1968. Applying the intent of the 

recommendations of the incident report to the SW-13 inert gas system, especially 

#4, would have prevented the SW-13 incident. 

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The SW-13 incident report also mentioned that Mound had not characterized a material that had 

been released to the room from the incident (Madding and Carfagno 1970). 

Room decontamination and monitoring were complicated by the metallic 

compound released from the vacuum boxes. While the use of respirators and 

protective clothing which occurred is considered reasonably safe, the hazards of 

this material have not been defined as indicated by discussions with the involved 

personnel. 

Although the recommendations from the R-127 and R-149 incident report were considered 

appropriate to have prevented the event in SW-13, it is interesting to note that the inert system in 

the R-Building labs experienced an extreme pressurization incident only 1 month after the 

SW-13 report. Over a period of 4 days in November 1970, pressurization of an inert atmosphere 

hood line cracked two hood fronts in R-127 and caused a hood front blowout in R-149. The 3/8” 

Lucite hood front ruptured into several sections, with pieces blown up to 10 feet from the hood. 

A primary contributing factor was that, “Budgetary considerations forced using a common 

purifying and pumping system for two separated installations with ‘too many marginally safe 

procedures on this system.’” A researcher troubleshooting the system pressure concern 

selectively closed off each hood in R-127 while noting pressure changes on a Photohelic gauge. 

“Unfortunately, closing off this last hood deprived both the hood line in R-127, as well as in 

R-149, of any relief valving since the bubbler in R-127 is in the Photohelic line and the bubbler 

in R-149 [recently removed and sealed off due to a silicone oil leak] had not been replaced.” 

Multiple corrections to the system, including independent bubblers for each box line and an 

independent purification system for the R-149 hood line, were recommended by the investigation 

team (Fauble et al. 1970). 

The gloves used in dryboxes often had failures, which could lead to the spread of airborne 

contamination. In the following example, the incident investigation committee noted that the 

dryboxes were not kept in an orderly state (a great deal of trash was noted), and this incident was 

compounded by the lack of a functional contamination survey instrument in the area 

(Abrahamson et al. 1964). 

At approximately 12:20 a.m. on October 1, 1964, the air monitor registered a 

high level of contamination in the R&R Building. The high level was first 

believed to be caused by the release of activity through a hole in a glove which 

was accidently produced by [name redacted] while working in an alpha box on 

recoverable trash. The contamination of R&R Building was caused by an 

accidental puncture of a glove by [name redacted]. 

Another glove failure occurred on June, 29, 1970, resulting in a release of plutonium-238 activity 

in the B-2 laboratory of the PP-Building. This particular incident was classified as a “near miss,” 

because nose wipes indicated potential internal uptakes. “The primary cause of this 

contamination release was thought to be a hole, too small to be detected by the unaided eye, in 

one of the glovebox gloves in either glovebox 041 or 042” (Freidline et al. 1970). 

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An incident at SM-35 occurred while the integrity of a glovebox glove was being checked 

(Amos et al. 1963). 

In alpha box 7 a small pinhole was noted in the left hand glove and [name 

redacted] slowly brought his hands from the gloves to avoid spreading 

contamination. However excessive talc (used to aid in "sliding" in and out of the 

gloves) in the glove caused a puff of talc to come out into the room. Previously 

cold areas of the room were now contaminated including the floor, the hood 

fronts, and other alpha box gloves. The alpha air particulate monitor, 10–12 feet 

away showed an increase of 30,000 counts per minute. 

In some cases, glove failure was a result of poor maintenance, rather than a specific accident or 

event. A glove failure in SM-59A was discovered when an air monitor alarmed when a worker 

removed his hands from Box 8. Surveys indicated that Box 8 was not the source; previous work 

in Box 14 had resulted in the spread of contamination. Some personnel who had already left the 

work area were requested to return to Room 59A for survey by health physics and were found to 

be contaminated. Among the conclusions of the investigating committee (Mershad et al. 1966): 

The direct cause of the incident was the opening up of a crack in the upper left 

hand glove of box #14. After the glove was changed, a visual inspection by [name 

redacted] revealed a crack about l/l6th inch in length along the inner side of the 

glove thumb. It was described as typical of a hole which develops from the 

deterioration or strain of the glove material over a period of time, and there was 

no evidence that the glove was cut or punctured. 

Drybox seals were also known to fail. For example, an incident in PP-Building A-1 laboratory 

was categorized as a “near miss,” because “one Electronics Technician received a high nose 

wipe” (Kell and Combs 1971): 

The contamination levels in Gloveboxes R-007 and R-006 and the subsequent 

contamination to [name redacted] was the direct result of an unsealed service 

penetration into Glovebox R-007. This penetration had been previously sealed 

but the sealant obviously had deteriorated to the point of opening up again. 

3.1.2 Work Practice Controls and PPE 

Work practices and PPE in low-activity environments could be less stringent than those used in 

production areas. A contaminated acid burn in an analytical lab in PP-Building resulted from a 

technique and PPE that were not adequate for handling concentrated acid solutions. A health 

physics surveyor monitoring an [redacted] technician used his hand (with a surgical glove) to 

dip a wipe into a spill of 8N nitric acid. The acid penetrated the glove, resulting in a 

contaminated burn. An inter-office communication from Health Physics recommended that 

“orange” latex gloves, rather than surgical gloves, should be used for fumehood work, noting 

that, “Analytical is the only area where surgical gloves are used.” A secondary correction was to 

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write a procedure specifying the use of tweezers or tongs in addition to heavier gloves when 

monitoring work with liquids (Davis 1974). 

An unfinished and forgotten maintenance effort appeared to cause a 1963 contamination incident 

in SM-Building. The accidental disturbance of a plastic bag that had been used to seal what was 

believed to be an old vacuum line resulted in widespread contamination of the low-risk side of 

SM-Building. High levels of contamination spread to Rooms 21, 10, 38, 39, 17, 18, 9, and 

corridor 40, as well as other adjoining rooms. It must be noted that although this incident 

involved gross contamination and possible internal uptakes, it was made reportable only on the 

basis of cleanup costs (Chong et al. 1963). 

Based on the findings it appeared this line had been cut, then the open end sealed 

with a plastic bag. Examination revealed a brittle bag, brownish yellow green in 

appearance. It appeared that solution was present in the bag some time ago and 

had since dried to form oxide dust. A slight touching of the bag caused it (the 

bag) to flake and disintegrate. This line was rebagged with three polyvinyl glove 

port covers. Counts in the immediate vicinity were well over 2 million. 

A metal tritide contamination incident in R-Building went undetected for 2 days. On September 

6, 1978, a worker broke a capillary containing “a maximum of 0.3 Ci of tritium as a metal 

tritide” while attempting to straighten it in the rotating anode fixture. This sample, in addition to 

five other samples received on three different dates, was incorrectly presumed to be a deuteride 

sample, rather than a tritide sample. The worker notified two individuals of the break, one of 

whom returned the call the following day. “Since there was data on the duplicate sample, no 

request for additional analysis was made. No one expressed any concern about a possible spill.” 

Two days later, two researchers discussing analytical results became aware of the 

misunderstanding about sample identity; one of these researchers recalled the sample break and 

requested a survey to investigate the possibility of contamination. Health Physics confirmed a 

spill and determined that contamination had been tracked throughout the R-Building corridors. 

Findings emphasized poor communication and labeling, resulting in the sample analysis being 

conducted in an uncontrolled area without special handling (Pardieck and Sheehan 1978): 

 Verbal communications between requestor and x-ray laboratory personnel did 

not establish identity of samples and requirement for special handling. 

 Form 5188, Radioactive Material Transfer Tag, was not attached to the 

samples and did not accompany the samples to R-Building. 

 The word tritide written on the request for analysis form was overlooked or 

misinterpreted by x-ray laboratory personnel. 

 The analyst did not review request for analysis form prior to performing 

analysis. 

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Ineffective passbox procedures led to a widespread contamination of T-Building. This incident 

was not detected when it occurred; the contamination was detected during routine surveys at a 

later time. The investigating committee also noted that no functional alpha survey meter was 

present in the area at the time of the incident (Heidelberg et al. 1964). 

Radioactive contamination which was discovered spread widely throughout the 

"T" Building on June 11 was released from the passbox area of the south cell. . . 

The most probable method is the accidental drag-out of some of the highly 

contaminated damp debris left in the box. This damp material was then tracked 

throughout the building on the shoes of personnel. The spread throughout the 

building was speeded by the fact that Stairway 13 has been used by large numbers 

of persons not involved in cell operation; as a traffic route between the first and 

second floors of the "T" Building. 

A contamination event in corridor 16 of the PP-Building was attributed to lack of a procedure for 

the work being performed and a lack of communication as to how the task would be 

accomplished. The event occurred while pipefitters were removing contaminated drain pipes. 

The investigating committee noted that it was normal practice for workers to select from several 

different tools to cut or break a 4-inch cast iron soil pipe. The pipefitters on this occasion chose 

to use a sledge hammer rather than a soil pipe cutter. Lack of operating survey equipment was 

also an issue in this incident (Bond et al. 1986): 

If the pipefitters normally make the decision in the field, an adequate number of 

optional tools should be close at hand and immediately available and guidance on 

restrictions should be provided. Methods or options, if to be selected on the job, 

should receive advance approval from the project engineer. All parties involved 

in the operation need to be made aware of approved methods. 

There was not an operating survey meter in the area due to portable alpha 

counter window contamination problems; steps should have been taken to solve 

the window contamination problem. 

Even routine maintenance activities could, and sometimes did, cause widespread contamination 

events. For example, the changing of roughing filters on several dryboxes in SM-35 resulted in 

elevated nose wipes (potential internal uptakes) from 19 people in the low-risk area of the 

building. The filters were changed out using what is now considered a standard bag out method. 

It must be noted that at the time, no written procedure existed for performing filter changes; the 

methods were the result of passed-on knowledge. Airborne contamination was determined to 

have spread from room 35 into rooms 34, 26, 19, 20, 15, 9, 10, 40, 11, 28, 2, 3, 28, and 38. 

Because of the rapid spread of airborne contamination, the investigating committee 

recommended a thorough investigation of the building ventilation system, with the findings or 

recommendations of such an investigation to be carried out as soon as possible (Meyer 1964). 

Waste containers were known to rupture outside of areas considered contaminated. Room 26 in 

the following example was not normally surveyed, because it was not an operating area. The 

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trash had produced enough pressure to split open the metal can containing it, and the committee 

concluded that tracking caused the spread of high levels of contamination (Rogers et al. 1965): 

At approximately 9:15 A.M. February 26, 1965 a package of hood trash was 

discovered to be ruptured in an open drum located in room 26 of the SM building. 

The incident resulted in the release of activity into the room and caused minor 

external contamination of an AEC visitor and four Mound Laboratory personnel. 

Furthermore (Rogers et al. 1965): 

 Rooms 26, 34 and 19 were severely contaminated (>1,000,000 c/m on the floor); 

adjacent laboratories and corridors were contaminated to a lessor [sic]extent. 

Most contamination outside of room 26 was probably caused by tracking of 

evacuating personnel. 

And (Rogers et al. 1965): 

The ruptured #12 can (marked "burnable 2-24-65") was split down the seam and 

around the top and bottom. The lid of the inner container (press lid can 5-7/16" 

diameter × 5-7/8" high) was off and trash was scattered in the drum. The 

containers were deformed indicating pressure had built-up in the package. The 

other packages marked "burnable 2-22-65" also contained wet paper and were 

beginning to bulge slightly. 

Activities other than major production campaigns have been known to produce exposure 

potential. Even work with sealed sources is not immune from accidents. An actinium spill 

occurred in R-114 when a source being used for gamma experiments leaked in the safe in which 

it was being stored. “The source itself consisted of actinium perchlorate in a water solution total 

volume being 6 to 8 ml., contained in a ground-glass stoppered flask about 10 mL in volume. 

The flask was contained in a brass cylinder with a threaded stopper, which had been greased.” 

After health physics arrived, an air sample was taken. “The air sample was too hot to count so 

complete protective equipment was used” (Madding and Carfagno 1970). 

3.1.3 Safety Culture 

Disregard for radiological posting exacerbated some incidents, as was cited for a spill in R-149 

(Bigler et al. 1960): 

A spill of radioactive material in Room-149 of the "R" Building during the 

morning of May 19, 1960 resulted in the contamination of the floor of the lab and 

the adjoining corridors. ''Danger - Radioactivity" signs were used to mark off the 

area of contamination and decontamination of the corridor was started 

immediately. Despite the placement of signs, some of the personnel in the 

building continued to track through the contaminated area while it was being 

decontaminated, thus hampering the clean-up operation. In one case, an 

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employee failed to comply with a health surveyor's request not to walk in the 

contaminated portion of the corridor.

