Draft 

MOUND LABORATORY SITE 

POTENTIAL EXPOSURES TO STABLE METAL TRITIDES 

REVISION 1 

Contract No. 200-2009-28555 

Prepared by 

Joseph Fitzgerald 

John Mauro, PhD, CHP 

Bob Barton III 

Ron Buchanan, PhD, CHP 

John Stiver, MS, CHP 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

July 2012 

Disclaimer 

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

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.

 
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Document No. 

Mound – Stable Metal Tritides 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Effective Date: 

July 06, 2012 

Mound Laboratory Site Potential Exposures to 

Stable Metal Tritides Page 2 of 92 

Task Manager: 

________________________ Date: ___________ 

Joseph Fitzgerald 

Supersedes: 

Draft Rev. 1 

Project Manager: 

________________________ Date: ___________ 

John Stiver, CHP 

Reviewers: 

 None. 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 05/24/2012 Initial issue 

05/31/2012 Privacy Act-cleared version distributed. Some minor deletions concerning legal 

wording were removed from this version. These deletions did not affect the intent or 

integrity of the technical document. Minor redactions were also made in this version 

in accordance with the Privacy Act. 

1 (Draft) 07/06/2012 Changes made to Sections 5.2 and 5.4 to reflected reasonable changes in parameter 

values, as opposed to maximum changes in parameter values as listed in Rev. 0. 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................6 

Executive Summary.........................................................................................................................9 

1.0 Introduction........................................................................................................................10 

1.1 Background............................................................................................................10 

1.2 Summary of STC Deliberations.............................................................................10 

2.0 Statement of Concern: Plausibility of Proposed Approach and Related Assumptions .....16 

3.0 Description of NIOSH Model for Tritide Dose Reconstruction........................................22 

4.0 Review of NIOSH Data and Assumptions.........................................................................25 

4.1 Review of Data Adequacy and Completeness.......................................................25 

4.1.1 Temporal Data Coverage ...........................................................................25 

4.1.2 Availability of Additional Data Sources....................................................30 

4.1.3 Dose Calculation Inconsistencies Identified in Spreadsheets....................33 

4.1.4 Brief Evaluation of Potential Transcription Errors....................................37 

4.1.5 Evaluation of Additional Data Compiled in NIOSH 2012 ........................38 

4.1.6 Concluding Statements on Data Adequacy and Completeness.................43 

4.2 Review of Detector Efficiency and Tritium Air Sample Filters for SMTs............43 

4.2.1 Evaluation of 4% Detector Efficiency .......................................................43 

4.2.2 Tritium Air Sample Filters for SMT..........................................................45 

4.3 Review of Resuspension Factor.............................................................................45 

4.4 Review of Dose Conversion Factors......................................................................51 

4.5 Review of Original Excel Spreadsheet ..................................................................55 

4.5.1 Sheet ‘CDE Summary’ ..............................................................................55 

4.5.2 Sheet ‘SRDB Search Summary’................................................................56 

4.5.3

.............56 

Sheets ‘R108 1985,’ ‘R108 1986,’ ‘R108 1988,’ ‘R108 1989,’ ‘SW8 

1985,’ ‘SW8 1986,’ ‘SW8 1987,’ ‘SW8 1988,’ and ‘SW8 1989’

5.0

.........................................................................................................................59 

Evaluation of Variables and Uncertainties Used on Mound Laboratory SMT Dose 

Estimations

5.1 Introduction............................................................................................................59 

5.2 SC&A’s evaluation of Parameters/Variables used in Estimating SMT Doses......59 

5.3

..........................................62 

SC&A’s evaluation of variability in the derived case study dose based on 

exposure duration and latency time after the exposure

5.4 Summary................................................................................................................65 

6.0 Comparison between NIOSH and DOE dose estimation methods for STCs ....................66 

6.1 ...................................................................................................................66 Purpose

6.2

.....................................................................................................66 

Comparison of DOE 2008 Insoluble Tritiated Particle Dose 

Characterization

6.3 Conclusion .............................................................................................................70 

7.0 References..........................................................................................................................71 

Attachment 1: Extrapolation of Intakes Assuming a Full Year Of Exposure...............................79 

Attachment 2: Description of Transcription Errors, Missed Data and Duplicate Entries ............87 

Attachment 3: Description of Data, Information, and Reports in the SRDB ...............................90 
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LIST OF TABLES 

Table 1. Swipe Data Availability for Room R-108 (1983–1989).............................................26 

Table 2. Swipe Data Availability for Room SW-8 (1969–1989) .............................................28 

Table 3. Available Health Physics Trend Data for Room SW-8 in 1980.................................31 

Table 4. Available 1986 HP Trend Data for Months with No Available Raw Data ................31 

Table 5. Available 1987 HP Trend Data for Months with No Available Raw Data ................32 

Table 6. Available 1988 HP Trend Data for Months with No Available Raw Data ................32 

Table 7. Available 1989 HP Trend Data for Months with No Available Raw Data ................33 

Table 8. Steps Used by NIOSH in Calculating Doses for 1972 ...............................................34 

Table 9. Values Reported by NIOSH in Annual Dose Calculation for 1983 ...........................35 

Table 10.

..........................................................................................36 

Original NIOSH Intakes Compared to Adjusted Intakes for a Full Year 

Exposure for Room R-108

Table 11.

..........................................................................................36 

Original NIOSH Intakes Compared to Adjusted Intakes for a Full Year 

Exposure for Room SW-8

Table 12.

..............................37 

Comparison of Limiting Organ CDEs Based on NIOSH Intake Estimates 

versus Intake Estimates Extrapolated to a Full Year of Exposure

Table 13. Overview of Transcription Error Analysis for the Years 1981–1984 ........................38 

Table 14.

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

Overview of Available Surface Contamination Swipe Results for Room SW-13 

by Year

Table 15.

..............................................................................................40 

Overview of Available Surface Contamination Swipe Results for 

Room SW-150 by Year

Table 16.

...................................................................................................42 

SC&A Corrected Potential SMT Doses to the Lung Based on NIOSH 2012 

Case Study Example

Table 17.

....................................43 

Ratio of SC&A Corrected Case Study Lung Doses shown in Table 16 to 

Original NIOSH 2012 Case Study Values shown in Figure 9

Table 18. Representative Reported Indoor Resuspension Data*................................................49 

Table 19. Target Organ Designations and Descriptions.............................................................52 

Table 20. Dose (rem) from 1 μCi Intake.....................................................................................53 

Table 21. Annual Dose Adjusted for the Number of Months with Swipe Data.........................56 

Table 22. Check of 95 Percentile Air Concentration................................................................57 th

Table 23. SMT Dose Parameters and Ranges.............................................................................61 

Table 24. Calculated Doses based on NIOSH Case Study for Room SW-150 ..........................62 

Table 25.

