NIOSH Response to 

“Interim SC&A Review of the SEC 

Petition Evaluation Report for 

Petition SEC-00256: Pinellas Plant” 

Response Paper

National Institute for Occupational 

Safety and Health

October 11, 2023

Joseph Guido, CHP 

Pat McCloskey, CHP, CIH 

Oak Ridge Associated Universities Team

Reviewed by 

Madeline Cook 

Timothy Taulbee, Ph.D., CHP

Division of Compensation Analysis and Support 

Page 1 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 2 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

INTRODUCTION

NIOSH completed the Petition SEC-00256, Pinellas Plant Special Exposure Cohort (SEC) 

Petition Evaluation Report (SEC-00256 ER) [NIOSH 2021a] on October 13, 2021. At its 

December 8, 2021, meeting [NIOSH 2021b, PDF p. 53], the Advisory Board on Radiation and 

Worker Health (ABRWH, Board) requested that SC&A review the SEC-00256 ER. NIOSH 

received SC&A’s Interim SC&A Review of the SEC Petition Evaluation Report for Petition SEC00256: Pinellas Plant [SC&A 2023], dated June 16, 2023. In their Executive Summary, SC&A 

noted: 

...several new issues have recently been raised by the petitioners that may have 

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

documents found in recent data captures have not yet been reviewed. However, 

SC&A is releasing this interim draft to inform the Board and to facilitate moving 

discussions forward. [SC&A 2023, PDF p. 9] 

SC&A also indicated the following: 

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

which may reflect either unfavorably or favorably or provide noteworthy 

information on the radiation-related conditions and practices at Pinellas and the 

conclusions of the ER. [SC&A 2023, PDF p. 10]

In this response paper, NIOSH addresses the 13 observations raised in the SC&A interim review 

[SC&A 2023, PDF pp. 9–13]. The first five observations were based on a review of the SEC00256 ER itself, and the remaining observations were taken from SC&A’s review of the 1990 

Tiger Team Report [DOE 1990]. 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 3 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

NIOSH RESPONSES TO SC&A OBSERVATIONS

In the sections below, NIOSH presents SC&A’s 13 observations with a detailed response 

following each. 

SC&A Observation 1: Neutron generator production was fairly steady

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

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

into 1980. (section 3.1) [SC&A 2023, PDF pp. 10, 21] 

NIOSH Response to SC&A Observation 1: 

NIOSH concurs with this Observation. 

SC&A Observation 2: Potential for tritium contamination is adequately addressed 

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

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

also monitored via urinalysis. However, given the deficiencies noted by the Tiger Team in 

the performance of the bioassay program as late as 1990, relying on bioassay 

completeness to establish exposure potential is likely inappropriate. (section 3.3.1)

[SC&A 2023, PDF pp. 10, 27]

NIOSH Response to SC&A Observation 2: 

At issue is the identification of claimants potentially exposed to stable metal tritides (SMT) and

the subsequent assignment of the SMT exposure to those individuals. Tritium bioassay data is 

only one of the sources of information used by dose reconstruction personnel in designating 

individuals as potentially exposed to SMT. If bioassay data are available for a claimant, that 

claimant will automatically be assigned SMT dose. However, for an unmonitored individual, the 

totality of information available to the dose reconstructor is used to determine if an individual 

should have been monitored, with appropriate dose assignments to be made after that 

determination is made. 

Following the ABRWH and SC&A review of the SEC-00256 ER, NIOSH will update Pinellas 

Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5 [Oak Ridge Associated Universities 

Team (ORAUT) 2016] to include a discussion of how to determine exposure potential for 

unmonitored personnel. Based on this Observation, NIOSH will also add the following 

clarification:
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 4 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

When periods are identified during which an individual claimant should have been 

monitored but was not, internal dose from insoluble tritium (based on the methodology in 

section 5.8.1.2) will be included in addition to soluble tritium dose. 