In 1973, the area manager for the Atomic Energy Commission (AEC) expressed concern about 

workers’ disregard for standard procedures in regard to an uptake incident in R-120. He wrote to 

the Mound director (Wainwright 1973): 

I feel it necessary to bring to your attention an attitude of disregard for standard 

procedures which was clearly displayed at the time of this occurrence. Although 

this attitude may have had little or no effect on the degree of seriousness of this 

incident, such laxity of discipline can be expected to increase the potential for 

subsequent problems, if allowed to continue. 

A 1964 contamination incident in SM-35, like several other incidents described above, was 

exacerbated by lack of a functional alpha survey meter. The incident was detected after the fact 

by an air monitor alarm just outside the low-risk change room. The change room and shower 

area were determined to have been lost to airborne contamination when workers were found to 

be even more contaminated after showering. The investigating committee noted, “The rule that 

‘No Operating Monitoring Devices - NO WORK’ should be strictly enforced.” It seems that this 

rule was routinely ignored at Mound. Another statement in the investigating committee’s report 

raises doubts about the adequacy of air monitoring practices and contamination control with 

respect to workers’ breathing zones: “Four constant air monitors were operating, but the 

background level of the building was of such magnitude that the warning bells had been turned 

off or were malfunctioning. The instrument controls were set so that no warning light would 

flash unless the contamination level reached the highest level recorded by the instruments” 

(Meyer 1964). 

 

At times, areas were posted to require respiratory protection when work resumed in an area 

before decontamination from previous accidents was completed. For example, “The 

development laboratory has been a respirator area most of the time for the past several months 

due to the material being handled and because of the several radioactive spills which have 

occurred” (Witzerman et al. 1963). 

3.1.4 Explosions and Fires 

Contamination was likely to have spread to normally inaccessible areas, such as above ceiling 

panels, electrical raceways, and crawl spaces, due to a number of incidents involving explosions 

and/or fires (Fiely et al. 1966). 

The Committee investigated an incident which occurred on October 21, 1966, 

yellow control side, Room 21 of the Special Metallurgical Building. The incident 

resulted in a release of Plutonium-238 of unknown quantity when a double 

contained vessel nearly full of drybox sieved material intended for recovery of the 

isotope exploded and dispersed a quantity of the waste material in the south 

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NOTICE:

portion of the laboratory. . . A large quantity of the material was adhering to the 

ceiling above the point of explosion.

Room 21 was highly contaminated especially in the south end where the explosion 

took place. [Name redacted], the Health Physics Supervisor for the "SM" 

Building, initiated an immediate survey of the entire building. The results 

indicated that Corridor 40, side Corridor 41, and the south end of Corridor 66 

were contaminated. 

Another example of an explosion took place in R-116A. It involved a source M-218, a standard 

5-curie plutonium-239 unit. The source contained 80.0 g plutonium metal and 39.37 g beryllium 

metal in a welded tantalum cylindrical capsule. Workers were attempting to re-can this sealed 

source when it exploded. “Contamination of the room was severe, but was almost confined to 

R1l6A and R1l6” (Blanke et al. 1960). 

An explosion and fire in SM-38 lifted the false ceiling panels across the room. As a result of the 

explosion and fire, contamination was spread to room 38, corridors 66 and 41, and to a lesser 

extent, the yellow production areas of the SM Facility. It is likely that contamination spread to 

the areas above the ceiling panels and to other areas affected by air exchange as a result of the 

concussion wave of the explosion. The investigating committee requested cessation of “all spent 

anion exchange resin drying operations” and “a demonstrated safe disposition of the spent 

nitrated resin” (Ofte et al. 1965). 

During the opening of a calorimeter can, a mild explosion caused contamination spread in SM10. Only one can was open of four, each of which contained about 8 g of plutonium oxide. 

Significant levels of contamination were detected in adjacent areas, “the corridor outside room 

10 and extending the full length of the low-risk corridor, rooms 2, 9, 18 and 21. All of which 

showed a rise in airborne and surface contamination, low to intermediate levels.” The 

investigating committee could not determine a conclusive cause for the spread of contamination 

to room 2, but they concluded that it must somehow share an air supply with the corridor (Adams 

et al. 1962). 
4.0 RADIUM, ACTINIUM, AND THORIUM USAGE BEYOND 

FEBRUARY 28, 1959 

NIOSH has acknowledged a single class of employees for which they cannot estimate radiation 

doses with sufficient accuracy. “NIOSH cannot estimate internal Ra-Ac-Th exposures from the 

arrival of K-65 sludge in October 1949 through February 28, 1959, when the related area of work 

was decontaminated and decommissioned and sufficient monitoring was in place” (NIOSH 

2007). 

Although the major production campaigns associated with Ra-226, Th-228, and Ac-227 occurred 

prior to March 1959, exposure to these radionuclides continued well beyond the NIOSHproposed SEC period, whereas the availability of isotope-specific bioassay data dropped 

dramatically. Actinium and thorium separation/production continued throughout the 1970s. 

Research and development, waste management, and decontamination activities took place 

throughout much of Mound’s operational history. Collectively, these programs involved direct 

handling, contamination potential, and known environmental releases. Specific examples 

include: 

 Th-229 extraction from U-233 occurred from 1966 through 1981 (Mound 2001). 

 Th-232 was used as a substitute for Pu-238 in R&D and analytical programs in the 

plutonium processing area from the early 1960s through 1980 (Mound 2001). 

 Ac-227 was processed and shipped between 1964 and 1970. It was also used in 

analytical programs from the late 1960s through plant closure (Mound 2001). 

 Cotter Concentrate, processed for rare isotope extraction from 1970–1979, contained 

isotopes of thorium, actinium, and radium (along with other exotics discussed below). 

Mound had more than 1,000 drums of this material on site (Stought 1979). 

 Thorium ore and sludge from the 1955 Thorium Refinery program remained on site until 

1975. This corrosive material deteriorated drums. Re-drumming campaigns, as well as 

material transfers into and out of the bulk storage facility, occurred from 1955 through 

1975. Leaking drums and material transfers produced extensive soil contamination. 

Hazardous levels of radon and thoron have been found in some facilities (Mound 2001, 

Abbott 1990, Draper 1994). 

In addition to Th-229, Th-230, and Ac-227 extractions identified above, several other 

radioisotopes were processed at Mound. The Cotter Concentrate program extracted Pa-231, as 

well as Th-230. Despite relatively low quantities, both Th-230 and Pa-231 were identified as 

radionuclides of concern. According to Stought (1979): 

Several hundred grams of this mixture [Cotter Concentrate] are extracted and 

stored each year. The bulk of it, 97%, is thorium-232 which has a very long halflife and so is of little concern. But the remaining 3% is thorium-230 whose RCG 

for airborne contamination is the same as for plutonium-238, 2 × 10-12 μCi/ml 

air, and so the mixture must be treated with respect.

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Of all Cave Area radionuclides, Pa-231 is of greatest concern. Although only a 

few milligrams are produced and stored each year a potential for exposure exists 

because of an RCG of 1 × 10–12 uCi/ml air, only half that of Pu-238, and 

operations that do not provide for continuous containment. 

Contaminated soils and buildings could potentially expose Mound workers long after operations 

were discontinued. For example, the corrosive sludge from the thorium refinery project was 

removed from Building 21, repackaged, and shipped off site in 1974–1975 (Mound, no date). 

The interior was washed and painted, and the facility was used to store drums of Cotter 

Concentrate from 1976–1987. According to a 1987 memo, health physics personnel made 

regular entries into Building 21 to conduct radiological surveys and air monitoring. Shoe covers, 

smocks, and smoke-checked respirators were required for brief entries (Draper 1987). In 1990, a 

request to use Building 21 for storage of low-level boxes was contra-indicated, because high 

levels of Rn-220 (thoron) appeared to necessitate supplied air, which was not available at 

Building 21. Additional concerns included potential thoron penetration of respiratory protection 

equipment and inadequate means to detect and quantify potential intakes (Abbott 1990). A D&D 

characterization report from 1996 states, “Radon levels inside Building 21 have been reported as 

high as 2.0 Working Levels. The source of this contamination is due to the delivery, storage, and 

removal of the Bulk Thorium Sludges” (EG&G Mound 1996). Since the conditions in the 1990s 

were attributed to residual contamination from the bulk storage of thorium sludge, and detection 

of thoron uptake was not considered feasible in 1990, SC&A assumes that these conditions were 

present during the intervening years, potentially exposing workers who participated in 

decontamination efforts, radiological assessments, and handling of the Cotter Concentrate drums.

The ER indicates that in-vitro urine data are the primary source of information to support dose 

reconstruction, and outlines bioassay program requirements associated with specific projects. 

For example, a bioassay program for Pa-231 required monthly bioassay for research personnel 

involved in Pa-231 extractions between 1956 and 1960 (NIOSH 2007); SC&A has located 

bioassay data for Pa-231 from 1955–1959. However, Pa-231 was utilized in analytical work in 

R-120 and other production and development areas from the late 1950s through the late 1960s; it 

was chemically extracted from Cotter Concentrate in SW Building from 1970–1979; and it was 

separated, characterized, and analyzed in R-Building from 1956–1987. A site expert interview 

conducted by NIOSH indicates that workers performing Pa-231 separations were concerned 

about uptakes and desired a bioassay program (NIOSH 2008a). However, no Pa-231 bioassay 

data have been found for the years between 1959 and 1993. 

A bioassay program for Th-232 sludge re-drumming calls for Thorium Refinery personnel to 

provide 24-hour urine specimens on a monthly basis. According to NIOSH (2007), “several 

hundred drums were periodically re-drummed in the summer months between 1954 and 1966.” 

Some drums remained in use after construction of Building 21 for bulk storage; at least 117 

leaky drums remained outside Building 21 as late as 1973 (Mound, no date). Even 

acknowledging the seasonal nature of this work, the limited quantity of available bioassay data 

does not appear adequate to represent monthly bioassay samples from all participating personnel 

throughout the duration of this mission. 

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It is interesting to note that bioassay data for “other” radionuclides were far more prevalent 

during the proposed SEC period than during later years. There were 238 Th-232 bioassay results 

for the SEC period, based on the MJW other radionuclide files alone. In contrast, a total of 84 

sample results were located by SC&A for Th-232 for the period from 1960 to 1967 in the Data 

Base of Excretion Data of Other Radionuclides (ORAU 2003a) and the Database of Ra-Ac-Th 

Excretion Data (ORAU 2003b), as well as logbooks and bioassay reports. No results were 

located for 1962. Similarly, there were 180 bioassay results for Th-230 during the SEC period; 

there were no sample results for the 1960s and 1970s, when Th-230 was utilized in analytical 

programs and was extracted from Cotter Concentrate. 

An uptake incident from October 1978 demonstrates that radium, actinium, and thorium 

continued to pose an exposure potential well after decontamination and entombment of the 

former processing facility. The incident summary reviewed by SC&A does not clearly indicate 

the location or work activities of the exposed individual, although it refers to a prior health 

physics audit of the “Cave Area.” This seems to imply that the exposure may have been related 

to legacy contamination from the entombed Old Cave, rather than current processing or research 

(Jenkins 1978). 

A gamma scan of the nosewipe indicated the presence of Ra-226. An analysis of 

the nosewipe by alpha spectroscopy indicated the presence of Po-2l0, Th-230, 

Ac-227, Th-227, Ra-223, Ra-226 and U-238. 

A gamma scan of plaster from the area indicated the presence of Ac-227. 

An analysis of the air filter after 11/2 [at least 4 days post exposure] by alpha 

spectroscopy indicated the presence of Po-210, Th-230, U-233, U-238 and the 

following decay products of Ac-227: Th-227, Ra-223, Rn-219, Po-215 and Bi211. 

In an effort to minimize the chances of missing one or more of the nuclides that 

may have been present in the urine, the chemical procedures used to prepare the 

urine samples were not the same as is used routinely; therefore, a comparison of 

these data with data from the subject's routine urine samples would not be 

meaningful” (Jenkins 1978). 

The incident summary also indicates a potential for loss of control of internal monitoring 

samples: “The nosewipe was set aside in the counting room without its identification.” The 

author’s confidence in the correct identification of the nosewipe is “quite high,” because “it was 

the only positive nosewipe observed in the last month,” and because alpha spectroscopy for the 

nosewipe and the air filter resulted in a similar mix of radionuclides (Jenkins 1978). 