...............................................................................63 

Calculated Lung Dose (mrem) as a Function of Exposure Duration and 

Latency Time for Room SW-150

Table 26.

.............................................................................................................63 

Ratio of Remaining Target Organ Doses to NIOSH Base Case Values by 

Exposure Duration and Latency after Exposure based on 95 Percentile 

Contamination

th
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NOTICE:

Table 27.

.............................................................................................................64 

Ratio of Remaining Target Organ Doses to NIOSH Base Case Values by 

Exposure Duration and Latency after Exposure based on 50 Percentile 

Contamination

th

Table 28.

......................................................................67 

SAFe Various ITP Materials and Polydisperse (σg = 2.5) 

Particle Size Distributions (in AMAD)

Table 29.

......................................................................67 

SAFβ for Various ITP Materials and Polydisperse (σg = 2.5) 

Particle Size Distributions (in AMAD)

Table 30.

........................67 

Unadjusted Lung Committed Equivalent Dose DCFs (Sv/Bq) for Various ITPs 

and Particle Sizes (AMAD, σg = 2.5), Absorption Type S Assumed

Table 31.

..........................................................................................68 

Lung Committed Equivalent Dose DCFs (Sv/Bq) for Various ITPs and Particle 

Sizes (AMAD, σ = 2.5), Absorption Type S Assumed with 

SAFe Corrections Applied

g

LIST OF FIGURES 

Figure 1. R-108 Tritium Swipe Data for October 30, 1985.......................................................23 

Figure 2. SW-8 Tritium Swipe Data for November 6, 1985......................................................23 

Figure 3.

..............................................................................................................24 

Calculation of 95 Percentile Tritide Air Concentration for R-108, 

October 1985

th

Figure 4. Number of Samples by Period for Room R-108 (1983–1989)...................................26 

Figure 5. Number of Samples by Period for Room SW-8 (1969–1979) ...................................29 

Figure 6. Number of Samples by Period for Room SW-8 (1980–1989) ...................................30 

Figure 7.

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

Comparison of the Annual Average Surface Contamination versus the Monthly 

Weighted Average Annual Surface Contamination for Room SW-13

Figure 8.

.....................41 

Comparison of the Annual Average Surface Contamination versus the Monthly 

Weighted Average Annual Surface Contamination for Room SW-150

Figure 9. Recreation of NIOSH 2012 Table 1 ...........................................................................42 

Figure 10. PC-5 (cpm) vs. LSC (dpm) and 4% and 10% of LSC dpm Values............................44 
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ABBREVIATIONS AND ACRONYMS 

AI alveolar interstitial region 

AIDE Activity and Internal Dose Estimates 

ABRWH Advisory Board on Radiation and Worker Health 

AMAD Aerodynamic Median Activity Diameter 

Bq Becquerel 

BR breathing rate 

CAM Continuous Air Monitor 

CDE Committed Dose Equivalent 

CF conversion factor 

CFR Code of Federal Regulations

cm

2 square centimeter 

cpm counts per minute 

D&D Decontamination and Decommissioning 

DCF Dose Conversion Factor 

DNFSB Defense Nuclear Facility Safety Board 

DOE Department of Energy 

dpm disintegrations per minute 

DWL derived working limits 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

ER Evaluation Report 

ET extrathoracic region 

GI gastro-intestinal 

GM geometric mean 

GSD geometric standard deviation 

HP Health Physics 

Hr Hour 

HTO Tritiated water 

IAEA International Atomic Energy Agency 

IC Ionization Chamber 

ICRP International Commission on Radiation Protection 

IMBA Integrated Modules for Bioassay Analysis 
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IREP Interactive RadioEpidemiological Program 

ITP Insoluble Tritiated Particle 

keV kiloelectron volt 

LLI lower large intestine 

LN lymphatics and lymph nodes 

LS liquid scintillation 

LSC Liquid Scintillation Counter 

m meter 

m

2 square meter 

m3 cubic meter 

μCi microcurie 

μm micrometer 

ML Mound Laboratory 

MORE Mound Occupational Radiation Exposure Records 

MPC maximum permissible concentration 

mrem millirem 

NCRP National Council on Radiation Protection and Measurements 

NIOSH National Institute for Occupational Safety and Health 

NRC U.S. Nuclear Regulatory Commission 

ORAUT Oak Ridge Associated Universities Team 

OSTI Office of Scientific and Technical Information 

OTIB ORAUT Technical Information Bulletin 

PC proportional counter 

R Research Building 

rem roentgen equivalent man 

RF Resuspension Factor 

RSTC R/SW Tritium Complex 

SAF self-absorption factor 

SAFβ Self Absorption Factor, beta: fraction of betas emitted that escape the 

particle surface and are counted in the LSC system 

SAFe Self Absorption Factor, energy: fraction of energy available to impart 

 dose to the lung 

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

SEC Special Exposure Cohort 

SI small intestine 

SRDB Site Research Data Base 

SMT Stable Metal Tritide 

STC Special Tritium Compound 

STP stable tritiated particulate 

Sv Sievert 

SW Semi-Works Building 

TBD Technical Basis Document 

TH Thoracic 

ULI upper large intestine 

yr year 
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EXECUTIVE SUMMARY 

The origin of SC&A’s concern over dose reconstruction for special tritium compounds (STCs)1

at Mound is founded in their clear presence and exposure potential in certain Mound operations 

and the lack of site-specific personnel monitoring or source term characterization data for STCs 

upon which to base dose reconstruction. As in some other Special Exposure Cohort (SEC) 

reviews, NIOSH has proposed a model that substitutes a related radionuclide form, in this case 

tritium, to permit the use of swipe samples from STC operations where STC-containing tritium 

was processed to enable extraction. However, in this instance, SC&A is not only concerned that 

such a model is being proposed in the absence of site-specific or empirical STC data, but also 

because it is being used as a threshold to define a “theoretical” exposure potential, not as a means 

for dose reconstruction, and because it fails to consider the uncertainty ranges associated with the 

various assumptions employed in the model. This last issue is, of course, critical in any dose 

reconstruction under the Energy Employee Occupational Illness Compensation Program Act 

(EEOICPA), but even more so when the model would exclude a particular exposure source from 

being dose reconstructed. It appears that NIOSH is not offering the proposed dose 

reconstruction methodology as a coworker model, but as a means to demonstrate that exposure to 

STCs does not represent a source of radiological health endangerment. If this is, in fact, the 

argument that is being made by NIOSH, it represents an important policy decision that warrants 

explicit consideration by the Advisory Board. 

As such, the Advisory Board needs to view this proposed model in the context of a Board policy 

precedent that requires its judgment on (1) the acceptability of this de facto determination of de 

minimus dose as a threshold for whether dose reconstruction is conducted for exposures to 

Type S special tritium compounds at Mound; and (2) the use of a conceptual model to derive 

worker dose, where site-specific and empirical values for STCs are lacking, and for which a 

range of uncertainties exist for the modeling parameters that drive the end result. 

