Preliminary Draft 

For the Mound Work Group Review 

MOUND INTERNAL DATA ADEQUACY AND COMPLETENESS 

ISSUE STATUS REPORT 

Prepared by 

Lynn Ayers 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

October 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.
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 2 of 7 

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.

Document Description: 

Draft Status Report – Mound 

Effective Date: 

Draft – October 4, 2010 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 0 (Draft) 

MOUND INTERNAL DATA ADEQUACY AND 

COMPLETENESS ISSUE STATUS REPORT 

Page 2 of 7 

Task Manager: 

______________________________ Date: 

Joseph Fitzgerald 

Project Manager: 

______________________________ Date: 

John Mauro, PhD, CHP 

Supersedes: 

N/A 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 10/04/2010 Initial issue 
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 3 of 7 

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.

1.0 INTRODUCTION 

Upon release of Mound Internal Dosimetry Data Adequacy and Completeness (SC&A 2010), 

questions were raised regarding the resolution status of all matrix items associated with Mound 

internal dosimetry. At the request of the Mound Work Group, SC&A has reviewed several 

earlier papers to determine which issues have been resolved or closed, which open concerns 

merit further consideration in the Special Exposure Cohort (SEC) review, and which issues are 

relevant to the Site Profile and the dose reconstruction process, rather than the SEC evaluation. 

The review encompassed internal dosimetry concerns from the Mound Composite Matrix

(SC&A 2008), five SC&A papers presented to the Work Group in 2009 (SC&A 2009a–2009e), 

and the most recent paper (SC&A 2010). A complete list of reference documents is provided in 

Section 3.0. A brief description was prepared for each major discussion point in the 2009 

internal dosimetry papers, and notations were made to indicate the matrix item, resolution status, 

and discussion of the issue in SC&A 2010. The open items that were not covered in SC&A 2010 

were reviewed for their pertinence to the SEC evaluation or the Site Profile. 

Results of this review are tabulated in Section 2.0. Table 1 lists the remaining open SEC issues 

that were not thoroughly discussed in SC&A 2010. Table 2 lists several issues raised in the 

context of the SEC review that are applicable to the Site Profile. 
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 4 of 7 

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.

2.0 ISSUE STATUS 

Table 1: Open SEC Issues Not Addressed in SC&A 2010 

SC&A Document/Reference Issue Description Matrix 

Item 

SC&A 2009a, Section 3.1 Uncertainties and low recovery for Polonium bioassay procedures 11 

SC&A 2009a, Section 3.2 

Partial coverage in SC&A 

2010 (gross alpha and anion 

exchange) 

Thorium bioassay data 

o Uncertainties and concerns regarding analytical methods prior 

to 1970. No specific procedure 1959–1967. 

o Procedures not evaluated for effectiveness or plausibility. 

o Radium daughter analysis of limited value – cannot assume 

equilibrium. 

o Thorium urinalysis and modeling. 

o Unusual forms of thorium (YY). 

11 

SC&A 2009a, Section 3.3 Use of surrogate radionuclides in the absence of isotope-specific 

bioassay data 

o Pa-231 determination from Th-227 and Ra-223. 

o Ac-227 and Th-228 determination from differential decay of 

radium daughters. 

11 

SC&A 2009a, Section 3.5 

Partial coverage in SC&A 

2010 (isotopes, lack of data, 

gross alpha). Solubility and 

procedure issues are not 

covered in detail. 

Uranium bioassay adequacy 

o Multiple isotopes and compounds of varied solubility were 

handled. 

o Uncertainty regarding procedure. 11 

SC&A 2009a, Section 3.7 

Brief mention in SC&A 2010 

Price-Anderson Amendments Act – remaining issues 

o Lacked capability to monitor for all radionuclides present. 

o Lacked radiological characterization data and appropriate 

guidance for supervisors and HPs to assess bioassay needs. 

RWP bioassay requirements did not include all isotopes of 

concern for the work activity. 

o Failed to obtain, analyze, and/or obtain vendor analysis of 

bioassay samples in timely manner. Potential for missed dose 

if follow-up cannot be confirmed. [Absorbed from Matrix 

Item 21.] 