The health physics report for this incident does reflect a diligent effort to evaluate the 

individual’s internal exposure, and the analysis conservatively estimated an uptake of less than 

1% of a maximum permissible body burden. However, the incident demonstrates that D&D of 

the Old Cave in 1959 did not eliminate exposure potential to airborne actinium, radium, thorium, 

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and their decay products. The event also indicates that standard bioassay procedures in the late 

1970s were not capable of detecting all of these radionuclides. Communication among workers, 

supervisors, field health physics, and the bioassay lab would be essential for ensuring that correct 

(non-standard) procedures were used to analyze for exotic radionuclides. Since these isotopes 

were actively handled in research, analytical procedures, separations, and waste management 

well beyond 1959, SC&A maintains that these isotopes represent an inadequately monitored 

exposure potential. 

The ER and subsequent white papers have not demonstrated that quantities handled were 

insufficient to affect worker dose. The responses NIOSH has provided to date do not satisfy 

SC&A’s concerns regarding the feasibility of assigning dose in the absence of personnel 

monitoring data. 
5.0 URANIUM AND TRANSURANICS (AM-241, CM-244, NP-237, 

U-233, U-234, U-235, AND U-238) 

Uranium-233 projects occurred in 1958 and 1959 and from 1966 through the late 1970s. 

Uranium-234 was produced from chemical separation of aged Pu-238 from 1962 to 1979. Other 

isotopes of uranium, such as U-232, U-235, U-236, and U-238, were also handled at Mound. 

Several U-234 separation campaigns occurred at Mound in R-Building and SM-Building. The 

petition evaluation report identifies U-234 separation from Pu-238 occurring from the mid-1950s 

to 1972 (NIOSH 2007, pg. 24). A pilot program for separating U-234 from Pu-238 by tri-butyl 

solvent extraction and ion exchange was conducted in SM-Building from 1965–1970; the 

ensuing production occurred in R-Building from 1970–1980 (Mound 2001). Uranium-234 was 

listed as being present during compatibility studies involving assembly and disassembly of heat 

source units and “hot” metallographic analysis (Mound 2001; Wagner and Stought, no date). A 

successful U-234 separation process and investigation of a second extraction process were 

reported in 1963 (Eichelberger 1963). According to Mound Facility Activities in Chemical and 

Physical Research: July-December 1979 (Mound 1980), “Mound Facility has been separating 

and recovering high-isotopic purity uranium-234 from aged plutonium-238 since 1964.” Gram 

quantities of high-isotopic purity U-234 were shipped to Oak Ridge National Laboratory at least 

through 1979. 

Isotopic separation of uranium isotopes, especially U-235 and U-238, using a chloride separation 

technique occurred in R-Building starting in 1980. This project also involved work with Pm-147 

and calcium separation analysis (Mound 2001). 

One of Mound’s primary missions was to produce tritium for the weapons program. Research 

and development activities for this program utilized metal tritides, including uranium tritide. 

Facilities for tritium recovery also involved the use of uranium in the R-Building, SW-Building, 

and T-Building. King (Mound 2001) lists uranium as a secondary radionuclide of concern 

during these operations, behind tritium. Uranium beds containing pulverized powder were used 

as storage beds in the tritium program. Enriched uranium, in the form of metal and scrap, was 

listed on an inventory in 1963 (Blanke 1963). 

The report of a small uranium fire in SW-Building provides some details of interest regarding 

uranium handling and monitoring in the tritium program. The incident investigation report 

indicated that the uranium that ignited had been treated no differently than previous uranium 

samples. The tritium was removed from the uranium tritide complex by heating, and the 

uranium cooled to room temperature in a reaction vessel. The material in the reaction vessel was 

approximately 0.3 grams of fine powder. Air was introduced to oxidize the uranium; a red glow 

was observed. The uranium was then left open to air in a fume hood from Friday until Tuesday 

morning. An individual shook the reaction vessel and poured the uranium into a plastic waste 

bottle, which contained oxidized waste from approximately 10–15 previous thermal 

decompositions. Turning away after pouring the uranium into the bottle, the worker saw a red 

glow reflected in the glass front of an instrument (Nunn et al. 1980): 

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He turned around and saw a flame rising about two inches above the mouth of the 

plastic waste bottle and the entire bottle glowing red. He warned [name 

redacted] to evacuate the area. As [name redacted] walked past the burning 

plastic container, he tried to pull it out of the hood with his hand into a fire 

retarding trash container located in front of the hood. Some of the burning 

material fell outside the trash container to the floor and on a chair near by. A 

paper schematic on the chair was ignited, and the material on the floor continued 

to burn. 

The [redacted] individuals extinguished the fire while another worker called for emergency 

assistance. There were no firm conclusions as to why the uranium had not completely oxidized 

in the reaction vessel (Nunn et al. 1980). 

Urine samples were collected from [redacted] individuals involved in the incident. The samples 

were analyzed for tritium uptake (increases from background were judged to be insignificant). 

No uranium bioassay data are available, despite the fact that all material in the waste container 

had undergone thermal decomposition, which was known to remove “greater than ninety-nine 

percent of the tritium.” It appears that radiological monitoring for this situation, from a beta 

monitor in the room to the urine bioassay, focused exclusively on tritium, while ignoring the 

uranium. 

There are uranium urinalysis data from 1958–1959, 1965–1966, 1972, 1984, 1989–1991, and 

1993–2006. There is limited radionuclide-specific data for U-233, and no specific data for 

U-234 prior to 1966. Ten workers were monitored for uranium during 1958 and 1959, and five 

samples labeled as U-233 were processed during 1965 and 1966. After 1966, there is a gap 

broken by one uranium bioassay in 1972 and samples collected for several individuals in 1984. 

No U-234-specific bioassay program was associated with the U-234 processing from 1954–1958 

(within the proposed SEC period) or from 1970–1980 (well after the proposed SEC period). 

Beginning in 1984, isotope specific (i.e., U-234, U-235, and U-238) results are seen in the 

bioassay data. 

While processing and handling of uranium compounds continued until the 1990s, uranium 

bioassay data are scarce from 1966 until the D&D era. The ER does not indicate how process 

data can be used to assign dose to unmonitored exposed workers for all isotopes of uranium. 

SC&A questions whether NIOSH can bound the exposures to uranium based on the minimal 

bioassay data available, particularly given the inherent limitations of fluoroscopic analysis 

techniques used during the 1950s–1985. The responses provided to date do not satisfy SC&A’s 

concerns regarding the feasibility of assigning dose in the absence of personnel monitoring data. 

5.1 AMERICIUM, CURIUM, AND NEPTUNIUM 

Transuranics such as americium, curium, and neptunium were handled during R&D activities, 

including chemical separations. They were also used in analytical procedures involving 

vaporization. Available documentation indicates that activities involving these isotopes occurred 

from 1956 to 1987. Bioassay records are limited to 1 cluster of Am-241 results for an individual 

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in 1987, 38 Cm-244 results for 6 workers in 1983, and 2 Cm-244 results for an individual in 

1986. The paucity of bioassay data for Am-241 and Cm-244 could limit validity of dose 

estimation; it is also unclear in which programs the monitored people were involved. In this 

context, the extension of the available data to unmonitored individuals would become 

questionable. No Np-237 bioassay data have been located for the period of concern. The 

numbers and dates of available bioassay data do not represent the entire exposure period for any 

of these radionuclides. The ER and subsequent white papers do not demonstrate that quantities 

handled are insufficient to affect worker dose. The responses provided to date do not satisfy 

SC&A’s concerns regarding the feasibility of assigning dose in the absence of personnel 

monitoring data. 
6.0 FISSION AND ACTIVATION PRODUCTS AND OTHER 

RADIONUCLIDES 

The most predominant source of activation products at Mound, which has not been adequately 

addressed in NIOSH’s evaluation, was the production of Po-210. There are two periods of time 

for which NIOSH has excluded Mound workers from the SEC class. The first is the period from 

February 1, 1949–September 30, 1949, and the second is the period after February 28, 1959. 

SC&A has concerns regarding the feasibility of dose reconstruction for fission and activation 

products associated with the polonium process at Mound during both of these excluded periods. 

The polonium production process, which transferred to the Mound Plant in February 1949, 

involved the separation of the bismuth slug from the aluminum can through chemical dissolution. 

Both the aluminum used in fabricating the can and the bismuth contained impurities of iron, 

silicon, cobalt, lead, tin, zinc, silver, chromium, vanadium, and gallium. Upon being irradiated, 

these impurities produced gamma- and beta-emitting radionuclides, which at the time of bismuth 

processing created a radiological hazard (BWXT 2002; Moyer, 1956). 

The chemical separation produced a waste stream with a higher concentration of these gamma 

and beta-emitting isotopes than was present in the original slug. Waste processing and handling 

would also result in a potential for exposure to these impurity radionuclides. Aqueous waste 

from Po-210 was originally transferred to HH-Building via waste lines. In 1959, the waste 

treatment was moved from HH-Building back to T-Building. From 1949 to 1971, WD-Building 

supported the polonium operations. Aqueous wastes containing polonium from HH-Building, 

and subsequently from T-Building, were transferred to WD-Building via underground sewer 

lines for polonium wastewater treatment. WD-Building also received polonium waste or waste 

byproducts from R, T, and HH buildings, where research and processing took place, as well as 

wastewater from the H-Building laundry. Potential for exposures existed from contaminated 

areas, breaches of pipes and sumps, leakage from filter banks through 1969, hot maintenance 

activities, sludge packaging, and denitrification and scrubbing of gases (Mound 1993, Mound 

2001). 

This issue is closely linked with previous SEC determinations. The polonium process was 

transferred to Mound Plant in Miamisburg, Ohio, from the Monsanto Chemical Company (MCC) 

Dayton Laboratory in Dayton, Ohio, where unmonitored exposures to activation products and 

neutrons have contributed to the granting of SEC status. NIOSH stated the following in the 

MCC ER (NIOSH 2006): 

Initially part of the Manhattan Project, the Dayton facility separated 

polonium-210 from naturally occurring materials to produce polonium-beryllium 

source neutron generators for atomic bomb initiators. By 1944, the decision was 

made to transmute bismuth-209 into polonium-210 via neutron bombardment. 

That reaction can be stated as: 83 209Bi + η→ 83 210Bi → 84 210Po + β-. The 

beta radiation from the irradiated slugs was so intense that they could not be 

handled without lead gloves and tongs (ORAUT-TKBS-0016-6) [ORAUT 2004]. 

Polonium impurities produced a number of activation products that were beta 

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emitters. Silver-112 was a particular problem with beta particles of 3.94 MeV 

and caused the irradiated ingots to generate high dose rates. Other beta-emitting 

radionuclides of concern were antimony-124 (2.31 MeV), iron-59 (1.57 MeV), 

cobalt-60 (1.48 MeV), cesium-137 (1.176 MeV), bismuth-210 (1.160 MeV), 

tin-121 (0.42 MeV), zinc-65 (0.327 MeV), and mercury-203 (0.214 MeV). 

NIOSH has determined at this time there is a lack of sufficient monitoring and 

source term data for nuclides other than polonium between 1943 and 1949 at 

MCC. Although polonium bioassay data used in conjunction with co-worker data 

from Mound Laboratory and ambient environmental polonium internal intakes 

could be used to support internal dose reconstruction, due to lack of information 

and internal exposure data for the use and production of radionuclides other than 

polonium, NIOSH has concluded that there are insufficient data available to 

support internal dose reconstructions with sufficient accuracy at MCC for the 

time period 1943 through 1949. This inability to complete internal dose 

reconstruction at MCC for the 1943 through 1949 time period is because of a lack 

of information and internal exposure data for radioisotopes other than polonium, 

such as antimony-124; bismuth-210; cesium-137; cobalt-60; iron-55 and -59; 

lead-210; mercury-203; polonium-208 and -209; selenium-75; silver-112; 

strontium-90; tellurium-121 and -132; and tin-121; as well as radium and 

thorium. 

The presence of these impurities at Mound is well established. Activation products were readily 

identified in the waste streams from the polonium process and were considered a radiological 

hazard. Longer-lived activation products from this process were identified during 

characterization activities in the 1990s. NIOSH reaffirmed the presence of impurities in the 

aluminum cladding and their presence at T-Building in the roadmap. 

Both waste streams had high degrees of beta and gamma radiation from the 

irradiated impurities in the aluminum can and in the bismuth metal. [ORAUT 

2009, pg. 81 of 110] 

NIOSH has not provided an adequate explanation for excluding the period from February 1, 

1949, through September 30, 1949. Work on polonium processing began in R-Building and 

T-Building as early as February 1949. Polonium processing at the Mound Plant, as at the Dayton 

facility, began with the dissolution of the aluminum can from the bismuth slug; this step and 

associated waste streams constitute a major source of activation products. The process used to 

separate Po-210 was equivalent for both facilities during this time period. In addition, neutron 

monitoring was not implemented at Mound until August 1949. Absence of neutron monitoring 

was also cited as a reason for granting the Dayton Laboratory SEC class. 