SC&A Observation 3: The ER does not reference recent special tritium compound 

document

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

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

performing dose reconstruction for intakes of stable metal tritides from revision 01 of 

ORAUT-OTIB-0066 (2020). NIOSH should commit to reference and discuss guidance 

from OTIB-0066 in the next revision of the occupational internal dose TBD and evaluate 

whether it has any consequential effect on the SEC evaluation report conclusions. In 

addition, as noted in key aspect 2 of the stable metal tritide model accepted by the Board 

(as presented by SC&A at the August 9–10, 2016, Board meeting), sitewide air 

monitoring data or contamination survey data should be preferentially used over other 

modeling in dose reconstructions for stable metal tritides whenever available. (section 

3.3.1) [SC&A 2023, PDF pp. 10, 27]

NIOSH Response to SC&A Observation 3: 

SC&A correctly observed in their review: 

...as noted in key aspect 2 of the stable metal tritide model accepted by the Board (as 

presented by SC&A at the August 9–10, 2016, Board meeting), sitewide air monitoring 

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

dose reconstructions for stable metal tritides whenever available [SC&A 2023, PDF pp. 

10, 27]. 

Section 2.0 of the document Calculation of Dose from Intakes of Special Tritium Compounds,

ORAUT-OTIB-0066 [ORAUT 2020a] indicates that the use of workplace information is 

preferred over the use of urinalysis. Consistent with this guidance, NIOSH has adopted a 

methodology for Pinellas based on sitewide contamination data [ORAUT 2016]. This 

methodology has received the concurrence of both the ABRWH and SC&A [NIOSH 2016b, 

PDF p. 83]. 

ORAUT-OTIB-0066 [ORAUT 2020a] does not have any consequential effect on the SEC-00256

ER [NIOSH 2021a]. OTIB-0066 states “Ideally, workplace information, in the form of air 

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

intakes of this material, which is addressed in a site profile when possible” [ORAUT 2020, PDF 

p. 6]. This statement supports the current sitewide methodology used for Pinellas. Nevertheless, 

NIOSH agrees that it is appropriate to include a reference to ORAUT-OTIB-0066 [ORAUT 

2020a] along with an affirmation that the implemented methodology is consistent with OTIB-
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 5 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

0066 guidance. NIOSH will incorporate that information in the TBD Pinellas Plant – 

Occupational Internal Dose [ORAUT 2016] when it is next revised. 

SC&A Observation 4: Lack of bioassays records for 1988–1990 

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

1990, NIOSH only has monitoring records for 3–10 claimants per year. According to the 

1990 DOE Tiger Team report, approximately 1,750 people were employed in 1989, 

suggesting that monitoring records are missing. (section 4.3) [SC&A 2023, PDF pp. 10–11, 

37]

NIOSH Response to SC&A Observation 4: 

The records information cited by SC&A was derived from Tables 6-1 and 6-2 of the SEC-00256 

ER [NIOSH 2021a, PDF pp. 47–49]. Table 6-1 was developed by querying dose reconstruction 

claims files. The original query looked at a working file that is developed in preparation for the 

dose reconstruction process. This working file compiles the internal monitoring data for a claim. 

Because this compilation of data is not necessarily a complete picture of the final data used in a 

dose reconstruction, querying this specific claim document was not the appropriate way to 

determine the entries for Table 6-1 of the ER. In this case, Pinellas used a different reporting 

scheme in their files from 1988 to 1990, which led to some data being overlooked and not 

transcribed into the dose reconstruction preparation file. Because the data preparation file was

the source of the information used in Table 6-1, the data presented in Table 6-1 for those years 

was incomplete, as SC&A pointed out. Again, this issue did not impact the dose reconstruction 

process, because the actual dose reconstructions used all the available data. This issue 

specifically impacted how Table 6-1 of the ER was developed. 

NIOSH will not retroactively update the ER but has updated the 1988, 1989, and 1990 tabulation 

(see Table 1, below) to include all bioassay data used in each individual dose reconstruction 

report, as well as data received since the dose reconstruction was performed. It is worth noting 

here that monitoring data received after the completion of a dose reconstruction report is 

periodically evaluated to determine the impact on each individual claim probability of causation

(POC) determination. If the POC changes (from <50% to >50%), NIOSH notifies the 

Department of Labor and asks for the claim to be returned for a revised dose reconstruction. 

Table 1 below provides an update for the Pinellas Plant based on the complete 1988, 1989, and 

1990 bioassay data collection. Using this collection, the number of Pinellas claimants reported to 

have been monitored by tritium bioassay now ranges from 22 to 35 from 1988 to 1990, rather 

than 3 to 10 as reported in the SEC-00256 ER [NIOSH 2021a, PDF p. 48]. As shown below in 

Table 1, for 1988, 1989, and 1990, the percentage of all Pinellas employees monitored by 

bioassay was 7.5%, 11.8% and 10.7%, respectively; the percentage of the population of 

claimants monitored by bioassay was 7.1%, 11.7%, and 8.0%, respectively. The percentage of 

Pinellas claimants monitored by bioassay is similar to the percentages of employees monitored 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 6 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

by bioassay as reported by Pinellas for 1988–1990. The monitoring frequency for the Claims 

Tracking System (NOCTS) dataset is no longer inconsistent with that for the site population. 