1 Special Tritium Compounds (STCs), Stable Metal Tritides (SMTs), Insoluble Tritiated Particles (ITPs), 

metal tritides, tritium compounds and tritides are used (and have been used) interchangeably for the same compound 

of interest defined as metal compounds, such as titanium and hafnium, that absorb and store tritium atoms in the 

crystalline structure of the metal.   
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1.0 INTRODUCTION 

1.1 BACKGROUND 

On October 14, 2011, the Mound Work Group and SC&A received by e-mail a set of files that 

describe the National Institute for Occupational Safety and Health’s (NIOSH’s) approach for 

assigning a plausible upper bound on the inhalation exposures of Mound workers exposed to 

Special Tritium Compounds (STCs). As discussed on numerous occasions, it is not feasible to 

reconstruct the internal doses to workers from the inhalation of metal tritides based on tritium 

bioassay data or tritium air sampling data, because the vast majority of tritium observed in either 

urine or in air samples is expected to be tritiated water, and it is not possible to determine what 

fraction of the historic dose may have been contributed by insoluble inhaled metal tritides. Our 

review of air sampling data also revealed that the air samples were prefiltered, which implies that 

the analysis of air samples for tritium excluded tritides. Inspection of the air sampling records 

was not able to uncover any data where the prefilters were analyzed for tritium. In theory, if 

such data existed, it could have been one means of estimating the airborne concentration of 

tritides. In practice, however, a quantitative analysis of tritium particulates based on air filter 

samples is very difficult, as discussed in Section 4.2.2 of this report. Finally, we have 

determined that it is inappropriate to assume that all the observed levels of tritium in urine and/or 

air samples are metal tritides, because such a condition would result in exposure conditions that 

are implausible and derived doses to the respiratory tract that are implausibly high. 

To address this challenging problem, NIOSH has developed a method for bounding internal dose 

associated with the intake of tritium particulate aerosols at the Mound Laboratory. Of particular 

interest are exposures to Type S insoluble STCs, such as hafnium tritide, that could deliver more 

dose per intake than other more soluble tritiated compounds. The NIOSH methodology takes 

advantage of the large amount of tritium swipe data that has been collected at Mound. The swipe 

data represent the amount of tritium contamination on surfaces, a portion of which can be 

assumed to be metal tritides. Given information on the amount of metal tritides on surfaces, the 

airborne concentration of metal tritides can be estimated by the use of a resuspension factor (RF). 

This white paper summarizes SC&A’s review of the data and assumptions and the inherent 

uncertainties of the values used to derive dose estimates that form the basis for the proposed 

methodology, and our concerns regarding its applicability for the stated purpose of bounding 

doses from intakes of STCs at the Mound laboratory. 

1.2 SUMMARY OF STC DELIBERATIONS 

The December 2007 Mound Special Exposure Cohort (SEC) Evaluation Report (ER) (NIOSH 

2007) observed that “limited information is available on the metal tritides to which workers 

could have been exposed,” and notes that a lung clearance class of “S” should be assumed for 

hafnium tritides and for all metal tritides other than lithium. In its initial SEC issues matrix, 

SC&A questioned the ability to bound tritium doses from STCs with the limited monitoring data 

for STCs available in Mound records. Likewise, SC&A cited Sullivan (1996), in his letter to the 

Department of Energy (DOE), which indicated a technology shortfall in the monitoring, 

characterization, and dose assignment from partially soluble and highly insoluble tritium 

compounds, particularly as it pertains to reliance on air monitoring and contamination swiping. 
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While STCs were long known to Mound researchers and operators, their dosimetric properties 

were less understood and not recognized for their significance until the 1990s, when the advent 

of extensive decontamination and decommissioning activities at Mound elevated attention within 

the operating contractor and DOE, and led to specific control and monitoring requirements. 

SC&A also questioned whether existing metabolic models applicable to tritides, such as those 

provided in ORAUT-OTIB-0066 (ORAUT 2007) and ORAUT-OTIB-0011 (ORAUT 2004), 

could adequately address this issue in the absence of Mound-specific parameters, such as the 

identity of compounds and their respective solubilities, potential exposure locations, workers 

affected, and time periods. 

NIOSH responded to SC&A’s issues by indicating that hafnium tritide was the STC compound 

that exhibited the bounding insolubility and (after some iterative deliberation with the work 

group and SC&A) represented an exposure potential at Mound; that all others identified were 

either of greater solubility (i.e., of “intermediate” solubility) or had negligible exposure 

significance. After conducting its own interviews, NIOSH concluded in its October 2009 

response paper that the historic exposure potential for hafnium tritide was limited to a “very 

small, discrete group of workers (10 individuals) known to NIOSH...by name” (NIOSH 2009). 

The NIOSH response discussed how a bounding dose estimation model is available in OTIB0066, and that abundant site-specific monitoring data are available from extensive tritium 

bioassay records. It further noted that site-specific parameters cited by SC&A are either not 

relevant or represented site profile issues, except for the location where hafnium tritide was 

handled, which was indicated as being known to NIOSH. NIOSH also acknowledged that it “has 

proposed to consider exposure to intermediate solubility class tritium compounds for any Mound 

worker on the tritium bioassay program.”2

SC&A expressed concern as to whether all workers in all operations involving hafnium tritide 

could be accounted for at Mound, which if not the case, would undercut NIOSH’s premise for its 

proposed dose reconstruction approach for hafnium tritide. Subsequently, both SC&A and 

NIOSH personnel made a series of onsite visits to the Office of Scientific and Technical 

Information (OSTI) records archives at Oak Ridge to conduct document searches related to 

hafnium tritide activities at Mound. These reviews suggested to SC&A that the actual nature of 

activities at Mound would make the compilation of a complete and accurate roster of potentially 

exposed Mound workers for hafnium tritide infeasible, and that potential worker exposure to 

hafnium tritide, while probably small relative to tritium, could not be ruled out and likely 

occurred at some exposure level. 

NIOSH continues to believe it can identify those workers who had an exposure potential to 

hafnium tritide and that, in their opinion, the exposure potential for hafnium tritide was very low, 

although “not zero,” based on interviews with key former tritium operators (Ulsh 2010). 

However, SC&A believes such an approach falls short for the following reasons, based on the 

same interviews: 

2

 SC&A agrees with NIOSH regarding the extensive nature of operations with intermediate soluble tritides 

as compared with hafnium tritide; the status of NIOSH’s proposal to assign additional dose commensurate with 

potential exposure to these intermediate soluble tritides is not clear.
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(1) NIOSH did not consider support worker categories (e.g., technicians, maintenance, crafts, 

housekeeping, etc.), as well as decontamination and decommissioning (D&D) personnel, 

all of whom had some degree of exposure potential and for whom the compilation of an 

accurate roster would be unlikely at this point, because such workers were drawn from 

facility-wide, if not plant-wide, support functions or were of temporary work status. 