During the January 5–6, 2010, Mound Work Group meeting, NIOSH indicated that the 

radiological controls in the T-Building at the Mound Plant were substantially better than those at 

Dayton Laboratory. While controls were somewhat improved over those at Dayton, the existing 

situation did not preclude the potential for exposure to impurity radionuclides. The potential for 

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exposure existed throughout the polonium processing years, as demonstrated by analysis of 

radiological controls and incidental releases. Additional documentation of concerns regarding 

radiological controls is presented in Attachment 1 of this report. 

Gloveboxes used for polonium processing at Mound were primitive by modern standards. In the 

early days of the project, all work was performed on an open bench top or in standard laboratory 

fume hoods. All rooms where radioactivity was handled additionally had air locks and negative 

ventilation. “Urine analysis, used as a monitor of activity in the body, indicated that the 

aforementioned installations and precautions were inadequate” (McEwen 1949). The solution 

was to use a drybox (glovebox in modern terms), which was originally developed “to maintain 

an inert atmosphere around the enclosed operation rather than to prevent the spread of activity.” 

As the need for more effective confinement of radioactivity became apparent, work was initiated 

to design “Special Hoods” for this purpose. Because gloveboxes were not available on the 

market at the time, Mound’s dryboxes were designed and built in-house. The main objective 

was a design “that would adequately confine activity, but would not materially handicap 

personnel or require drastic changes in the design and operations of the existing process 

equipment” (McEwen 1949). 

“Plywood of the proper thickness was to be used for the basic hood structure because of its 

relatively low cost, ease of fabrication, adaptability for alterations, and suitability to the 

installation of services” (McEwen 1949). The surfaces of the boxes were to be varnished or 

painted to resist the chemicals used in processing. Attempts were made to standardize hood 

design. This attempt achieved some success, but true standardization did not occur. “Some 

further standardization might be accomplished in later designs, but as long as the material of 

construction is limited to plywood, improvements in design and standardization will probably be 

minor. The greatest improvement would be the discovery of a better construction material” 

(McEwen 1949). 

The following incidents from the 1960s were associated with failures of the original design 

gloveboxes that had been used from the start of polonium operations, providing evidence of 

exposure potential throughout the period of use. “The items below, list the incidents which have 

occurred in either T-267 or T-270 over the years 1963-64-65, which can be attributed to faulty 

glove boxes that have now been in use sixteen years” (Guillet 1965, emphasis added).

1. None in 1963. 

2. 01/17/64 - Faulty plastic pass box. 

3. 04/28/64 - Contaminated water leaking thru low risk barrier. 

4. 10/5/64 - Pressurized acid supply line. 

5. 10/30/64- Fire in wooden hood. 

6. 05/20/65 - Repeat of 4/28/64 - dried out caulking 

7. 03/29/65 - Pass box repair needed. 

In addition to the polonium impurities, beta/gamma-emitting radionuclides were handled in other 

operations at Mound. In some cases, the beta- or gamma-emitting radionuclides were identified 

as the major radionuclide(s). For example, isotopic separation of Sr-90 and Y-90 occurred in 

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R-Building from 1960–1962. In the NIOSH response on data adequacy and completeness, Sr-90 

is listed as a major radionuclide of concern for this program. NIOSH indicates in their response 

that this project was limited to two radiochemists; however, they have not considered the 

potential exposures to support staff or the fact that no bioassay data exist for Sr-90 from this time 

period for either the radiochemists or support workers. There are no isotope-specific or gross 

beta/gamma bioassay results for Sr-90 until 1993, and NIOSH has not specified how dose will be 

reconstructed for prior years. 

A campaign to separate Ba-137m and Cs-137 was also conducted onsite during 1968 and 1969 

(Essig and Neubert 1969, Mound 2001). No bioassay data for either isotope have been located 

from this period. Cesium-137 bioassay was not performed until 1993, and no method has been 

proposed to reconstruct internal doses prior to this time.

Several other operations, including incineration, use of a glass melting-furnace, neutron 

accelerator source irradiations, and handling of orphan sources, created exposure potential to 

fission products. SC&A acknowledges beta/gamma emitters were often handled in the presence 

of alpha emitters. However, NIOSH has not presented a method of reconstructing doses from 

beta/gamma emitters from alpha bioassay data, nor have they addressed those situations in which 

beta/gamma emitters were handled without associated alpha emitters. 

Workers at Mound experienced exposure potential to beta- and gamma-emitting radionuclides 

throughout the site’s history, extending before and after the NIOSH-proposed SEC period. 

During the July 2008 work group meeting, NIOSH/ORAUT indicated that no gross beta results 

had been located to date. Limited bioassay sampling was done for Cs-137 (1993–1995), Co-60 

(1993–1995), Mn-54 (1994–1995), and Sr-90 (1993–1997). In the Health Physics – 5 Year Plan

(Monsanto 1967), there is mention of the development of a promethium urinalysis procedure for 

Mound. Whether the procedure was implemented and monitoring data collected is unknown. 

No promethium bioassay data have been located to date. There is an absence of beta/gamma 

internal monitoring for a majority of the years when beta/gamma emitters were present at 

Mound, particularly during the production era. With several of these isotopes persisting into the 

D&D characterization period, it is apparent that they were present in higher activities, and 

accompanied by additional shorter-lived radionuclides, during the period when polonium was 

actively processed. 

Again, NIOSH has indicated that the predominant internal exposure at Mound was to alpha 

emitters and tritium. They further state that beta/gamma emitters played a minor role in Mound 

activities, and for the most part only existed in trace-quantity research and production-scale 

operations (NIOSH 2009). NIOSH has not produced objective data regarding the quantities of 

material handled or processed or the concentrations of these radionuclides in various source 

terms, including waste streams. While they maintain that these radionuclides are not of 

dosimetric significance, they have not quantitatively defined what constitutes dosimetric 

significance. 

In summary, the responses provided to date do not satisfy SC&A’s concerns regarding the 

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emitting radionuclides. The ER and subsequent white papers do not demonstrate that quantities 

of beta/gamma emitting radionuclides are dosimetrically insignificant to all organs, nor have 

they provided objective evidence that radionuclide concentration data are available such that the 

relative dose of beta/gamma emitters can be determined from available personnel monitoring 

data for the predominant radionuclides in the process and waste streams. 

NIOSH has not provided an adequate justification for excluding Mound workers from February 

1949–September 1949 or for periods after February 1959 when no bioassay data are available. 

They have granted an SEC at MCC Dayton Laboratory for an equivalent polonium process in the 

period immediately prior to this, and for Mound starting in October 1949. NIOSH has not 

provided an adequate explanation for why it is not feasible to reconstruct dose for Sb-124, 

Bi-210, Cs-137, Co-60, Fe-55, Fe-59, Pb-210, Hg-203, Po-208, Po-209, Se-75, Ag-112, Sr-90, 

Te-121 through Te-132, and Sn-121 at the Dayton Laboratory, yet dose reconstruction is feasible 

for the same radionuclides at the Mound Plant. The current position that fission and activation 

products at Mound are not of importance due to their trace concentration is in conflict with the 

position taken in the MCC petition evaluation. The lack of information and internal exposure 

data for impurity radionuclides has not been resolved for the period of active polonium 

production at the Miamisburg location. 
7.0 USE OF GROSS ALPHA AS A SURROGATE FOR 

RADIONUCLIDE-SPECIFIC BIOASSAY 

NIOSH has indicated that gross alpha results can be used to bound the dose for all alpha-emitting 

radionuclides at Mound where isotope-specific data are not available. The gross alpha results 

would be credited to the radionuclide resulting in the highest dose to the organ of concern, with 

case-specific information being considered when available (e.g., where a worker worked). This 

methodology encompasses all alpha-emitting radionuclides (i.e., Am-241, Cm-244, Pu-238, 

Pu-239, Ac-227 via daughters Th-227 or Ra-223, Ra-224, Ra-226, Th-228, Th-229, Th-230, 

Th-232, Pa-231, Np-237, U-233, U-234, U-235, and U-238) at Mound for which there are no 

isotope-specific bioassay data. 

To appreciate the intricacies of the bioassay data collected for alpha emitters, the following items 

must be understood. 

(1) The different radiochemical and subsequent counting techniques utilized 

(2) The method for designating the radionuclide to which an individual was exposed 

SC&A has attempted to obtain very specific information from radiochemists and chemists 

throughout the evaluation process; however, those consulted were not familiar with the particular 

radiochemical techniques. SC&A has conducted interviews with personnel responsible for 

radiochemical analysis of bioassay samples in an effort to clearly understand the radiochemical 

analysis, the method for identifying radionuclides present in the urine, and the protocol for 

documenting bioassay results. 

7.1 GROSS ALPHA DETERMINATION (AKA PLUTONIUM BIOASSAY) 

The history of plutonium bioassay is relevant to the detection of other alpha-emitting 

radionuclides, since this technique was not specific to plutonium, but also carried other alphaemitting radionuclides through the radiochemical process. The initial plutonium technique 

(gross alpha determination) developed in 1956 was developed to monitor for plutonium; 

however, the technique was actually more of a gross alpha procedure. It was later referred to as 

the “gross alpha determination.” The first step of the procedure was to cause an alkalinephosphate precipitate to form by adding ammonium hydroxide. Most of the solids and the 

polonium remained in supernate (i.e., urine). Purified cerium carrier in the +3 and +4 valence 

state was added to the sample. The cerium phosphate carrier brought down plutonium, thorium, 

uranium, protactinium, and americium (possibly curium). The cerium precipitate was initially 

mounted on a disk and counted for gross alpha activity. Although the radiochemical process 

actually brought down multiple actinides, the sample results were considered as plutonium, 

unless it was known that an individual was working with another radionuclide, such as uranium 

or thorium (Sheehan 2009a). 

Whether all alpha emitters were captured along with the plutonium or were captured at the same 

efficiency as plutonium is not clear. A similar procedure was implemented for analyzing 

actinides in urine at Argonne National Laboratory (ANL) using alkaline phosphate precipitation 

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followed by co-precipitation with bismuth phosphate and then cerium fluoride, isolated heavy 

metals, including thorium, neptunium, actinium, plutonium, and trans-plutonium elements (ANL 

1989). Although uranium is present after the alkaline phosphate precipitation step, ANL 

indicates that uranium does not come through in the co-precipitation process with bismuth 

phosphate and then cerium fluoride (ANL 1984). 

The gross alpha procedure did not isolate radium isotopes. A radium bioassay procedure, 

utilized during the Ac-Ra-Th production campaign, used barium sulfate to isolate the radium 

isotopes from the other actinides (e.g., Ac, Th, U, Pu, and Pa). The barium sulfate step was 

eliminated once the Ac-Ra-Th program ended; it required much more labor and was no longer 

necessary, because Mound was no longer doing radium bioassay (Sheehan 2009a). The gross 

alpha technique, at a minimum, could not be used as a surrogate for radium after the barium 

sulfate step in the gross alpha radiochemical procedure was discontinued. 

Actinium-227 is a beta emitter. There was no attempt after the Ra-Ac-Th separation project to 

characterize Ac-227 from its alpha-emitting daughter by the Mound bioassay group. 

While the gross alpha radiochemical procedure may have precipitated Ac-227, the sample 

counting procedure with a low background proportional counter yielded gross alpha results. The 

gross alpha count would not be inclusive of Ac-227, a beta emitter. Because Ac-227 was not 

directly analyzed, radionuclide progeny (i.e., daughters) must be used as a surrogate for the 

parent. Where daughters are used to derive parent radionuclide activities, the knowledge of the 

ratios of the daughters to parents in the respective source terms must be known, and the 

differential effects of biokinetics between parent and daughter radionuclides must be considered. 

Data can be obtained from process information; however, the age of the material at the time of 

uptake is generally unknown, and equilibrium between parent and daughter depends on the age 

of the material being processed. Equilibrium may or may not exist. For dose reconstruction, 

NIOSH might assume that Ra-223 is in equilibrium with Ac-227 in urine. However, this 

assumption would not support estimates of Ac-227 from gross alpha results, because the gross 

alpha procedure is selective against radium. Thorium-227 is detectable by the gross alpha 

procedure according to Mound radiochemists; however, the state of equilibrium must be known. 

Given the Ac-227 separation activities conducted at Mound, it is unclear how the alpha-emitting 

daughters can be used to extrapolate Ac-227 uptakes. The claimant-favorable assumption would 

be to assume 100% pure Ac-227, which cannot be detected by an alpha count. 