Table 1. Tritium bioassay data for Pinellas employees, 1988 to 1990. 

Year

Total Site 

Personnela

Employees (#) 

Monitored by 

Bioassayb

Employees (%)

Monitored by 

Bioassay

Pinellas 

Claimants 

in 

NOCTSc

Pinellas 

Claimants (#)

Monitored by 

Bioassayd

Pinellas 

Claimants (%) 

Monitored by 

Bioassayd

1988 1720 129 7.5% 310 22 7.1%

1989 1700 201 11.8% 299 35 11.7%

1990 1650 177 10.7% 288 23 8.0% a Sources: 1988 [GE 1989], 1989 [GE 1990], and 1990 [DOE 1991] b [Weaver 1992, PDF p. 12] c As of the SEC-00256 ER [NIOSH 2021a] (through NOCTS Claim #53368) d Data derived from [Tritium Bioassay Results 1988], [Bioassays and Recounts 1989], [Personnel Bioassay Results 1990]. 

NOCTS update [ORAUT 2023]. 

SC&A Observation 5: Bioassay schedule noncompliance by the plant

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

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

Appropriate bioassay compliance (data completeness levels) in general is a subjective 

judgment to be made by the Board. In addition, the level of compliance with the bioassay 

program is unknown before the findings of the Tiger Team. It is SC&A’s opinion that at a 

minimum, NIOSH should demonstrate that an appropriate co-exposure model can be 

constructed to address apparent incompleteness in the tritium bioassay program (likely 

throughout its relevant operating history). Despite concerted efforts by the site to rectify 

the compliance issues, nearly one-fifth of worker bioassay requirements were still not 

met. Bounding co-exposure values would certainly appear warranted during this latter 

period (1991–1997). (section 4.3) [SC&A 2023, PDF pp. 11, 39]

NIOSH Response to SC&A Observation 5: 

NIOSH does not believe that the demonstration of a co-exposure model is necessary to address 

the "apparent incompleteness in the tritium bioassay program." The Tiger Team's report was a 

basis for the SEC-00256 ER [NIOSH 2021a] which evaluated and affirmed NIOSH's ability to 

accomplish dose reconstruction for Pinellas Plant workers even when considering these noncompliance issues. 

Since SC&A did not comment on the evaluation outlined in the SEC-00256 ER, it is summarized 

below for renewed consideration. 

1. The total internal dose and the average individual tritium dose generally followed a 

downward trajectory from 1986 through 1990 and continued in the same direction 

through the end of reporting in 1995 when the Pinellas Plant was undergoing D&D work. 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 7 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

Therefore, the increase in bioassay compliance achieved in response to the DOE Tiger 

Team findings did not lead to an increase in the Pinellas Plant’s total measured internal 

dose or the average individual internal dose, as might be expected if the bioassay 

program had missed identifying significant exposures [NIOSH 2021a, PDF p. 63]. 

2. According to the findings of the 1990 Tiger Team report, this group of workers, who 

were generally sampled daily or weekly, was more compliant with the sampling program 

than the workers with lower exposure potential, who were sampled on a monthly 

frequency. This finding indicates that the monitoring data that is available would likely 

be biased high due to the larger fraction of missing data from the workers with lower 

exposure potential. In turn, any unmonitored dose approach based on the monitored 

workers would also be biased high [NIOSH 2021a, PDF p. 63]. 

3. NIOSH reviewed NOCTS claimant files for individuals who worked prior to 1990. 

NIOSH confirmed that the workers that would be expected to have had a potential for 

internal tritium exposure (e.g., those with hands-on tritium work or tritium-equipment or 

systems-maintenance responsibilities) were in fact monitored [NIOSH 2021a, PDF p. 

63]. 

4. NIOSH reviewed NOCTS files to evaluate bioassay compliance and found that the lack 

of any clear indication of when a urine sample had to be submitted made it impossible to 

quantify the degree of compliance with bioassay schedules for each former worker. 