(2) Mound handled STCs from other DOE facilities, which may have introduced highly 

insoluble compounds that had comparable exposure pathways. 

(3) The frequency of tritium Continuous Air Monitor (CAM) alarms in hafnium tritide 

handling areas confirms that the integrity of gloveboxes was breached frequently enough 

to provide an exposure pathway to the workers who frequented these handling areas. 

On June 30, 2009, and again, on April 7, 2010, secure meetings were held at DOE Germantown 

for NIOSH, work group members, and SC&A to discuss site-specific circumstances and 

information regarding the preceding issues. Based on this information, at its July 27, 2010, 

meeting, the work group considered forwarding the tritides issue to the full Advisory Board for 

consideration, but held off pending additional research by NIOSH regarding the feasibility of 

using tritium swipe data for dose reconstruction purposes for support workers in the period 1980 

forward (including the D&D phase). Another key aspect of that review was to be whether those 

workers with exposure potential could be identified. Portions of what would become a formal 

NIOSH white paper on this subject were provided to the work group and SC&A on October 14, 

2011 (these advance “pieces” of the review consisted of informal drafts of a summary of 

“Resuspension of Tritide Surface Contamination at Mound,” [untitled] SMT Exposures in R-108 

and SW-8 in the 1980s, and “PC-5 Gas Proportional Counter Tritium Counting Efficiency 

Discussions”), in advance of the work group’s November 7, 2011, meeting. 

In the e-mail forwarding this advance material, NIOSH emphasized that “it has been, and 

continues to be NIOSH’s position that exposure to the most insoluble of these compounds was 

limited to a special cohort of workers, identified by name.” In forwarding the preceding material 

pertinent to the use of swipe data available for the relevant locations and time periods at Mound, 

NIOSH notes that the “take home message” is that by applying “multiple extremely conservative 

assumptions,”3

 the calculated doses are extremely small (“order of a few millirem”) and that 

NIOSH’s position is therefore supported: “that the exposure potential for these materials for 

anybody other than the named group of workers is extremely low.” 

At the November 7, 2011, work group meeting, NIOSH made it clear that it is “not proposing 

this [model] as necessarily a dose reconstruction methodology;” that “even under worst-case 

3

.Defined as: 

1. A detector efficiency of 4%. 

2. Assuming that all tritium activity on the swipes is from insoluble SMTs, even though these materials 

composed a very small fraction of the tritium Mound worked with. In addition, with the exception of 

accident scenarios, these materials were always handled inside containment designed to isolate tritium 

gas (which is more mobile than particulate tritium). 

3. All swipe results were treated as if they were Type S solubility metal tritides, even though the very large 

majority of the small inventory of SMTs Mound handled over its history were Type M. 

4. A conservative value for a resuspension factor. 

5. 95th percentile air concentrations and 95th percentile organ doses are reported 
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assumptions it doesn’t give you a dose which is not (sic) sufficiently accurate.”4 NIOSH claims 

that [tritides] is not an SEC issue, because its conservative smear-based model analysis shows 

that the resulting dose is “small” or “extremely low,” and that the model applied is both 

“plausible” and “bounding.” It was emphasized by NIOSH that this approach is no different than 

substituting the most insoluble form of a particular radionuclide to achieve a bounding dose 

estimation, e.g., substituting Type S uranium or Super Type S plutonium for their higher 

solubility forms. NIOSH considers tritides an insoluble, bonded compound of hydrogen, 

fluoride, and oxygen, and substituting the most insoluble form is viewed as simply adopting a 

“claimant-favorable” assumption for dose reconstruction. 

In January 2012, NIOSH released its December 20, 2011, draft white paper (NIOSH 2011a), 

which as indicated earlier, consisted of the advance analyses that were provided to the work 

group in October 2011. In the paper’s executive summary, NIOSH notes that: 

The dose method presented here makes use of the contamination swipe data to 

estimate the SMT concentration resulting from the aerodynamic entrapment 

and/or mechanical resuspension of surface contamination for estimating the 

inhalation dose...more than 62,000 swipe data entries for Rooms R-108 and SW-8 

collectively were used in the assessment. The maximum annual CDE associated 

with intakes of the SMT is 226 mrem to the critical organ...” 

The paper further indicates that the review focused on “tritium research, development, analytical 

recovery, enrichment, and surveillance activities” in the Research (R) and Semi-Works (SW) 

buildings at Mound, specifically rooms R-108 and SW-8, with operations starting “in the 1960s 

in these rooms and [continuing] beyond the 1980s.” In its analysis, NIOSH notes that it is 

presenting “an alternative method of more precisely bounding doses for workers who had a 

theoretical potential for exposure to SMTs at the Mound Laboratory.” That “this is 

accomplished by applying a resuspension factor defined as the ratio between the airborne 

concentration of a pollutant per cubic meter directly over a contaminated surface and the areal 

pollutant surface contamination.” NIOSH further notes that “the outcomes of this dose 

assessment provide ceiling values for potential SMT exposures at the Mound Laboratory during 

the 1960s through the 1980s.” 

At a secure meeting at DOE Germantown on January 6, 2012, individuals from NIOSH, the 

work group, and SC&A, clarified facility-specific technical issues associated with this recent 

white paper and the new proposal. SC&A raised a concern over how this approach would 

address the D&D phase at Mound, where engineered controls for residual tritides would have 

been lacking and a wholly different population of support workers would have been involved. 

SC&A also raised questions regarding how radiological self-absorption within tritide compounds 

4

 SC&A agrees with this position, in that there are inherent uncertainties associated with inferring surface 

contamination from swipe counts, which are subject to a host of variables, such as assumed removal factor (affected 

by chemical form of tritium and how it is absorbed on a particular surface), area swiped (function of individual 

sampling technique), instrument efficiency, self-absorption of contaminant (proven for tritide compounds), and other 

factors. The collective contributions of these uncertainties cannot be specified with “sufficient accuracy,” albeit 

they can be conservatively bounded or “maximized,” as has been proposed by NIOSH in its approach. 
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would be addressed, as well as the implications of a 2008 Sandia study (Coffey and Burkhart 

2008), which found a delayed count response phenomenon for liquid scintillation counting of 

erbium tritide. Finally, a need was expressed by the work group to reconfirm identifiable 

operators and support staff for all hafnium tritide activities for which an exposure potential is 

identified, whether small or large. 