7.2 ANION EXCHANGE 

From mid-1966 to mid-1967, Mound implemented an anion exchange technique for most urine 

samples, which was selective for plutonium or uranium. In 1967, laboratory technicians returned 

to using the gross alpha procedure, but they began to do some specific analyses for “special 

samples” (e.g., Th-228, Th-230) by running samples through a column to select the nuclide(s) of 

interest. In 1967, Mound also implemented pulse-height analysis for “special samples.” 

Interviews with a former worker indicate that pulse-height analysis was conducted when they 

wanted more specific information on the radionuclide in the urine (SC&A 2008b). Documented 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
details on when Mound used pulse-height analysis versus gross alpha measurement with a 

proportional counter are not available. 

Plutonium-specific data using an anion exchange column, starting in mid-1966, allowed 

sequential elution off the column to obtain isotope-specific samples. The adjustment of the pH 

allowed for isolation of plutonium, americium, neptunium, and uranium in sequential steps. In 

general, an 8 M HNO3 solution was used to strip off the plutonium, and this material was 

electroplated along with an internal tracer (Sheehan 2009a). “Mound Laboratory 24-Hour 

Urinalysis Procedures for Actinides,” History of the Mound Bioassay Programs (Meyer 1992) 

indicates that thorium, curium, trans-plutonium, strontium, and polonium are not absorbed onto 

the column and are carried in the rinsate. With the implementation of anion exchange, the focus 

of routine bioassay was on plutonium; analyses of other radionuclides depended on notification 

from the field or technical staff regarding which radionuclides were handled by the personnel 

submitting specimens. The default routine analysis did not include all alpha emitters. Unless the 

field indicated potential exposure to an isotope other than plutonium, the bioassay lab only 

pulled off the plutonium fraction from the column. Once electroplating and use of an internal 

tracer began, pulse-height analysis was used (Sheehan 2009a). The routine use of anion 

exchange, rather than the rapid gross alpha technique, would preclude the analysis of all alpha 

emitters, once again putting a reliance on isotope-specific bioassay. Appropriate analysis for 

radionuclides other than plutonium during this period required effective communication between 

the field and the bioassay laboratory. 

It is important to note that the Field Health Physics group was responsible for communicating the 

need to analyze a bioassay sample for radionuclides that were not routinely isolated and counted. 

The information was provided by several Health Physics Supervisors who had responsibility 

over specific areas of the plant. For example, there was a supervisor for G-Area, T-Area, 

SM/PP-Area, and SW Area (Sheehan 2009a). For the technical staff who worked directly with 

special radionuclides, the field health physics staff was generally aware of the isotopes being 

utilized and the need for special analysis. In the case of the maintenance staff, Maintenance 

Work Permits (MWPs) generated for each maintenance job provided some information on 

monitoring needs. These MWPs have not been located to date. For maintenance staff, it was 

more difficult to identify those working with radionuclides other than polonium or plutonium. 

There was a period of time when maintenance workers were restricted to either the polonium 

areas or the plutonium areas (SC&A 2008b). After the bioassay laboratory added copper powder 

to their radiochemical procedure, they were able to remove the polonium from plutonium 

samples, and workers were allowed to work in both areas (SC&A 2008b). The communication 

between the field and the bioassay staff was relatively successful in the case of an incident, but it 

was not always effective for routine operations. 

As a point of clarification, SC&A has not implied that the Mound bioassay program lacked the 

capability to detect alpha emitters other than plutonium and uranium during the 1966–1967 time 

period, as argued by NIOSH. The rapid gross alpha technique was still available; however, a 

memo from Sheehan (1966) referenced above actually states: 

Draft White Paper – Internal Data 36 SC&A – June 21, 2010 

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Starting with this report all 24-hour urinalysis results are being reported as 

plutonium and uranium as we are now using anion exchange separations which 

are selective. [Emphasis added.] 

The procedure using the anion exchange column, while capable of isolating multiple actinides in 

sequential steps, only pulled off the plutonium fraction from the column, unless the field 

indicated there was a potential exposure of an isotope other than plutonium. 

Procedures are available for both the gross alpha determination and the anion exchange 

procedure at least as early as 1968, and results from this era generally do not indicate which 

procedure was used. 

Based on a review of Meyer (1992) and the PURECON database, it appears that, from 1956 to 

mid-1966, results from analysis of 24-hour urine samples were reported as gross alpha and total 

alpha, without specification of an isotope. Results continued to be reported as gross alpha or 

total alpha until 1970, with exceptions in some records from mid-1966 to mid-1967. The 

bioassay results themselves provide little assistance in determination of whether gross alpha or 

anion exchange were used after 1970. There is a notable change in the recording practices in 

1971. In general, the bioassay result was assigned to the radionuclide that the individual was 

working with at the time. As such, during the 1970s, results identified in PURECON as Pu-238, 

Pu-239, or other specific radionuclide may be misleading, because the gross alpha determination 

was not selective for particular alpha emitters. In the case of anion exchange, the radiochemical 

method allowed for the discrimination between plutonium, americium, neptunium, and uranium. 

Pulse-height analysis, starting in 1967, was conducted on special samples when more specific 

information on the radionuclide in the urine was desired; however, the use of this technique is 

not clearly stipulated in the bioassay record. A preponderance of the bioassay results in 

PURECON are for Pu-238, Pu-239, and/or total or gross alpha. The plutonium data in 

PURECON indicate that a majority of the results were assigned to Pu-238 from about 1971 

through 1980. In 1981, isotope-specific data started to appear in the record (e.g., Pu-238, 

Pu-239, etc.) 

7.3 ALPHA SPECTROSCOPY AND ANION EXCHANGE CHEMISTRY 

In 1980, Mound implemented alpha spectroscopy and anion exchange chemistry, which allowed 

for radioisotopic analysis (Meyer 1992). 

During 1980, [name redacted] had the technicians use specific anion exchange 

chemistry, plutonium-242 as a tracer with electrodeposition of sample mount, 

alpha spectroscopy counting and the processing of sample blanks. Running 

blanks allowed the calculation of the detection limit.

In 1980 and thereafter, radionuclide-specific analysis replaced the gross alpha technique. At this 

point, NIOSH’s proposal to bound dose with gross alpha results is no longer feasible. Personnel 

monitoring is now specific to the radionuclide and results listed in the dosimetry file. For 

example, if an individual worked with Pa-231, Ac-227, Pu-238, and Pu-239, and bioassay results 

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were available for Pu-238 and Pu-239, the individual was effectively unmonitored for Pa-231 

and Ac-227. SC&A has provided several examples of situations post-1980 where there was a 

potential for exposure to alpha and beta emitters for which no bioassay data are available. No 

technique has been proposed by NIOSH to assign dose from unmonitored alpha emitters during 

this time period. 

NIOSH has not provided relative ratio data for unmonitored alpha emitters to monitored alpha 

emitters for all processes. 

In summary, there are significant gaps in bioassay collection for alpha-emitting radionuclides 

other than plutonium and polonium (through 1973), compared to the years when the 

radionuclides were present at Mound. As a result, NIOSH is relying on gross alpha results to 

represent “other alpha emitting radionuclides.” The gross alpha determination procedure is not a 

catch-all procedure for all radionuclides of concern; the procedure is particularly inadequate for 

radium and actinium. With the use of the anion exchange procedure, there are questions 

regarding the ability to capture curium, thorium, trans-plutonium, strontium, and polonium (post1973) in the analyzed sample. Anion exchange was performed for plutonium only unless 

otherwise specified by the field radiological control staff. This communication was not always 

effective, particularly in the case of support workers. 

7.4 AIR SAMPLING 

A brief evaluation was done of the availability of air sampling data available on the SRDB, 

versus the buildings and time periods when thorium was handled. The available air sampling 

data are limited to specific locations and time periods; air monitoring information exists for PPBuilding (1981, 1982, and 1984), R-Building (1980–1990), SM-Building (1981, 1982, and 

1984), SW-Building (1972 and 1995), WD-Building (1978 and 1994), and Building 21 (1987). 

It is apparent that the available air sampling data do not represent all areas and time periods at 

Mound. Furthermore, NIOSH has stated in the ER (NIOSH 2007): 

Mound health physics program records include a number of air samples for 

alpha- and beta-emitters. Typically, such data are of limited use in dose 

reconstruction due to the great uncertainties associated with the doses estimated 

based on measured air concentrations. When possible, dose reconstructions are 

usually performed based on data related to a specific claim (including bioassay 

data), which provides a much more direct assessment of the uptake of a given 

radionuclide and the resulting organ dose. 

Although NIOSH indicates in the ER that measured air concentrations can be useful in 

estimating maximum doses when bioassay data are unavailable, this cannot be done where air 

concentration data are not available. 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
7.5 ITEM OF CLARIFICATION FROM THE NIOSH EVALUATION OF DATA 

ADEQUACY AND COMPLETENESS ISSUES AT THE MOUND LABORATORY 

7.5.1 Item #1 

NIOSH has indicated the following (NIOSH 2009, pg. 7): 

As has been explained repeatedly [(1) “NIOSH Responses to Mound Matrix 

Items,” July 5, 2008, page 19; (2) Mound Working Group meeting on May 27, 

2009 transcript page 163; (3) Mound Working Group meeting on July 14, 2008 

transcript pages 213–215] NIOSH does not propose to use gross beta results as 

this bioassay was not used at Mound. The mention of it in the ER was an error. 

Furthermore, 

NIOSH does not propose to use gross beta results (see previous response). 

NIOSH/Oak Ridge Associated Universities Team (ORAUT) indicated that in lieu of isotopespecific bioassay data, they could rely on gross alpha and gross beta results (NIOSH 2008b): 

Gross alpha and gross beta results are usually credited to the radionuclides 

resulting in the highest dose among those to which exposure is possible and 

plausible when circumstances of the potential exposure are not known. 

The SC&A review must be conducted on the current version of the ER which does state that 

gross beta results will be used. If the ER is incorrect in stating the above, a revision to the ER is 

warranted. 

7.5.2 Item #3 

NIOSH correctly identified on page 26 of their response to data completeness that Po-210 has 

only a stable daughter (Pb-206); therefore, it is inappropriate to refer to Po-210 daughters as 

radioactive. SC&A will eliminate Po-210 progeny from the list of radionuclides at Mound; 

however, NIOSH should do the same, as they have identified Po-210 daughters in the roadmap 

on pages 65, 68, 70, and 96 (ORAUT 2009). NIOSH also referred to Po-210 progeny as a major 

radionuclide of concern in Attachment A of their response. These corrections should clear up 

any further confusion. 

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7.6 SUMMARY 

NIOSH maintains that the exotic radionuclides were handled episodically. Furthermore, they 

infer that when this episodic handling occurred, bioassay was conducted. NIOSH has presented 

Major Mound Source Terms and Radionuclides of Concern in Attachment A of NIOSH 

Evaluation of Data Adequacy and Completeness Issues at the Mound Laboratory (NIOSH 2009). 

Because the table does not indicate relevant periods for these major Mound source terms, 

reviewers are unable to link the information provided by NIOSH with available bioassay 

methods and data in order to critically assess the data adequacy. NIOSH also did not provide a 

definition of “major radionuclide of concern,” nor have they substantiated their position that 

other radionuclides produce insignificant doses. As a result, SC&A was forced to rely on its own 

research to identify exposure scenarios with no supporting bioassay. 

SC&A has provided several examples representing potential exposure to radionuclides other than 

plutonium, polonium, and tritiated water or tritiated gas. In these situations, radionuclidespecific bioassay data are absent. In many cases, gross alpha bioassay is of questionable value in 

isolating these radionuclides, due to the radiochemical methods used. In the case of beta/gamma 

emitters, there is a complete absence of bioassay until the mid-1990s when the D&D effort 

began. 

NIOSH has indicated that exotic radionuclides were handled in trace quantities, and that their 

handling was episodic in nature. NIOSH has minimized the relevance of the King document 

(King 1995; Mound 2001) by characterizing it as listing “any radionuclide that could have 

possibly been in a particular room” and restricting its intent to determination of bioassay 

requirements during the D&D era. It is clear from the document itself that the dates provided for 

radionuclides of concern represent the “usage of radionuclides” and not necessarily “residual 

radioactivity” or radionuclides with a “possible presence.” While the King document (Mound 

2001) was utilized for identifying radionuclides that might potentially be encountered during 

D&D, the determination of bioassay requirements during that period was based on the potential 

for a worker to receive 100 mrem CEDE. While NIOSH has denied its usefulness in dose 

reconstruction, one of the stated purposes of the King document (Mound 2001) was to “facilitate 

internal dose assessment.” Episodic presence of exotic radionuclides is not indicated from the 

King document (Mound 2001), and potential fluctuations in operations cannot account for years 

and decades in which internal monitoring data are minimal or non-existent. The bottom line is 

that the King document (Mound 2001) and corroborating evidence indicate active handling of 

unencapsulated exotic radionuclides for extended periods of time beyond the NIOSH-proposed 

SEC period. 