However, NIOSH analyzed the number of urinalysis results each year for each claimant 

to identify indications of volatility in the number of samples submitted from 1957 

through 1989. This analysis of the data identified only four claims that seemed to be more 

variable than the others, having significant changes in the numbers of samples given from 

one year to the next, and worth further review in detail. The four claim records were for a 

lab technician, a maintenance craftsman, a development physicist, and a neutron tube 

technician. All of these were jobs that NIOSH would expect to be on a weekly to monthly 

urine sample schedule. NIOSH reviewed these claims and determined that the worker 

monitoring appeared consistent with the job responsibilities and exposure potential for 

these workers [NIOSH 2021a, PDF p. 64]. 

5. The Tiger Team audit document does not include references, specific data, or 

documentation to support the finding related to bioassay procedure compliance; 

therefore, NIOSH must assess its statements at face value. During interviews with former 

workers and DOE oversight staff, NIOSH asked participants to identify the cause of 

bioassay non-compliance. Of the 15 former Pinellas workers and DOE oversight staff 

who were interviewed specifically on the topic of participation in the bioassay program, 

all stated that they did not know of workers not submitting samples as requested 

[ORAUT 2020b,c,d,e,f,g,h,i,j,k, 2021a,b,c,d,e]. Although they did not know of workers 

who were not submitting samples, the responses on possible causes ranged widely. A 

former worker who had participated in the Tiger Team audit said the Plant set the 80% 

participation goal in response to the audit, and that non-participation was sometimes a 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 8 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

result of workers being on leave during their scheduled sample period [ORAUT 2020b, 

PDF p. 7]. This same former worker informed NIOSH that there were support personnel 

who entered a production area on a non-routine basis, whom the site assigned to the 

bioassay sample program for routine sampling instead of only requiring the worker to 

provide a sample upon leaving the tritium area. Providing a sample when exiting a 

radiological area was the Plant’s protocol for non-routine entries involving exposure 

potential. Thus, according to the interviewee, there were a large number of people who 

remained on the routine sampling program after it was no longer appropriate [ORAUT 

2020b, PDF p. 6]. A Radiation Control Compliance document from 1993 reports that the 

system used to document participation did not accurately track the reason samples were 

not submitted (i.e., vacation, sick leave, reassignment, or “just forgot") [Martin Marietta 

1993, PDF p. 6]. Therefore, NIOSH doesn’t have any evidence or indication of a single 

root cause of non-compliance with the requirement to submit a bioassay sample. It is 

unlikely that the non-compliance issue was a systemic problem, and there is no indication 

it was widespread among the workers. Therefore, the bioassay compliance issue does not 

impact NIOSH’s ability to develop a dose reconstruction approach based on the available 

monitored worker data [NIOSH 2021a, PDF p. 64]. 

6. NIOSH currently applies the 95th percentile whole body dose to all Pinellas claimants 

who were potentially exposed to photons or neutrons and were unmonitored for external 

exposure. NIOSH determined that the use of an unmonitored approach, based on the 

‘whole body’ dose, as a surrogate for the internal dose component is appropriate and 

claimant-favorable when alternative approaches are not viable. NIOSH will update 

Pinellas Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5 [ORAUT 2016] 

following the review of the SEC-00256 ER by the ABRWH and SC&A. This update will 

include a discussion of how to determine exposure potential for unmonitored workers or 

workers with large gaps in dosimetry, as well as a discussion of available approaches to 

bound internal dose [NIOSH 2021a, PDF p. 66]. 

In summary, the Pinellas Plant improved worker compliance with urine sample submission 

frequency following the 1990 Tiger Team report, and NIOSH found that measured doses did not 

increase as a result of improved compliance. This result indicates there was no significant dose 

that went unmonitored when workers sometimes did not turn in the urine samples according to 

procedure. NIOSH’s review of claimant records indicates that tritium bioassay data are available 

for the workers most likely to have been exposed during the period under evaluation. Bioassay 

data are available for the time period, for the personnel who worked in the areas, doing the jobs 

that NIOSH considers to have the potential for radiation exposure. NIOSH will update the site 

profile document, Pinellas Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5 

[ORAUT 2016] to further explain the approaches for determining internal tritium dose for 

unmonitored personnel and how NIOSH will use those approaches to bound internal dose based 

on claim information, job title, and monitoring history. 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 9 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

SC&A Observation 6: Radiological protection program commended by Tiger Team 

On a positive note, commending the radiological protection program, section 4.4.11.1 (p. 