SC&A also received from NIOSH additional tritium swipe sample data recently found for the 

two rooms in question. These additional datasets, contained in two spreadsheets compiled by 

NIOSH (‘SMT exposures in R-108 SW-8 10-6 pre 1980.xls’ and ‘SMT exposures in R-108 SW8 10-6 in 1980s.xls’), provide supplemental data in the form of health physics daily summary 

values for time periods prior to 1985. SC&A reviewed these data for completeness and found 

that gaps occur for the R-108 room from January 1983 to May 1983, July 1986 to June 1988, and 

January 1989 to June 1989. No data were compiled for 1987, and the only year with an intake 

defined for each month was 1985. For the SW-8 room, the following gaps in the available swipe 

data were observed: 

 September 1969 

 December 1969 through September 1972 

 December 1972 through June 1975 

 September 1975 through May 1976 

 August 1977 through December 1977 

 All of 1980 

 March 1986 

 July 1986 through December 1986 

 September 1987 through December 1987 

 July 1988 through December 1988 

 July 1989 through December 1989 

On April 4, 2012, NIOSH released a new white paper (NIOSH 2012), dated March 30, 2012, 

which presented the “bounding and best estimate internal dose associated with the intake of 

insoluble tritium particulate aerosols in the R/SW Tritium Complex (RSTC) at the Mound 

Laboratory.” This new white paper analyzed additional swipe sample data for the rooms SW-13 

(covering 1974 through 1989) and SW-150 (covering 1968 through 1989). Unlike the results 

presented in the preceding white paper, NIOSH estimated the “accumulated dose...for a Case 

Study that can typically be found in the dose reconstruction program...with “the bounding and 

best estimate annual dose equivalents to the lung associated with intakes of the SMT are 

0.48 mrem and 0.12 mrem, respectively.” As in the prior white paper, NIOSH concludes that 

their assessment “demonstrates that calculated exposures from the inhalation of insoluble metal 

tritides at Mound were small (in the millirem range), plausible, and bounding.” Based on this 

analysis, NIOSH concludes that “the worker protection practices and health physics program 

used at Mound for protection against insoluble tritides, and the processes in which they were 

encountered, indicates that the SMTs did not present any internal dose to workers, theoretically 

and physically” (NIOSH 2012). This paper also provided an assessment of exposure potential 

from D&D activities as gleaned from interviews with three former Mound workers. 
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The Mound Work Group met on April 10, 2012, and discussed both NIOSH white papers, in 

terms of the adequacy and completeness of the swipe data, the key assumptions and parameters 

contained in the proposed dose estimation models, and the implications of applying such a model 

as a threshold means to determine the exposure potential for SMTs at Mound. While SC&A had 

prepared a detailed response to the December 2011 white paper, that response was withheld 

while additional review was performed for the white paper issued on March 30, 2012, and 

received on April 4, 2012. The following assessment constitutes this augmented review, albeit 

limited time prior to the next work group meeting (scheduled for June 5, 2012) did not permit 

adequate follow-up regarding NIOSH’s recent findings for the exposure potential of SMTs in 

D&D activities at Mound. 

This report is organized, as follows: 

Section 2.0 of this report highlights concerns regarding the plausibility of the proposed approach 

and its related assumptions, and its use as a threshold basis for determining the exposure 

potential of SMTs at Mound. 

Section 3.0 describes the NIOSH model for SMT dose reconstruction, contrasting the differing 

assumptions and parameters applied in the most recent “best-estimate” bounding model, with the 

earlier “extreme” bounding model. 

Section 4.0 reviews the adequacy and completeness of the swipe data used in these models, as 

well as the assumptions made by NIOSH in applying its model to this data. SC&A believes that 

the data are essentially complete and adequate, provided a suitable rationale can be developed to 

bridge missing data by extrapolating from other onsite data collected for adjacent time periods. 

Section 5.0 provides an evaluation of the inherent uncertainties associated with the variables 

found in the NIOSH dose estimations calculated for SMTs at Mound Laboratory, offering a 

perspective on the “sensitivity” of the end result as a function of what value is assigned to critical 

model parameters. Included is a review of the variability in the derived doses that arises by varying 

the exposure duration and latency time after an exposure.

Section 6.0 provides a comparison between the NIOSH method to evaluate lung dose, as 

presented in its most recent white paper (NIOSH 2012), and a DOE method provided in their 

2008 report, DOE Handbook – Tritium Handling and Safe Storage (DOE 2008). Again, the 

focus is on rationalizing any differences found between the respective methodologies and 

quantifying variability associated with the assumptions used. 

Three appendices are included that provide an extrapolation of intakes assuming a full year of 

SMT exposure, as well as background regarding available documents in the Site Research Data 

Base (SRDB) and factual or transcription errors found by SC&A during its review. 
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d 

2.0 STATEMENT OF CONCERN: PLAUSIBILITY OF PROPOSED 

APPROACH AND RELATED ASSUMPTIONS 

The origin of SC&A’s concern over dose reconstruction for STCs at Mound is founded in their 

clear presence in certain Mound operations, and the lack of site-specific personnel monitoring or 

source term characterization data upon which to base dose reconstruction. As in some other SEC 

reviews, NIOSH has proposed a model that substitutes a related radionuclide form, in this case 

tritium, to permit the use of swipe samples from STC operations where STC-containing tritium 

was processed to enable extraction. However, in this instance, SC&A is not only concerned that 

such a model is being proposed in the absence of site-specific or empirical STC data, but also 

because it is being used as a threshold to define exposure potential, not as a means for dose 

reconstruction, and because it fails to consider the uncertainty ranges associated with the various 

assumptions employed in the model. This last issue is, of course, critical in any dose 

reconstruction under EEOICPA, but even more so when the model would exclude a particular 

exposure source from being dose reconstructed. 

As will be confirmed later in this report, the assumptions cited by NIOSH in its proposed 

approach are reasonable, based on the scientific literature, and within the range of plausible 

values that could be assigned for the exposure scenario outlined (albeit with attendant 

uncertainties, an issue pertinent to the application of this model for this purpose). The detector 

efficiency assumption is at the lower range of reported values, but is certainly a conservative 

assumption. Based on SC&A’s review of the literature, it is apparent that the variability and 

uncertainty in resuspension factors is enormous, but that a resuspension factor of 5E-5/m, as used 

by NIOSH, is claimant favorable and within the range of values reported. The 95th percentile air 

concentrations and 95th percentile organ doses are conservative approaches that have been 

employed previously by NIOSH in dose reconstruction. 

Taken in isolation, this model would seem to offer a simplifying means to bound levels of tritide 

activity that may have been present in the workplace.5

 However, as broached at the November 

7, 2011, work group meeting, SC&A has reservations regarding the plausibility of a propose

model that relies on workplace tritium contamination swipes and hypothesizes that all the tritium 

activity on these swipes be from insoluble SMTs in order to derive a maximum annual dose 

level. This approach does not provide an upper bound for dose reconstruction purposes, but a 

“theoretical” lower threshold for exposure potential where such potential has been already 

established by the work group in former worker interviews. Likewise, at the April 10, 2012, 

work group meeting, SC&A emphasized that with the lack of site-specific or other empirical 

bases, the inherent uncertainties associated with each of the assumptions employed in NIOSH’s 

model require consideration, given their compounding influence on any dose estimate. 