Where information concerning quantities of materials handled has been readily available, SC&A 

has included this information; however, months of further research would be required to compile 

this information for the range of projects described herein. NIOSH has provided no objective 

evidence supporting their statement that exotic radionuclides, some of which are impurities from 

major production processes, were present in trace or research quantities. Essential information 

for these exposure scenarios would include the relative activity of radioactive material handled, 

the ratios of “secondary radionuclides” to “primary radionuclides” in process and waste streams, 

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and the engineering and administrative controls utilized to prevent exposure to “secondary 

radionuclides.” Given that the impurity radionuclides were of no interest to the operations, it is 

unlikely that analytical information is available in many cases. 

Dosimetric significance in terms of the compensation program is not defined by the Energy 

Employee Occupational Illness Compensation Program Act (EEOICPA) or the associated rules. 

There is no de minimus dose specified. The dosimetric significance was therefore determined 

based on the requirement for bioassay sampling at 100 mrem CEDE, the radionuclides defined as 

nuclides of dosimetric significance during the Pre-1989 Dose Assessment Project at Mound, and 

the sensitivity of Probability of Causation (POC) codes. Clearly, alpha-emitting radionuclides 

such as Ra-226, Ac-227, Th-228, Th-230, Pa-231, Th-232, U-233, U-234, U-235, U-238, Am241, and Cm-244 are of dosimetric significance in compensation, as exposures can potentially 

lead to doses on the order of rems. The requirement for submitting bioassay in the mid-1990s 

indicates a potential for exposure to result in a CEDE of 100 mrem. If such doses could be 

encountered during the D&D era, this implies that workers should have been monitored for these 

radionuclides during the production era, when concentrations were much higher. During the 

production era, workers were potentially exposed to beta/gamma emitters that would not persist 

to the D&D era, due to their relatively short half-lives (i.e., <1 year). Furthermore, lack of 

monitoring or limited monitoring for the same exotic radionuclides have resulted in designation 

of SEC classes at other EEOICPA sites, indicating their dosimetric significance in the 

compensation program. Most notably, an SEC class was defined at Dayton Laboratory based on 

the lack of monitoring for “Sb-124, Bi-210, Cs-137, Co-60, Fe-55, Fe-59, Pb-210, Hg-203, Po208, Po-209, Se-75, Ag-112, Sr-90, Te-121 through Te-132, and Sn-121,” which also existed at 

Mound Laboratory. Although the engineering controls were better established at Mound 

Laboratory, these controls did not preclude potential exposures to these radionuclides for the 

periods of February 1949–September 1949 and after February 28, 1959. 

NIOSH has indicated that in order for a potential to exist, material must be handled in such a 

way as to make it accessible to the breathable atmosphere. The examples provided include 

handling of unencapsulated sources in various physical forms. Operations included handling of 

contaminated soil, repackaging of leaking or grossly contaminated drums, chemical separations 

including vaporization processes, emanation of gaseous radionuclides, handling and processing 

of radioactive waste, and D&D of radiologically contaminated facilities. From a routine 

processing standpoint, there was no difference between these exotic radionuclides and the 

primary radionuclides, yet NIOSH acknowledges potential exposure for plutonium, polonium, 

and tritium, and denies the same potential for exotic radionuclides handled in the same manner. 

Exotic radionuclides were clearly present in physical and chemical forms, which presented a 

potential for exposure. 

NIOSH indicates that radiological safety at Mound presented a controlled atmosphere in which 

radioactive materials were handled. The radiological controls and practices were proceduralized; 

however, the numerous incidents and failures in radiological and administrative controls paint a 

different picture. The “pervasive, controlled atmosphere in which radioactive material was 

handled” appears to be contradicted by: 

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NOTICE:

(1) Incidents numbering in the hundreds for the production areas 

(2) Multiple intakes identified for many Mound workers, some of which are not associated 

with incidental exposures 

(3) Administration of chelation therapy to over 60 Mound workers 

(4) Recurring failures of engineering controls 

(5) Inadequacies in facility procedures 

(6) Inadequacies in implementation of corrective actions 

(7) Incomplete radiological characterization prior to D&D efforts 

(8) Price Anderson Amendment Act (PAAA) fines received for ineffective implementation 

of radiological controls and personnel monitoring 

(9) Radiological control audit reports 

After being sued by a union in 1995, DOE agreed to enhance the radiological control program at 

Mound by installing personal contamination monitors, installing an automated record-keeping 

system, performing radiological characterization, assessing the need for personal air sampling 

and enhanced continuous air monitoring, accrediting the bioassay laboratory, and establishing a 

validation program for internal dosimetry methodologies. This raises questions regarding the 

appropriateness of the personnel and field monitoring in prior years, given the lack of 

characterization and the questionable effectiveness of egress monitoring. These factors clearly 

demonstrate the potential for exposure, not only to primary production radionuclides, but to 

exotic radionuclides as well.
Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

Ag-110, Co-60, Cs-137, Fe-59, Po-208, Po-209, Se-75, Sn-121, Sr-90, Te-125, Te-127, Te-129, Sb-124, Zn-65 

In the polonium production process, the bismuth slug was separated from the aluminum can through chemical dissolution. The aluminum used in fabricating the can and the bismuth contained impurities of iron, silicon, cobalt, lead, tin, zinc silver, chromium, vanadium, and gallium. 

Upon being irradiated, these impurities produced gamma-emitting isotopes that, at the time of bismuth processing, created a radiological hazard. The radionuclides went into the waste stream. 

1949–1971 T-Building R-Building Unencapsulated material 1949–1971 

Radionuclide impudissolving operatiocontamination, waprocess, leakage frthrough 1969, hot T-53, waste treatmpackaging, denitrascrubbing of gasessix process line inc1964–1965 in Roo270. Gross contamthrough all the corrmany of the workilow-risk side of the 

Ag-110, Co-60, Cs-137, Fe-59, Po-208, Po-209, Se-75, Sn-121, Sr-90, Te-125, Te-127, Te-129, Sb-124, Zn-65 

Processing of aqueous wastes from the Po-210 separations process (including radionuclide impurities) 

1949–1971 WD/HH/T Unencapsulated material 1949–1971 

Aqueous waste frooriginally transferrbuilding via waste the waste treatmenfrom HH-building building. From 19WD-Building supppolonium operatiowastes containing HH-Building and sT-Building were trWD-Building via usewer lines for polwastewater treatmewas renovated to pwaste water. WD-received polonium byproducts from RBuildings, where rprocessing took plawastewater from thlaundry. 

Draft White Paper – Internal Data 43 

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Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

Co-60, Sr-90, Cs137 

Room-floors have a high "fixed" radiation potential because of pipes and sumps from the old polonium program. 

No Dates 

T-Building (T-43, T-44, T-48, T-50, T-57, T-58, T-59, and corridor-51) 

Fixed contamination, internally contaminated pipes 

Co-60: <1993 and >1995; Cs-137: <1993 and >1995; Sr90: <1993 and >1997 

Potential of exposudisturbance of floopipe and sump sysexposures exist for years, as well as poyears. 

U-234 

A pilot program was developed to separate U-234 from Pu-238 by tributyl solvent extraction and ion exchange. 

1965–1970 SM-Building (SM-38) Unencapsulated material 1965–1970 Process moved to R

production. 

Th-232 

Th-232 was substituted for Pu-238 compounds for modeling purposes in R&D and for analytical studies. The compounds of thorium are identical to those of Pu-238 used in these areas. 

1961–1967 1965–1978 1967–1980 

SM-Building 

(Rooms 61, 62), 

R-Building, 

PP-Building 

Unencapsulated material 

1962, 1968–1971, 1973–1978, 1980 

Th-228, 232 Ra-226 Radon, Thoron 

Thorium sludge operations: redrumming, transfer to bulk storage, removal / repackaging, decontamination, and entries into contaminated facility. 

1955–1976 

(Active Storage); 

1976-demolition 

and remediation 

Warehouse 15. 

In and around 

Building 21. 

Outside Areas 1, 

3, 9, and 12. 

Unencapsulated material 

Drums of corrosive stored at Mound frcancelled thorium project. Drums leafrequent repacking necessary. 20%–4drums were repackThis was initially dWarehouse 15, but radiation levels foroutside. Building 1966 for bulk storamaterials. Materiafrom above througpanel roof. The slurepackaged and sh1975. Initial cleaninterior wash and pLater entries: DrumConcentrate were s21 from 1976–198entries were made 

Draft White Paper – Internal Data 44 

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Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

physics personnel surveys and air mo

Th-228, Th-230, Th-232, Ac-227, Cs-137, Ra-224, Ra-226, Radon, Thoron 

Soil contamination: Area 2 was a disposal trench for empty thorium drums and for Po-210 contaminated sand. Area 7 was a historic disposal area used for disposal of empty thorium drums and radiologically contaminated equipment. It also contains a historic septic tank contaminated with Ac-227 from SWBuilding. Thorium contaminated soil was moved from Area 1 to Areas 8 and 12. Area 21 was used for historic storage area formerly used for storage of high-risk wastes from the SW Building (Cs-137 and Ra-226). 

Sources of 

contamination 

date back at least 

to 1955. 

Contamination 

reported as late 

as 2000. 

Outside Areas: Area 1, Area 2, Area 3, Area 7, Area 8, Area 9, and Area 12; Warehouses 9 and 15; Building 21. 

Unencapsulated material; potential exposure from resuspension of soil 

Ac-227: 1960–1963, 1965–1988, 1990–1993; Cs-137: 1955–1992, 1996-2000, Th-228, 230: 1959–1987, 1990–1992; Th-232: 1962, 1968–1971, 1973–1978, 1980–1987, 1990–1992; Ra-224: 1959–2000; Ra-226: 1960–1963, 1968–1993; Sensitivity of urine bioassay for Ac-227 ~100X lower than for Pu. (Cheng and Halcomb, no date) 

During characterizthe late 1980s, 1992000, several outdcontamination areaidentified. Redrumthorium sludge resapparent widespreacontamination due dust emissions. Th reported for surfacBldg 21 - Contamisurrounding grounfrom loading and/osludge. At least 11still stored outside deteriorating as latSurface soil sampl34,000 pCi/g (80 f54.3 pCi/g thorium bldg). In general, samples were mucaround Bldg 21 thathe hill. Exposure Potential After sludge was rBldg 12, contaminscraped, moved to behind PP, & coveof the trench was dremoval of WTS ocausing Th contam"Rader's Hill" acro100. HP used the Bldg 21 for emergeresponse training 1

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Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

Co-60 

Outside soil contamination areas from polonium processing and spills to the environment. 

1949-

remediation 

Outside areas 

(Area 5, Area 20, 

Area 22) 

Unencapsulated material; potential exposure from resuspension of soil 

Co-60: 1949–1993, 1996–closure 

December 1970 - Wbreak near Buildinnorth of the WD B

Sr-90 / Y-90 Isotopic separation of Sr-90 and Y-90 through various techniques. 1960–1962 R-Building (R- 167) Unencapsulated material 1960–1962 Sr-90 was the prim

radionuclide. 

Pa-231, Pa-233 Am-241 Cm-244 U-233 Ra-226 Ce-141, 144 Th-230, 232 

Work included isotopic separation of Pa-231, Pa-233. Characterization and analysis of cerium-141, cerium-144, americium-241, and Pa-231. 

1956–1987 R-Building Unencapsulated material 

Pa-231, 233: 1960–1987; Th-230: 1959–1987; Th-232: 1962, 1968–1971, 1973–1978; 1980–1987; Am-241: 1956–1982, 1984–1985; Cm-244: 1956–1982, 1984–1985; Ra-226: 1960–1963, 1968–1987; U-233: 1960–1964, 1967–1971, 1973–1983, 1985–1988; Ce-141, 144: 1956–1987 

Incident: Cm-244 

U-235, U-238, Ca-45, Pm-147 

Isotopic separation of uranium radioisotopes, especially U-235 and U-238, using a chloride complex separation technique. The work was done on Pm-147. Ion exchange resins were used with Ca-45 for calcium 

1980–Present R-Building (R- 169) Unencapsulated material 

Pm-147: 1980-closure; Ca-45: 1980-Closure; U-235: 1980–1988, 

Dates defined per M

Draft White Paper – Internal Data 46 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

separation analysis. 1992; 

U-238: 1980–1983, 1985–1988, 1992 

U-234 

U-234 separation from aged Pu-238 was done. A homogeneous oxalate precipation technique was used along with two cycles of ion exchange on resins. 