4-90) of the 1990 DOE Tiger Team report states, “The overall assessment is that all 

levels of the GEND [General Electric Neutron Devices, another name for the Pinellas 

Plant] organization are receiving adequate radiological protection. This is primarily due 

to a GEND staff that appears willing to accept line responsibility for radiological safety 

along with a technically strong health physics staff providing direction.” [SC&A 2023, 

PDF pp. 11, 39]

NIOSH Response to SC&A Observation 6: 

NIOSH concurs with this Observation. 

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

Tiger Team

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

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

noncompliance issues related to the plant not following bioassay sampling frequency 

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

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

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

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

frequencies has not been satisfactory.” [SC&A 2023, PDF pp. 11, 40]

NIOSH Response to SC&A Observation 7: 

NIOSH concurs with this Observation. Indeed, the cited Tiger Team finding was the basis for the 

qualification of the Pinellas SEC Petition [NIOSH 2020]. Additional discussion on the bioassay 

compliance issue reported by the Tiger Team [DOE 1990] and evaluated in the SEC-00256 ER

[NIOSH 2021a] is included in the response to Observation 5. 

SC&A Observation 8: Contamination controls found generally good by Tiger Team 

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

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

instances when it is not: “Contamination controls are generally good. Contamination 

levels within the work areas are kept low and generally confined to the source. 

Indications were found that proper contamination control techniques are not always 

being followed, in some areas causing contamination spread to the general areas of the 

facility.”
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 10 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

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

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

personnel when working in and exiting from Contaminated Areas.” The report (p. 4-102) 

notes that a contractor disagreed that workers were inadequately protected given the 

extremely low contamination levels detected and that “radiation exposures from these 

contamination levels are not measurable, as supported by bioassay sampling.”

[SC&A 2023, PDF pp. 11–12, 40] 

NIOSH Response to SC&A Observation 8: 

As noted above, the Tiger Team Assessment of the Pinellas Plant stated: “Contamination 

controls are generally good. Contamination levels within the work areas are kept low and 

generally confined to the source” [DOE 1990, PDF p. 217]. Additional complimentary 

commentary from DOE 1990 included: 

• The overall assessment is that all levels of the GEND [General Electric Neutron Devices, 

another name for the Pinellas Plant] organization are receiving adequate radiological 

protection. This is primarily due to a GEND staff that appears willing to accept line 

responsibility for radiological safety along with a technically strong health physics staff 

providing direction.” [DOE 1990, PDF p. 216] (See also SC&A Observation 6) 

• Occupational internal exposures are low compared to other DOE sites. This 

accomplishment results from a conservative approach to working with tritium and 

through extensive use of engineering controls.” [DOE 1990, PDF p. 217] (See also

SC&A Observation 7) 

The Tiger Team characterization of contamination controls being ‘generally good’ would seem 

to speak to the overall working conditions within the Pinellas Plant. The negative Tiger Team 

statements [DOE 1990, PDF pp. 217, 227] cited in SC&A Observation 8 are related to an 

instance of surface contamination on a step-off pad and adjacent hallway [DOE 1990, PDF p. 

227] and would represent a transient condition. Based on the general Tiger Team remarks on the 

Pinellas Radiation Protection Program, it is unlikely that such conditions were frequent. 

The Tiger Team report [DOE 1990] made note of the contractor comments to that effect:

It is the contractor’s position that...: 

1) calculations will show that radiation exposures from these contamination levels are 

not measurable, as supported by bioassay sampling; and 

2) contamination levels which could cause measurable exposures are well controlled at 

the source. This is supported by routine work and contamination area surveys, which 

show that routine contamination levels within these zones are not significantly above 

uncontrolled area limits. [DOE 1990, PDF p. 228] 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 11 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

NIOSH does not believe that such transient conditions represent a challenge to reconstructing 

internal dose for claimants under the Energy Employees Occupational Illness Compensation 

Program Act of 2000 (EEOICPA). The contamination control limits used for controlled areas 

(440 dpm/100 cm2 [GE, no date; PDF p. 3]) and uncontrolled areas (220 dpm/100 cm2 [Burkhart 

1989, PDF p. 2]) are well below the values generally defined for contamination areas 

(10,000 dpm/100cm2) [10 C.F.R. 835] and represent a nominal internal dose potential. The 

average internal dose for all monitored workers between 1988 and 1991 ranged between 1.04 

and 4.38 mrem/year [Weaver 1992, PDF p. 11] and would include any exposure from plant-wide 

surface contamination. 