For context, it needs to be re-emphasized that for hafnium tritides (and other STCs), there were 

no bioassays conducted and no workplace monitoring performed; there were no measurements of 

relative concentrations of tritides to HTO, and no reliable means to ascertain same from the 

contamination swipes taken. And it is clear that it would not be plausible for all of the HTO 

 5

 While STCs were, indeed, routinely handled in containment, they were also intermittently released into 

the workplace via glovebox leaks, which were relatively common at Mound and other tritium operations of that era.
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measured on the swipes to consist of tritides. In response to this and other concerns, NIOSH 

responded (during the November 2011 work group meeting) that they would be in agreement 

with SC&A’s concern if the resulting calculated doses were “extremely high values,” i.e., “tens 

of rems, hundreds of rems, thousands of rems” (ABRWH 2011). It was further noted that the 

smears provide a source term that, “under some very conservative assumptions” can generate 

relatively low doses in the mrem range. NIOSH elaborated further that “there are oftentimes 

good reasons why people aren’t monitored for bioassay, and it has to do with the source term 

that’s available.” NIOSH further observed that it approached bounding assumptions like this “all 

the time” and offered the example of how Type S or Type Super S uranium or plutonium have 

been assumed to provide for a conservative bounding estimation of dose when solubility 

uncertainties arose. It was observed that tritides are like a more insoluble compound of 

hydrogen; that there is no distinction between them and how solubility has been addressed in the 

past. 

The illustrative example that was offered by NIOSH was how high-fired plutonium was handled 

during the Rocky Flats SEC review. First, it needs to be recalled that the Mound “maximizing” 

method proposed at the November 2011 meeting (as well as the “best-estimate” method 

proposed at the April 2012 meeting) was not being offered by NIOSH as a dose reconstruction 

method, but rather as a means to determine whether exposure potential would have been “very 

small” or in the context of the EEOICPA, “negligible,” or not for the support workers involved. 

However, SC&A believes that this comparison, i.e., Rocky Flats high-fired plutonium to Mound 

tritides, while analogous on one hand because they both address insoluble compounds, is also 

dissimilar because of fundamental differences in how they are supported by actual site 

monitoring data. It is noteworthy that the upper-bound assumption for high-fired plutonium 

(factor of 4 dose estimation over Type S Pu-239) was grounded in the Transuranium Dose 

Registry autopsy data from which the assumed parameter was derived, as well as the 

considerable plutonium monitoring data derived from a rigorous and routine bioassay program at 

Rocky Flats for all workers, both operators and support personnel. In contrast, given the 

complete lack of tritide bioassay, workplace monitoring data, or a measure of the relative 

concentrations of tritides to HTO, the proposed approach for tritides at Mound must rely on 

contamination swipes of workplace surfaces, for which the representativeness for all workers 

with exposure potential is questionable. When NIOSH assumed all of the plutonium at Rocky 

Flats was high-fired for purposes of an upper-bound dose reconstruction [under ORAUT-OTIB0049 (ORAUT 2010)], it was with the knowledge that this approach would be plausible and 
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sufficiently accurate, as validated by autopsy data, and founded on this extensive bioassay 

monitoring data.6

While the assumption that all of the tritium activity picked up on the swipe is from insoluble 

SMTs is extremely conservative and not plausible in the normal sense of the word, it was 

clarified (see above) that this assumption is being used solely to “maximize” or “bound” the 

“theoretical” potential exposure attributable to tritides, and not dose reconstruct with sufficient 

accuracy, with the objective to determine if the resulting dose would be significant7 under that 

conservative scenario. However, whether it is the “extreme” bounding organ dose of 226 mrem 

CDE to the LN(TH) or the “best-estimate” bounding dose of 0.48 mrem to the lung, NIOSH 

considers the “calculated exposures from the inhalation of insoluble metal tritides at Mound to be 

“small” and “in the millirem range.” 

From NIOSH’s modeling, though, it is not clear what is ultimately limiting, bounding, or just a 

best estimate. In its March 2012 white paper, NIOSH shows the limiting lung dose as 0.48 mrem 

(95th percentile) and 0.12 mrem (50th percentile), assuming a 2-year exposure and 10-year 

latency period. However, applying NIOSH’s case study method, the limiting dose should be 

92.9 mrem to the “Al” (95th percentile) and 23.8 mrem to the “Al” (50th percentile). If a longer 

latency time than 10 years is assumed, the LN(TH) then becomes the limiting organ. For 

example, if the 50-year CDE is calculated based on a single year exposure to the highest annual 

intake, the limiting dose would be 85.1 mrem to the LN(TH) at the 95th percentile and 21.5 mrem 

to the LN(TH) at the 50th percentile. 

In providing this methodology, NIOSH does not a priori acknowledge any potential exposure to 

these individuals, and therefore, is not proposing to demonstrate dose reconstructability “with 

sufficient accuracy.” In fact, as noted earlier, NIOSH commented during the November 7, 2011, 

work group discussions that even under the worst-case assumptions used in the model, it does 

not afford a dose estimate with sufficient accuracy; it is merely an upper-bound dose parameter 

for determining whether support workers should be excluded from consideration for exposure 

potential to insoluble tritides. 

 6

 For Rocky Flats, NIOSH acknowledged that high-fired plutonium oxide (Pu-239) may exhibit long-term 

retention in the lung exceeding that predicted by the default Type S model represented in conventional retention 

models. NIOSH addressed this issue in ORAUT-OTIB-0049 (ORAUT 2010), where lung dose adjustment factors 

were empirically derived from in-vivo bioassay results and from urine results, as well as adjustment factors for 

systemic organs, gastro-intestinal (GI) tract and the extra-thoracic (ET) region. Specific design cases were the basis 

for determining the more bounding adjustment factors. Finally, autopsy cases were used by NIOSH to validate the 

conservatism of these empirically based assumptions. While an analogy was drawn at the November 7th Mound 

work group meeting between this empirical approach for high-fired plutonium at Rocky Flats and the “maximizing” 

approach proposed for STCs at Mound, what is analogous is that “bounding” for “solubility” is being modeled, not 

the premise and supporting data or analyses behind it. While the OTIB-0049 model is based on both site-specific 

bioassay and lung count data, as validated by autopsy measurements, the “swipe” approach does not model or 

estimate tritide dose from any site-specific characterization information for tritides; it merely projects a hypothetical 

dose based on a “substitute” source-term, HTO, for which monitoring data are available. 7

 It is unclear how “significance” is defined by NIOSH for exposure potential suitable for dose 

reconstruction; while NIOSH observed (as noted) that it would share SC&A’s concerns over STCs if they resulted in 

“extremely high” doses from conservative calculations, NIOSH staff also acknowledged at the March 2012 work 

group meeting that 1 mrem has been used as a de facto threshold for dose reconstruction consideration in the past.
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NIOSH’s suggestion at the same meeting that “there are often times good reasons why people 

aren’t monitored for bioassay, and it has to do with the source term that’s available,” does not 

comport with the operational history of tritide handling at Mound and other DOE sites. STCs 

have had a long history of applications across the DOE complex, particularly at Mound. 