1962–1972 (ER)

(1970–1980 

WK) 

R Building 

SM Room 1 

Unencapsulated material 

1970–1971, 1973–1980 

U-234 was separat238from the mid-1U-234 separation aoccurred from 196through 1979, with quantities shipped An incident occurr1970; no uranium bcollected from tho

U-234 

Heat Source Program where plutonium molybdenum shards (PMC) were hot pressed into disks and machined to required dimension. 

1968–1975 R-Building (R-145, 147) Unencapsulated material 1968–1971; 1973–1975 

Heat Source programachining and preCompatibility studassembly and disassource units and "hmetallographic analisted as a third radconcern. An incident occurrinvolving Pu-238, 

Ac-227 Decontamination of contaminated equipment from R-building 1956–1982 R-Building (R-198) Unencapsulated material 1960–1982 Ac-227 is listed as 

radionuclide. 

Cm-244 Analytical laboratory supporting the heat source program. 1965–1978 R-Building (R-133) Unencapsulated material 1965–1978 Analytical laborato

the heat source pro

Th-228,230,232 Cs-137, Sr-90 U-234, 235, 238 Po-208, 209 Pa-231 

Analytical support for work in R-120 and other production and development areas in R-Building. 

1950s–late 1960s R-Building (R-140) 

Unencapsulated material, removable contamination 

Sr-90: 1950s–late 1960s; Cs137: 1950s–late-1960s 

Early programs coanalytical support 120 and other proddevelopment areas 

Draft White Paper – Internal Data 47 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

Am-241 Ac-227 

Analysis of plutonium compounds, alloys, and mixtures along with related radionuclides were studied by chemical analysis and emission spectroscopy. A variety of solutions of oxide samples were commonly prepared for these analyses. This involved vaporization of compounds from arcing. 

late–1960sclosure R-Building (R-140) 

Unencapsulated material, removable contamination in glove boxes and general area identified in postoperation era 

Ac-227: late1960s–1988, 1990–1993; Am-241: late1960s–1982, 1984–1985, 1988, 1990–1993; Sensitivity of urine bioassay for Ac-227 ~100X lower than for Pu. 

Analytical program compounds, along radionuclide compincluded chemical emission spectroscVaporization of coarcing can result in diameter particles. contained removabcontamination in e1,000,000 dpm in spost-operations. Isidentification confipresence of Am-24Am-241 and Ac-22secondary radionu

U-238, Np-137, Am-241, Cm-244 

Plutonium research reactor fuels program explored a variety of uranium and later Pu-239 metal and Pu-239 dioxide compounds for possible application into the fuel program. Also used were Np-237, Am-241, Cm-244 in the metal and oxide form. The supporting resarch laboratory used an electron microprobe to characterize materials through a vaporization technique. 

1956–1969 R-Building (R-155, 159) Unencapsulated material 

Np-237: 1956–1969; Am241: 1956–1969;Cm-244: 1956–1969; U238: 1960–1964, 1967–1969 

The plutonium reagroup explored a vuranium and later pcompounds for posapplication in the fU-238 was the primradionuclide of conused were Np-237Cm-244. 

U-235, U-238 Tritium processing and research and development activities 1965–Closure R-Building, SW-Building Unencapsulated material 

U-238:1967–1971, 1973–1983, 1985–1988, 1992 

Facilities for tritium including solid tritcompounds, gas repurification, analytand other tritium hprocesses involved U-235 and U-238. used in storage bedsecondary radio-nu

Draft White Paper – Internal Data 48 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

Ac-227 

Ac-227 (oxide and nitrate) was processed in a separation procedure to acquire a pure radionuclide. 

1964–1968 

SW-Building 

(SW-140), 

R-Building 

Unencapsulated material 1965–1968 

Ac-227 oxide & niprocessed to acquiradionuclide. No rinvolved in this proSeparations & shipconducted from 191967 using materia1952–1953. Ac-22from Th-227: shipmmade 1968 - 1970. 

Ba-137m, Cs-137 

Ba-137m was separated from its parent Cs-137 by residue adsorption in a phosphate medium as a part of the Radioactive Isotopes Separation program. 

1968–1969 Unknown Unencapsulated material Cs-137/Ba- 137m: 1968– 1969 

Am-241 Production of alpha sources by plating various metal substrates. 1956–1962 1962–1965 

R-Building 

(R-116, R-120), 

SW-Building 

(SW-219) 

Unencapsulated material 

Am-241: 1956–1965 

Major radionuclide R-116. 

Th-230, Pa-231, Th-232, Ac-227, Ra-223, Ra-224, Ra-226, U-234, U-235, U-238 

Chemical recovery of Th-230 and Pa -231 from "Cotter Concentrate." Several rooms served as staging areas for the 55-gallon drums of "Cotter Concentrate." 

1970–1979 

SW-Building 

(SW-22, SW-140 

and support 

rooms) 

Unencapsulated material 

Ac-227: 1970–1979; Pa-231: 1970–1979; Th-230: 1970–1979; Th-232: 1970–1971, 1973–1979; Ra-223, 224, 226: 1970–1979; U-234, 235, 238: 1970–1971, 1973–1979 

Concentrate was puranium, cobalt, conickel isotopes as eTh/Pa analysis and occurred in 1971 aProduction facility in 1974. Th-230 production (6.85 Ci) from 197(NIOSH 2007, p. 2Th-230 represented the activity. Other Th-232; Ac-227; R226; Pa-231; U-23An incident involvoccurred on 10/30/

Draft White Paper – Internal Data 49 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Draft White Paper – Internal Data 50 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Table 1: Examples in which a Potential for Exposure to Radionuclides Existed in the Absence of Interna

Radionuclides Description Time Period Location/Area Form Gaps in Bioassay Comm

NOTICE

wever, th

Th-229, U-232, U-233, Tl-208 

Thorium-229 was separated from aged U-233 and its daughters. This was done with a chloride complex separation technique. 

1966–1975 

SW-Building 

(SW-22, SW140) Unencapsulated material 

Th-229: 1966–1975; U-232, 233: 1967–1971, 1973–1975; Tl-208: 1966–1975 

Th-229, U-233 

Modification of the Th-229 Separation Program where U-233 was the precursor of the process. 

1975–1981 

SW-Building 

(SW-22, SW140) Unencapsulated material 

Th-229: 1966–1975; U-233: 1967–1971, 1973–1981 

Po-209 Process to retrieve Po-209 from old Po-210 work. 1976–1979 SW-Building (SW-140, SW- 132) Unencapsulated material Po-209: 1976– 1979 Po-210 daughters a

radionuclides of co

Radon, Cs-137, Ra-226, Th-230, Th-232, Sr-90 

Widespread contamination particularly near the old cave area. See comment 

Outside and 

under SWbuilding 

Unencapsulated material; potential exposure from resuspension of soil 

During characterizthe late 1980s, 1992000, several outdcontamination areaidentified. SW-19 was built aentombed old caveran through fill, cosoil under SW-2 & (adjacent rooms). 
REFERENCES 

Abbott, D.T., 1990. Memorandum from David T. Abbott (Mound) to Douglas Draper (Mound), 

Henry Spitz (Mound), P. Jerry Rhude (Mound), Jack Geichman (Mound), Marilyn Wirth 

(Mound) for L.M. Coco (Mound), Robert Keys (Mound), F. Keith Tomlinson (Mound), Rn-220 

in building 21. Mound, Miamisburg, Ohio, June 12, 1990. 

Abrahamson, S.G., Fiely, R.L., Levin, S.R., 1964. Memorandum from Investigation Committee 

to L.V. Jones (Mound), Subject: Investigation of Incident in R&R Building, Monsanto Research 

Corporation, Mound Laboratory, Miamisburg, Ohio, October 7, 1964. 

ABRWH, 2010, Meeting of the Advisory Board’s Work Group on the Mound Plant, Hebron, 

Kentucky, January 5-6, 2010. 

Adams, P.C., Otto, G.W., Freeman, S.S., and Pattillo, J.A., 1962. Memorandum from 

Investigation Committee to E.A. Rembold (Mound), Subject: Accident Investigation in SM-10 

9:20 A.M. - July 26, 1962, Monsanto Research Corporation, Mound Laboratory, Miamisburg, 

Ohio, August 1, 1962. 

Amos, W.R., Voigt, J.W., Lewis, E.L., 1963. Subject: Investigation of Accident in SM-35, 

Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio, November 16, 1963. 

ANL 1984. Gross Alpha Activity Determination in Bioassay Samples, ALP-1, Argonne National 

Laboratory, Argonne, Illinois. January 1, 1984. 

ANL 1989. Actinide and Lanthanide Determination in Urine, ICDL-Revision 00, Argonne 

National Laboratory, Argonne, Illinois. June 12, 1989. 

Bigler, W.A., Rinck, R.E., Abbott, C.W., 1960. Accident Investigation Report on Spill of 

Radioactive Material in “R” Building on May 19, 1960. Miamisburg, Ohio, May 25, 1960. 

Blanke, B.C., Heindl, C.J., and Best, S., 1960. Memorandum from Investigation Committee to 

E.A. Rembold (Mound), Subject: Interim Report on Accident Investigation of Explosion of 

Neutron Source M-218 in R116A, Monsanto Research Corporation, Mound Laboratory, 

Miamisburg, Ohio. September 4, 1960. 

Blanke, B.C., 1963. SS Material Inventory Report. Monsanto Research Corporation, Mound 

Laboratory, Miamisburg, Ohio. November 30, 1963. 

Bond, W.H., Beal, T.D., Hoadley, S.D., and Molloy, P.C., 1986. Memorandum from 

Investigation Committee to W.P. Davis (Mound), Subject: Release of Contamination -- PP-16, 

Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. March 11, 1986. 

Draft White Paper – Internal Data 51 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Butz, S.D., Kahle, J.B., and Yanger, R.L., 1963. Memorandum from Investigation Committee to 

G.R. Grove (Mound), Subject: Accident Investigation in R Building 9:00 A.M. January 16, 1963, 

Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. January 18, 1963. 

BWXT 2002. T Building Structural History and Process History Summary Background 

Document, BWXT of Ohio, November 2002. 

Cheng, S.C., and D. Halcomb, no date. Innovative Approach for the Decommissioning and 

Dismantlement of the “Old Cave” Project, U.S. Department of Energy, Mound Environmental 

Management Project, Miamisburg, Ohio. No date. 

Chong, C.H.H., Witzerman, M.A., Sheehan, W.E., Garner, J.M., and Lewis, E.L., 1963. 

Memorandum from Investigation Committee to J.E. Bradley, Subject: Building Incident, SM 

Facility, Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. December 21 

1963. 

 

Davis, W.P., 1974. Memorandum from W.P. Davis (Mound) to P.C. Adams (Mound), Subject: 

Contaminated Acid Burn on November 15, 1974, Monsanto Research Corporation, Mound 

Laboratory, Miamisburg, Ohio. November 20, 1974. 

Davis, W.P. 1994. Memorandum from William P. Davis (Mound) to Douglas C. Draper 

(Mound), Draper’s Recollection of Building 21 History. EG&G Mound, Miamisburg, Ohio. 

November 10, 1994. 

Draper, D.G., 1994. Memorandum from Douglas Draper (Mound) to Paul Matthews (Mound), 

Bldg 21 Vicinity. Mound, Miamisburg, Ohio. November 10, 1994. 

Draper, D.G, 1987. Memorandum from D.G. Draper (Mound) to C.W. Smith (Mound), Bldg 21 

Entry Requirements. Mound, Miamisburg, Ohio. April 2, 1987. 

Eichelberger, J.F., Grove, G.R., Jones, L.V., 1963. Mound Laboratory Progress Report for 

June, 1963. Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. June 28, 

1963. 

EG&G Mound 1996. EG&G Document No. 9608190042. Description: Pages from document 

providing information on the Building 21 and Surrounding Soils D&D Project, Site Box Number 

21167, Accession Number 434-06-1279. EG&G Mound, Miamisburg, Ohio, June 27, 1996. 

Essig, G.A. and R.L. Neubert, 1968. Annual Review 1967, MLM-ML-67-52-0001, Mound 

Laboratory, Miasmisburg, Ohio. 

Essig, G.A. and R.L. Neubert, 1969. Annual Review 1968, MLM-ML-68-52-0004, Mound 

Laboratory, Miasmisburg, Ohio. 