SC&A Observation 9: Bioassay sampling program implementation inadequacies noted by 

the Tiger Team

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

radiological protection findings and concerns related to internal dosimetry that are 

relevant here. Of particular importance, finding RP.7 (p. 4-98) claims that “Procedural 

requirements have not been established for an employee’s termination bioassay, nor a 

system developed to identify and address those individuals who fail to provide a bioassay 

sample.” Additionally, “GEND estimated that 20 percent of the personnel that 

terminated in 1988 did not provide a termination bioassay,” and that “Individual 

workers, their supervisors, and management are not ensuring that required bioassay 

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

GEND procedures. Seventy percent of the required monthly samples and 35 percent of 

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

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

[SC&A 2023, PDF p. 12, 40] 

NIOSH Response to SC&A Observation 9: 

NIOSH concurs with this Observation. As noted above by SC&A, the cited Tiger Team finding 

was the basis for the qualification of the Pinellas SEC Petition [NIOSH 2020]. Additional 

discussion on the bioassay compliance issue reported by the Tiger Team [DOE 1990] and 

evaluated in the SEC-00256 ER [NIOSH 2021a] is included in the response to Observation 5. 

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

production and mindset that Pinellas poses no unusual radiological risks

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

assessments. It opines the following on the probable root causes of some of its deficiency 

findings and lists the following two: “First, emphasis on production has traditionally 

overshadowed interest in fully complying with environment, safety and health 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 12 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

requirements”; and “Second, there is a wideset mindset that the Pinellas Plant poses no 

unusual or unique risks.” [SC&A 2023, PDF p. 12, 40]

NIOSH Response to SC&A Observation 10: 

The Management Assessment portion of the Tiger Team Evaluation [DOE 1990, PDF pp. 287–

319] identified 16 findings, none of which specifically identified issues with the Pinellas 

Radiation Protection Program. The text cited in Observation 10 was extracted from the ‘Probable 

Root Causes’ section [DOE 1990, PDF p. 319] and is related to the identified management 

deficiencies, none of which impacted the ability of Pinellas to accurately monitor personnel 

radiation exposure. 

In fact, as noted in the response to Observation 8, the Tiger Team assessment included a number 

of complimentary statements specific to the radiation protection program: 

• The overall assessment is that all levels of the GEND [General Electric Neutron Devices, 

another name for the Pinellas Plant] organization are receiving adequate radiological 

protection. This is primarily due to a GEND staff that appears willing to accept line 

responsibility for radiological safety along with a technically strong health physics staff 

providing direction. [DOE 1990, PDF p. 216] (See also SC&A Observation 6).

• Occupational internal exposures are low compared to other DOE sites. This 

accomplishment results from a conservative approach to working with tritium and 

through extensive use of engineering controls. [DOE 1990, PDF p. 217] (See also SC&A 

Observation 7).

It is NIOSH’s position that this observation does not imply a deficiency in the ability of Pinellas 

to accurately monitor personnel radiation exposure, nor a deficiency in the program’s ability to 

determine potential dose. 

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

reduced exposures

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

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

September 30, 1990). While data indicate a significant decrease for external doses from 

1990 to 1991, there was an increase in internal doses from tritium from 1990 to 1991, 

then a gradual decreasing trend during the years 1992–1995. The number of workers 

bioassayed for tritium remained reasonably consistent during the period 1986–1995, and 

the number of workers monitored for external exposure gradually decreased during the 

period 1985–1995. According to the “1991 Annual ALARA Program Report for Ionizing 

Radiation,” the increase in internal dose was due to the “T” box incident and recovery 

operations in Area 182C conducted in late December 1991. To date, SC&A has not found 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 13 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

indications that there are issues with exposure records that would prevent DR feasibility 

for the SEC period 1957–1990, nor for the period 1991–1997. (section 4.5) [SC&A 2023, 

PDF p. 12, 41]

NIOSH Response to SC&A Observation 11: 

NIOSH concurs with this Observation. 

SC&A Observation 12: ER is consistent with interview records

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

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

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

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

general, the interviewed workers in physics, engineering, chemistry, and lab-related 

professions had experience with the site internal and external monitoring program. The 

recollections reported in the interviews, in general, are consistent with the NIOSH SEC 

evaluation report. (section 5.4) [SC&A 2023, PDF pp. 12–13, 44]

NIOSH Response to SC&A Observation 12: 

NIOSH concurs with this Observation. 