However, DOE and its contractors did not fully appreciate its dosimetric and radiological control 

implications until the 1990s (during terminal D&D operations at Mound and other sites), and did 

not issue revised guidelines for monitoring and control until 2004 (DOE 2004). This very 

insoluble form of tritide was not previously addressed under a bioassay regime, because its 

radiological concerns were underappreciated, and available monitoring techniques were either 

not applied effectively or did not exist at the time. There is no evidence that suggests, as NIOSH 

does, that the insoluble form of tritides was not considered a significant exposure pathway or one 

for which any worker potentially exposed did not warrant bioassay; it merely was not recognized 

then as the dosimetric concern that it would become later. In fact, tritides were the subject of 

Defense Nuclear Facility Safety Board (DNSFB) review and correspondence to DOE (DNFSB 

1999), a DOE-wide review (DOE 1999), and resulted in the issuance of its own technical basis 

document (TBD), both at Mound (Mound 2000) and on a DOE-wide level (DOE 2004). 

For Mound, it is assumed that the swiping of surfaces in the four rooms in question represented 

the extent of HTO contamination, and that the tritide particulates would behave similarly to HTO 

upon release and be present on surfaces subject to routine swiping. However, support activities 

involve changing out room air filters, glovebox maintenance, and housekeeping, all of which 

entailed exposure pathways not likely represented by the surface swiping regime involved, and 

for which historic respiratory protection practice is not firmly established. NIOSH has not 

determined the representativeness of the swiping surveys to levels of HTO and tritide 

contamination to which support workers may have been exposed in these types of activities, and 

whether they represented upper bounds for what was likely more direct contact with 

contaminated surfaces and equipment. 

For Mound support workers that had access to the four rooms in question, there has not been any 

new information presented to the work group that they were not exposed to insoluble tritides. As 

noted earlier, work group members participated in secure meetings wherein that question was 

settled to their satisfaction: Mound support service workers had potential exposure to hafnium 

tritides in the course of their work during both operating and D&D periods,8

 and have not been 

identified, by name, to date. Given the lack of bioassay and air monitoring data and suitable 

source term characterization data, the work group has deemed the dose reconstructability of 

support worker exposures to hafnium tritide to be a legitimate SEC issue requiring a 

demonstration by NIOSH of plausible dose reconstructability with sufficient accuracy. The 

proposed bounding methods provided have not been directed at providing that demonstration, 

but rather as a means to illustrate through a model that this exposure pathway leads to 

theoretically “small” doses, thereby making dose reconstruction not. 

 8

 In its most recent white paper, “Potential Stable Metal Tritide Exposures at the Mound Laboratory,” 

(NIOSH 2012), NIOSH provides interview summaries for three former Mound workers it re-interviewed regarding 

potential D&D exposures to STCs, with a conclusion that such exposure did not take place. SC&A has not had 

sufficient time to conduct follow-up research regarding these accounts. 
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With respect to the “extreme case” model presented by NIOSH, it is not clear why NIOSH 

considers 226 (corrected to 1,532) mrem/year CDE to the critical organ (the maximum swipebased estimate) to construe anything other than a legitimate exposure potential requiring dose 

reconstruction. As a point of comparison, such annual internal dose levels are comparable (order 

of magnitude) to those likely to have been accrued by workers exposed to depleted uranium in 

Pantex disassembly, mixed activation products in the early years at Los Alamos, and U-238 dust 

at early steel rolling mills, all of which received SEC consideration by NIOSH and the Board. 

Likewise, they are not inconsistent with the low doses experienced from medical x-rays and 

occupational environmental radiation sources, which are routinely considered in claimant dose 

reconstructions. As past Board practice has been to only exclude “negligible” radiation 

exposures from SEC consideration, this level of potential exposure would certainly not fit this 

definition of negligibility. 

In its subsequent “best-estimate” model, however, NIOSH revised its model parameters to be 

more “realistic” and has reduced the resulting “upper-bound” target organ dose estimates by over 

an order of magnitude as a function of the target organ and latency period selected.9

 While this 

calculated dose value was deemed by NIOSH to also be “small,” as in the “extreme” case, it has 

also apparently fallen below NIOSH’s de facto threshold for an exposure potential subject to 

dose reconstruction (1 mrem) and would now, in effect, be considered de minimus.

10 As 

discussed at the April 2012 work group meeting, NIOSH observed that the basis for 1 mrem 

threshold is thought to be a limitation in the Interactive RadioEpidemiological Program (IREP) 

dose estimation model that restricts input exposure parameters to 1 mrem. Subsequent 

discussions with SC&A personnel involved directly in dose reconstruction reviews, however, 

indicate that radionuclide-specific input values of less than 1 mrem are actually common and 

apparently can be accomplished by IREP. It is not clear from any of these exchanges what the 

technical basis is for a 1 mrem dose threshold for dose reconstruction consideration by NIOSH 

under the EEOICPA and how that threshold is or should be applied for dose reconstructions to 

ensure claimant favorability. 

Beyond concern over NIOSH’s basis for defining a de minimus exposure potential for dose 

reconstruction, SC&A also finds that NIOSH has not adequately considered the uncertainties 

incumbent for a model that lacks either a site-specific or empirical basis for its assumptions. As 

discussed at the April 2012 work group meeting, each of these assumed parameters—for 

example the resuspension factor, dose conversion factor, swiping and counting efficiencies, selfabsorption correction factor, exposure duration, and latency time after the exposure—introduce a 

range of uncertainties to the modeling calculation that would be compounding and can lead to a 

wide range of dose estimation results as a function of relative conservatism. In fact, NIOSH 

itself has demonstrated this circumstance by its presentation of both an “extreme” bounding case 

and a “best-estimate” bounding case for its estimate of exposures to STCs at Mound, based on 

9

 Corrected limiting dose from NIOSH 2011b: 1,532 mrem 50-year CDE to the LN(TH). Corrected 

limiting dose from NIOSH 2012 using the case study approach (2-year exposure, 10-year latency) is 92.9 mrem to 

the AI, based on the 95th percentile contamination values. 10 Although it should be noted that SC&A has found that the corrected limiting lung dose based on the 

NIOSH 2012 case study is 3.73 mrem at the 95th percentile level of contamination (as compared with the stated 

0.48 mrem).
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NOTICE:

use of correspondingly very conservative (“extreme”) or less conservative (“best-estimate”) 

numerical assumptions. 