Draft White Paper – Internal Data 52 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Fauble, L.G., Ruppert, P.M., Traino, F.A., Edling, D.A., 1970. Memorandum from Investigation 

Committee to W. T. Cave (Mound), Accident Investigation Report 70-21 of Hood Front Blowout 

in R-149 on 11/10/70. Monsanto Research Corporation, Miamisburg, Ohio. November 23, 1970. 

Fiely, R.L., Cargafno, D.G., Olson, O.L., Kozuszek, T.K., 1966. Memorandum from 

Investigation Committee to L.B. Gregory (Mound), Subject: Investigation of Incident in Room 

21, Special Metallurgical Building on October 21, 1966, Monsanto Research Corporation, 

Mound Laboratory, Miamisburg, Ohio. November 10, 1966. 

Freeman, S.S., Daniels, H.F., and Putnam, J., 1960. Memorandum from Investigation 

Committee to J.F. Eichelberger (Mound), Subject: Accident Investigation in R-120 3:05 P.M. - 

July 6, 1960, Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. July 12, 

1960. 

Friedline, D.E., Kokenge, B.R., McMannon, R.U., 1970. Memorandum from the Investigation 

Committee to W.T. Cave (Mound), Subject: Radiation Exposure Near Miss Informal 

Investigation Report, Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. 

July 7, 1970. 

Guillet, R.A., 1965. Memorandum from R.A. Guillet (Mound) to Wilkinson Wright (Mound), 

Process Lines Incidents through 1963-1965, Mound Laboratory, Miamisburg, Ohio. July 30 

1965. 

Heidelberg, R.F., D.A. Edling, and M.R. Hertz, 1964. Subject: Investigation of Gross 

Contamination of “T” Building on June 11 1964, Monsanto Research Corporation, Mound 

Laboratory, Miamisburg, Ohio. June 22, 1964. 

Hertz, M.R., P.E. Figgins, and W.R. Deal, 1983. “The Recovery of Protactinium-231 and 

Thorium-230 from Cotter Concentrate: Pilot Plant Operations and Process Development,” 

Monsanto Research Corporation, Mound Facility, Miamisburg, Ohio. February 10, 1983. 

Jenkins, P.H., 1978. Memorandum from P.H. Jenkins (Mound) to P.C. Adams (Mound), 

Subject: Evaluation of Inhalation Incident of [Name Redacted], Monsanto Research Corporation, 

Mound Laboratory, Miamisburg, Ohio. December 5 1978. 

Kell, R.E. and Combs, A.B., 1971. Memorandum from the Investigation Committee to J.L. 

Ricks (Mound), Subject: Investigation of Near-Miss Radiation Exposure Incident “PP” Building 

on January 27, 1971, Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. 

February 9, 1971. 

King, W.C., 1995. Mound Site Radionuclides by Location, MD-22153, Issue 1, EG&G Mound 

Applied Technologies, Miamisburg, Ohio. 

King, W.C., 1998. Mound Site Radionuclides by Location, Appendix B, MD-22153, Issue 2, 

EG&G Mound Applied Technologies, Miamisburg, Ohio. 

Draft White Paper – Internal Data 53 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Kozuszek, T.K., Requarth, J.C., Martin, L.D., and Mickey, J.S., 1977. Memorandum from 

Investigation Committee to H. L. Williams (Mound), Subject: Investigation of Unusual 

Occurrence" Investigation #7702, Monsanto Research Corporation, Mound Laboratory, 

Miamisburg, Ohio. November 11, 1977. 

Madding, R.D. and Carfagno, D.G., 1970. Memorandum from R.D. Madding (Mound) and D.G. 

Carfagno (Mound) to W.T. Cave (Mound), Subject: Rupture of a Glove in SW-13; Accident 

Report #70-15, Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. 

September 3, 1970. 

McEwen, M., 1949. Development of Special Hoods (an interim report), MLM-301, Monsanto 

Chemical Company, Miamisburg, Ohio. March 24, 1949. 

Mershad, E.A., Anderson, H.F., and Balsmeyer, D.L., 1966. Memorandum from Investigation 

Committee to J.E. Bradley (Mound), Subject: Investigation of Incident in Special Metallurgical 

Building on February 10 1966, Monsanto Research Corporation, Mound Laboratory, 

Miamisburg, Ohio. February 21, 1966. 

Meyer, H.E., 1964. Memorandum from H.E. Meyer (Mound) to E.A. Rembold (Mound), 

Subject: Investigation of Incident in Special Metallurgical Building on November 3, 1964, 

Monsanto Research Corporation, Mound Laboratory, Miamisburg, Ohio. November 13, 1964. 

Meyer, H. E., 1992. History of Mound Bioassay Programs, MLM-MV-93-93-0003, EG&G 

Mound Applied Technologies, Miamisburg, Ohio [SRDB Ref ID: 1962]. 

MJW 2002a. Pre-1989 Dose Assessment Project Phase I Final Report, Volume I, Non-SUD 

Version, MJW Corporation, Inc. April, 2002. 

MJW 2002b. Pre-1989 Dose Assessment Project Phase II Final Report, MJW Corporation, Inc. 

June, 2002. 

Monsanto 1967. Memorandum to W.B. Brown, Subject: Health Physics – 5 Year Plan, Mound 

Laboratory, Miamisburg, Ohio. May 17, 1967. 

Monsanto 1970. Bioassay Group Analytical Procedures, MD-20736, Mound Laboratory, 

Miamisburg, Ohio. April 28, 1970. 

Monsanto 1971. Summary Report – 1970. MLM-ML-71-41-0001, Monsanto Research 

Corporation, January 1971. 

Monsanto 1975. Summary Report – 1974. Monsanto Research Corporation. February 1975. 

Mound 1980. Mound Facility Activities in Chemical and Physical Research: July-December 

1979. Mound Facility, Miamisburg, Ohio. June 18, 1980. 

Draft White Paper – Internal Data 54 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Mound 1993. Operable Unit 9, Site Scoping Report Volume 3 – Radiological Site Survey, 

EG&G Mound Applied Technologies, Mound Plant, Miamisburg, Ohio. June 1993.

Mound 2001. Mound Site Radionuclides by Location, MD-22153, Issue 3, Mound Plant, 

Miamisburg, Ohio. 

Mound 2003. Handwritten Notes from Folder Title “SW Old Cave Historical,” Site Box 

Number 27621, Accession Number 434-06-1225, BWXT, Mound, Miamisburg, Ohio, June 25, 

2003. 

Mound, no date. Processes and Characterization of Major Radionuclides Handled at Mound, 

Mound Laboratory, Miamisburg, Ohio. 

Moyer, H.V. (editor), 1956. Polonium, U.S. Atomic Energy Commission, Oak Ridge, 

Tennessee. July 1956. 

Nason, H.K., 1972. Annual Technical Summary Report – 1971. Monsanto Research 

Corporation. February 1972. 

Nason, H.K., 1973. Monsanto Research Corporation Annual Technical Summary Report – 

1972. Monsanto Research Corporation. March 1973. 

Nason, H.K., Neuberg, R.L., Hardy, E.E., 1970. Annual Technical Summary Report 1969. 

Monsanto Research Corporation. February 1970. 

NIOSH 2006. SEC Petition Evaluation Report, Petition SEC-00049, Office of Compensation 

and Analysis, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

November 7, 2006. 

NIOSH 2007. SEC Petition Evaluation Report, Petition SEC-00090, Office of Compensation 

and Analysis, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

December 19, 2007. 

NIOSH 2008a. [Name Redacted] Interview, NIOSH, telephone interview, January 2008. 

NIOSH 2008b. NIOSH Response to Mound Matrix Items, Office of Compensation and Analysis, 

Cincinnati, Ohio. July 5, 2008. 

NIOSH 2009. NIOSH Evaluation of Data Adequacy and Completeness Issues at the Mound 

Laboratory, Office of Compensation and Analysis, Cincinnati, Ohio. November 2009. 

Nunn, E., Metacalf, L., Whitney, M., Dell, R., Timpone, P., 1980. Memorandum from 

Investigating Committee to Dr. H. A. Woltermann (Mound), Investigation of Small Fire in SemiWorks Building. Monsanto Research Corporation, Mound Facility, Miamisburg, Ohio. 

November 17, 1980. 

Draft White Paper – Internal Data 55 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Ofte, D., Bischoff, T., Sheehan, W., Stambaugh, A., 1965. Memorandum from Investigation 

Committee to J.E. Bradley (Mound) and L.B. Jones (Mound), Subject: SM Building Room 38 

Fire on August 27, 1965, Monsanto Research Corporation, Mound Laboratory, Miamisburg, 

Ohio. September 7, 1965. 

ORAU 2003a. Database of Excretion Data for Other Radionuclides, ORAU file locator, DOE 

Site Images, Mound Laboratory, Data Capture 09-24-03, Folder 1806; Oak Ridge Associated 

Universities for NIOSH Office of Compensation Analysis and Support, Cincinnati, Ohio; SRDB 

Ref ID: 8757. 

ORAU 2003b. Database of Ra-Ac-Th Excretion Data, ORAU file locator, DOE Site Images, 

Mound Laboratory, Data Capture 09-24-03, Folder 1805; Oak Ridge Associated Universities for 

NIOSH Office of Compensation Analysis and Support, Cincinnati, Ohio; SRDB Ref ID: 8754. 

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

Dosimetry, ORAUT-TKBS-0016-6, Rev. 00, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. August 11, 2004. SRDB Reference ID 19791. 

ORAUT 2009. Major Isotopes, Process, Material, and Bioassay Road Map for the Mound 

Laboratory, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. July 2009. 

Pardieck, W.D., Sheehan, W.E., 1978. Memorandum from Investigation Committee to Dr. H. 

Anthony Woltermann (Mound), Investigation Report of Tritium-Tracking Incident Which 

Occurred in R-Building on September 8, 1978. Monsanto Research Corporation, Mound 

Facility, Miamisburg, Ohio. September 22, 1978. 

Rogers, D.R., Garner, J.M., and Insley, J.V., 1965. Memorandum from Investigation Committee 

to J. Bradley (Mound), Subject: Investigation of Incident in Room-26 Special Metallurgical 

Building on February 26, 1965, Monsanto Research Corporation, Mound Laboratory, 

Miamisburg, Ohio. March 2, 1965. 

SC&A, 2008a. Draft Mound SEC Issues Matrix, S. Cohen and Associates, Inc., Vienna, 

Virginia. March 17, 2008. 

SC&A 2008b. Interview Summary for [Name Redacted], S. Cohen and Associates, Inc., Vienna, 

Virginia. 

SC&A 2009b. Mound Internal Dosimetry Data Completeness, S. Cohen and Associates, 

Vienna, Virginia. April 2009. 

Sheehan, W.E., 1966. Memorandum from W.E. Sheehan (Mound) to E.A. Rembold (Mound), 

Mound Laboratory, Miamisburg, Ohio. February 11, 1966. 

Sheehan, W.E., 2009a. SC&A Site Expert Interview with [Name Redacted], S. Cohen and 

Associates, Inc., Vienna, Virginia. December 17, 2009. 

Draft White Paper – Internal Data 56 SC&A – June 21, 2010 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Draft White Paper – Internal Data 57 SC&A – June 21, 2010 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

Sheehan, W.E., 2009b. Mound’s 24 Hour Urinalysis Program, unpublished memorandum, 

August 24, 2009 [SRDB Ref ID: 72071]. 

Stought, R.L., 1979. Internal Audit SW Audit SW Cave Area Radiation Safety, EG&G Mound, 

Miamisburg, Ohio. January 29, 1979. 

Stought, R.L., Edling, D.A., and Draper, D.G., 1988. The Mound Site Survey Project for the 

Characterization of Radioactive Materials in Site Soils, MLM-3517, Monsanto, Miamisburg, 

Ohio. 

Wagner, C.W. and R.L. Stought, no date. Summary of HP Support to the D&D Operation in 

R-Building Laboratories R-143, R-145/147, April 1978 through June 1980. [SRDB 59269] 

Wainwright, H.L., 1973. Letter from H.L. Wainwright (AEC) to R.K. Flitcraft (Mound), 

Subject: Investigation of Plutonium Uptake Occurring in R-Building at Mound Laboratory on 

6/18/73, Atomic Energy Commission, Dayton Area Office, Miamisburg, Ohio. August 28, 1973. 

Witzerman, M.A., Adams, P.C., and Miller, W.S., 1963. Memorandum from Investigation 

Committee to E.A. Rembold (Mound), Subject: Radiation Incident - SM-10, Monsanto Research 

Corporation, Mound Laboratory, Miamisburg, Ohio. May 1, 1963.