SC&A Observation 13: Pinellas plant diligent in following up on contamination-related 

incidents

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

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

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

various incidents, and most (1) indicate that followup monitoring was performed for 

employees involved in the incidents and (2) provide recommendations to prevent the 

incidents from reoccurring. However, given the lack of bioassay records for the years 

1988–1990 described in observation 4 (section 4.3) and the issues surrounding bioassay 

noncompliance described in observation 5 (section 4.3), observation 7 (section 4.4), and 

observation 9 (section 4.4), it is possible that the program may not have captured all the 

internal exposures related to contamination incidents. (section 6.2.2) [SC&A 2023, PDF 

pp. 13, 49]

NIOSH Response to SC&A Observation 13: 

NIOSH has evaluated the issues related to missing bioassay data (Observation 4) and has 

concluded that there is no indication that bioassay data is missing. Similarly, NIOSH has 

addressed the issue related to bioassay compliance (Observations 5, 7, and 9) and has concluded 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 14 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

there is no impact to the feasibility to reconstruct internal dose at the Pinellas Plant. With these 

issues resolved, the assertion “the program may not have captured all the internal exposures 

related to contamination incidents” is unsupported. As stated in Observation 11, “To date, SC&A 

has not found indications that there are issues with exposure records that would prevent DR

[dose reconstruction] feasibility for the SEC period 1957–1990, nor for the period 1991–1997.”

CONCLUSION

Based on the evaluation of the 13 Observations made by SC&A in their Interim Review [SC&A 

2023], NIOSH finds that none of the Observations contradict the conclusions presented in the 

SEC-00256 ER [NIOSH 2021a].
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 15 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

REFERENCES

Bioassays and Recounts 1989 Pinellas [1989]. Pinellas Plant, Largo, FL. January 3 through 

December 29. [SRDB Ref ID 197484] 

Burkhart, RA [1989]. Release criteria used at GEND. Pinellas Plant, Largo, FL: General Electric 

Neutron Devices. October 2. [SRDB Ref ID: 12168] 

DOE [1990]. Tiger Team assessment of the Pinellas Plant. Washington, DC: U.S. Department of 

Energy, Assistant Secretary for Environment, Safety and Health. DOE/EH-0126, May. [SRDB 

Ref ID: 46090] 

DOE [1991]. Pinellas plant environmental monitoring report 1990. Pinellas Plant, Largo, FL: 

Department of Energy, Environmental Health and Safety Programs. NDPP-OSP-0053, August 9. 

[SRDB Ref ID: 12007] 

GE [1989]. Pinellas plant environmental monitoring report 1988. Pinellas Plant, Largo, FL: 

General Electric Neutron Devices. GEPP-EV-1193, June 1. [SRDB Ref ID: 13252] 

GE [1990]. Pinellas plant environmental monitoring report 1989. Pinellas Plant, Largo, FL: 

General Electric Neutron Devices. GEPP-EV-1061, June. [SRDB Ref ID: 13257] 

GE [no date]. Tritium smear surveys preparation and processing. Section 2.5 of unknown 

document. Pinellas Plant, Largo, FL. [SRDB Ref ID: 12958] 

Martin Marietta [1993]. Final action plan MMSC -OSP-93052. Section 3.4. Pinellas Plant, 

Largo, FL: Martin Marietta Specialty Components. MMSC-OSP-93052. [SRDB Ref ID: 12956] 

NIOSH [2016a]. U.S. Department of Health and Human Services Centers for Disease Control 

National Institute for Occupational Safety and Health Advisory Board on Radiation and Worker 

Health Pinellas Plant Work Group Thursday, February 11, 2016. Transcript. Washington, DC: 

Department of Health and Human Services, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, Advisory Board on Radiation and Worker 

Health. [SRDB Ref ID: 187124] 

NIOSH [2016b]. United States of America Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on Radiation and Worker Health 112th meeting 

Tuesday August 9, 2016. Transcript. Washington, DC: Department of Health and Human 

Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety 

and Health, Advisory Board on Radiation and Worker Health. [SRDB Ref ID: 198486] 

NIOSH [2020]. Petition qualification review for special exposure cohort (SEC) petition SEC00256, Pinellas Plant. Cincinnati, OH: U.S. Department of Health and Human Services, Centers 

for Disease Control and Prevention, National Institute for Occupational Safety and Health. 