11 

SC&A 2009b, Section 3.6 Other radionuclide data (SC&A data comparison) 

o ~95% of data found for selected individuals was collected in 

1990 and later. Pre-1990 results included uranium, thorium, 

and curium. 

o Majority of pre-1990 results not available in MESH. 

o Data comparison was difficult – units and radionuclides did not 

always match (e.g., monitoring daughter to evaluate parent). 

o Volume corrections were not possible in many cases. 

12 
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 5 of 7 

 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.

Table 1: Open SEC Issues Not Addressed in SC&A 2010 

SC&A Document/Reference Issue Description Matrix 

Item 

NOTICE:

SC&A 2009c, Section 4.6 Secondary/Other radionuclide data (MJW evaluation) 

o Some results were not associated with a name, social security 

number, or HP number. 

o Results with no units. 

o Result attributed to 2 or 3 different radionuclides. 

o Information was poorly documented, often approximate at best. 

o Questionable use of surrogate bioassay. 

o Inconsistent/conflicting interpretation. 

o Insufficient data to determine need for Phase II assessment. 

12 

SC&A 2009c, Section 4.0 Tritium logbooks are missing for 1976 and 1977 (MJW evaluation) 

o HTO dose data are available in MESH; the raw bioassay data 

are missing. 

o Can’t apply NIOSH model for estimating tritide dose without 

the bioassay data. 

12 

SC&A 2009d 

SC&A 2009e, Section 3.3 

o Interpretation of tritium bioassay data and exposure to stable 

metal tritides. 

o Unresolved concerns regarding feasibility of dose 

reconstruction for STCs. 

o Can’t appreciate scope of tritium program without classified 

references. 

6 

SC&A 2009a, Section 3.6 

SC&A 2009d 

Tritium bioassay data adequacy 

o Don’t have algorithm for early dose calculations. 

o Compounds other than HTO were apparently not considered 

in bioassay. 

6, 11 
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 6 of 7 

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.

Table 2: Site Profile Issues 

SC&A Document / Reference Issue description 

SC&A 2009b, Section 3.1 Plutonium data comparison – some gaps in all sources 

Need to check all sources to get complete history for individual 

SC&A 2009b, Section 3.2 Polonium data comparison – some gaps in all sources 

Need to check all sources to get complete history for individual 

SC&A 2009b, Section 3.3 Fecal bioassay data: 

o Few results in PURECON – poor overlap w/logbooks. 

o Majority of data is missing from individual exposure files. 

o Most data are available in logbooks or could be estimated from urine 

bioassay, but may not be accessible to personnel performing dose 

reconstruction. 

SC&A 2009b, Section 3.4 Tritium (HTO) data comparison: 

o Two individuals from SC&A’s data completeness evaluation had 

bioassay data that were not reflected in MESH tritium dose data; one 

of these individuals had positive results. 

o Extent of problem is unknown, because a comprehensive data 

comparison has not been completed. 

SC&A 2009b, Section 3.5 In-vivo data – database is incomplete 
Effective Date: 

October 4, 2010 

Revision No. 

0 – Draft 

Document Description: 

Draft Status Report – Mound 

Page No. 

Page 7 of 7 

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.

3.0 REFERENCES 

SC&A 2008. Mound Composite Matrix, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., 

Jefferson, Maryland. February 2008. 

SC&A 2009a. Mound Internal Dosimetry Data Adequacy, SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc., Jefferson, Maryland. April 2009. 

SC&A 2009b. Mound Internal Dosimetry Data Completeness, SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. April 2009. 

SC&A 2009c. Mound Internal Dosimetry Data Quality Assurance, SC&A, Inc., Vienna, 

Virginia, and Saliant, Inc., Jefferson, Maryland. April 2009. 

SC&A 2009d. Response to Modeling of Intakes for Special Tritium Compounds, Revision 0, 

SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. April 2009. 

SC&A 2009e. Mound Roadmap Response, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., 

Jefferson, Maryland. December 2009. 

SC&A 2010. Mound Internal Dosimetry Data Adequacy and Completeness, Preliminary Draft 

for the Mound Work Group Review, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. May 2010.