October 21. [SRDB Ref ID: 186383] 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 16 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

NIOSH [2021a]. Special exposure cohort petition evaluation report petition SEC-00256 rev. 0 

Pinellas Plant qualified October 20, 2020. Cincinnati, OH: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, National Institute for Occupational 

Safety and Health. October 13. [SRDB Ref ID: 190456] 

NIOSH [2021b]. U.S. Department of Health and Human Services Centers for Disease Control 

National Institute for Occupational Safety and Health Advisory Board on Radiation and Worker 

Health 143rd Meeting Wednesday, December 8, 2021. Transcript. Washington DC: Department 

of Health and Human Services, Centers for Disease Control and Prevention, National Institute 

for Occupational Safety and Health, Advisory Board on Radiation and Worker Health. December 

8. [SRDB Ref ID: 198487] 

ORAUT [2016]. Pinellas Plant – occupational internal dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0029-5 Rev. 03, July 18. [SRDB Ref ID:

158070] 

ORAUT [2020a]. Calculation of dose from intakes of special tritium compounds. Oak Ridge, 

TN: Oak Ridge Associated Universities Team. ORAUT-OTIB-0066 Rev. 01, October 15. 

[SRDB Ref ID: 183483] 

ORAUT [2020b]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990 October 23, 

2020. Oak Ridge, TN: Oak Ridge Associated Universities Team. October 23. [SRDB Ref ID: 

185745] 

ORAUT [2020c]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples November 30, 2020. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. November 30. [SRDB Ref ID: 185748] 

ORAUT [2020d]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 2, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 2. [SRDB Ref ID: 185752] 

ORAUT [2020e]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 7, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 7. [SRDB Ref ID: 185809] 

ORAUT [2020f]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 7, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 7. [SRDB Ref ID: 185753] 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 17 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

ORAUT [2020g]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 9, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 9. [SRDB Ref ID: 185749] 

ORAUT [2020h]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 9, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 9. [SRDB Ref ID: 185754] 

ORAUT [2020i]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 16, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 16. [SRDB Ref ID: 185929] 

ORAUT [2020j]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 22, 2020. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 22. [SRDB Ref ID: 185747] 

ORAUT [2020k]. Documented communication SEC-00256 with [name redacted] on ability to

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples December 22, 2020. Oak Ridge, TN: Oak Ridge Associated

Universities Team. December 22. [SRDB Ref ID: 185813] 

ORAUT [2021a]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples January 14, 2021. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 14. [SRDB Ref ID: 185751] 

ORAUT [2021b]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples January 27, 2021. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 27. [SRDB Ref ID: 185810] 

ORAUT [2021c]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples January 28, 2021. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 28. [SRDB Ref ID: 185812] 

ORAUT [2021d]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples February 1, 2021. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. February 1. [SRDB Ref ID: 185811] 
Response Paper NIOSH Response to 

Interim SC&A Review of the SEC Petition Evaluation Report 

for Petition SEC-00256: Pinellas Plant

October 11, 2023

Page 18 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

ORAUT [2021e]. Documented communication SEC-00256 with [name redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, particularly 

those not returning bioassay samples February 2, 2021. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. February 2. [SRDB Ref ID: 185814] 

ORAUT [2023]. Pinellas bioassay data compiled to respond to SC&A observation 4 on the 

Pinellas ER 2023 ORAU team project spreadsheets. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. August 11. [SRDB Ref ID: 197977] 

Personnel bioassay results 1990 [1990]. Pinellas Plant: Largo, FL. January 2 through December 

7. [SRDB Ref ID: 133535] 

SC&A [2023]. Interim SC&A review of the SEC petition evaluation report for petition SEC00256: Pinellas Plant 2023 - draft. Arlington, VA: SC&A. SCA-TR-2023-SEC001 Rev. 0, June 

16. [SRDB Ref ID: 198062] 

Tritium Bioassay Results 1988 [1988]. Pinellas Plant: Largo, FL. January 4 through December 

27. [SRDB Ref ID: 133433] 

Weaver AS [1992]. ALARA program report for CY1991. Pinellas Plant, Largo, FL: General 

Electric Neutron Devices. April 13. [SRDB Ref ID: 182933]