To illustrate the range of uncertainties attendant to these modeling assumptions, SC&A has 

provided analyses in Sections 5.0 and 6.0, based on the scientific literature, that address the 

variability of parameters used in the most recent NIOSH model, as well as contrasting these 

same variables between that model and one provided by DOE in its Tritium Handling and Safe 

Storage handbook (DOE 2008). As can be seen by the results in these two sections, the total 

range of uncertainty based on the extreme high and low values of assumed modeling parameters 

would be a factor of 0.0003 to 8,112 than that of NIOSH’s resulting dose estimate from its 

March 2012 paper, and more significantly (see SC&A discussion in Section 4.3), a factor of 0.02 

to 135 than that of the same result, assuming a constant resuspension factor (RF = 5E-5/m), as 

proposed in that paper.11 Likewise, the self-absorption factor (“SAFe”) derived by NIOSH 

yields lower doses to the lung for STC than the method presented in the DOE handbook (DOE 

2008) by a factor of approximately 0.45. 

Essentially, NIOSH is proposing a new analytic model (use of HTO swipe data) to bridge a wide 

data gap at Mound (lack of hafnium tritide monitoring and source term characterization data), 

not as a means of conducting bounding dose estimation or reconstruction, but as a means to 

define a level of “theoretical” worker tritide exposure that can be considered insignificant or 

equivalent to “negligible.” In this context, NIOSH is not offering the proposed dose estimation 

methodology as a coworker model, but as a means to demonstrate that exposure to STCs does 

not represent a source of radiological health endangerment. If this is, in fact, the argument that is 

being made by NIOSH, it represents an important policy decision that warrants explicit 

consideration by the Advisory Board. 

As such, the Advisory Board needs to view this proposed model in the context of a Board 

policy precedent that requires its judgment on (1) the acceptability of this de facto

determination of de minimus dose as a threshold for whether dose reconstruction is 

conducted for exposures to hafnium tritide at Mound, and (2) the use of a conceptual model 

for which site-specific and empirical values for STCs are lacking, and for which a wide 

range of uncertainties exist for the modeling parameters that drive the end-result. 

11 In this latter case, SC&A acknowledges that, while conservative and clearly bounding, NIOSH’s use of 

an RF of 3E-5/m in its earlier “extreme” model estimate is beyond what the literature and NRC have recommended. 

However, as pointed out later by SC&A in Section 4.3, an argument can be made that even the 5E-5/m value should 

be 2.5E-4/m, a factor of 5 higher to account for the fact that the starting point for this calculation is swipe data and 

not total surface contamination. 
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3.0 DESCRIPTION OF NIOSH MODEL FOR TRITIDE DOSE 

RECONSTRUCTION 

NIOSH 2011a proposes a model that calculates the airborne radionuclide concentration in a 

room or area based on the measured surface contamination within that room or area. 

Mathematically, the NIOSH model is: 

C = (3-1) 

Where: C = Tritide air concentration (μCi/m3) 

M = Tritium measurement (cpm/100 cm2) 

100 = Area of measurement (cm2) 

em = Detector efficiency (unitless) 

= 0.01 

k = Conversion factor (dpm/μCi) 

= 2.22×106

 (dpm/μCi) 

RF = Resuspension factor (m-1) 

= 0.00005 (m-1) 

NIOSH 2012 applies “best-estimate” parameter values of 0.01 for detector efficiency and a 

resuspension factor of 5E-5 m-1, as discussed in detail in later sections of this report. The 

derivation and appropriateness of the detector efficiency and the resuspension factor in NIOSH 

2011a are described in detail in Sections 3.3 and 3.4, respectively. The disintegration per minute 

(dpm) to microcurie conversion factor needs no discussion, which leaves the tritium 

measurement as the only parameter in equation 3-1 that needs further explanation. A brief 

explanation is provided below of the tritium measurements used and the data that were used 

specifically to calculate the 50th and 95th percentile tritide air concentrations. (NIOSH 2012 

presents both 50th and 95th percentile air concentrations). Figures 1 and 2 were taken from the 

Mound SW Building contamination survey datasheets (Connell 2010a) and show contamination 

in room R-108 on October 30, 1985, and in room SW-8 on November 6, 1985. Section 3.1 

presents a detailed review of the completeness and appropriateness of the Mound contamination 

survey datasheets as they relate to the tritide problem. 
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Figure 1. R-108 Tritium Swipe Data for October 30, 1985 

Figure 2. SW-8 Tritium Swipe Data for November 6, 1985 

To arrive at the 95th percentile air concentration, an air concentration was calculated for each 

swipe data point. For example, from the Figure 1 datasheet, 15 swipe data were collected and 15 

air concentrations were calculated for room R-108. For the total month of October 1985, 357 

swipe data were collected and 357 air concentrations were calculated for room R-108. To 
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s 

calculate the 95th percentile room R-108 air concentration for October 1985, the natural 

logarithms of those 357 air concentrations were plotted against their calculated z-scores a

shown in Figure 3. 

Figure 3. Calculation of 95th Percentile Tritide Air Concentration for R-108, 

 I = 

October 1985 

(3-2) 

Where: Monthly tritide intake (μCi/month) 

C n (μCi/m3) 

B

O factor (hr/month) 

nce the monthly tritide intake has been calculated, it is a simple matter to calculate dose, as 

 D = 

I = 

= 95th percentile tritide air concentratio

R = Breathing rate (m3

/hr) 

= 1.2 (m3/hr) 

c = Occupancy 

= 167 (hr/month) 

O

shown by the following equation: 

(3-3) 

Where: D = Annual tritide dose (mrem) 

DC r (rem/μCi) 

i/month) 

F = Tritide inhalation dose facto

1000 = Conversion factor (mrem/rem) 

Im = Tritide intake for month, m (μC

NOTICE:
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4.0 REVIEW OF NIOSH DATA AND ASSUMPTIONS 

4.1 REVIEW OF DATA ADEQUACY AND COMPLETENESS 

This section presents a comprehensive review of the completeness of the available swipe data 

proposed for use in bounding potential exposures to SMT’s. This review focuses on four facets 

of the original dataset, which covers rooms R-108 and SW-8: 

 Temporal data coverage (what time periods are covered by the data) 

 Availability of additional data sources 

 Inconsistencies in the annual dose calculations made using the data 

 An analysis of identified transcription errors and the overall effect of these errors on the 

calculated annual doses 

Each of these facets is presented in Sections 4.1.1–4.1.4, respectively. Subsequent to this 

review, additional data were compiled and analyzed in NIOSH 2012 for rooms SW-13 and 

SW-150. These data are discussed in Section 4.1.5. 

4.1.1 Temporal Data Coverage 

This section analyzes the completeness of the tritium swipe sample dataset compiled by NIOSH 

in the two spreadsheets ‘SMT exposures in R-108 SW-8 10-6 pre 1980.xls,’ ‘SMT exposures in 

R-108 SW-8 10-6 in 1980s.xls.’ Tables 1 and 2 show the available swipe data by intake 

evaluation period, as defined by NIOSH, for rooms R-108 and SW-8, respectively. Intake 

evaluation periods are generally on a monthly basis; however, NIOSH notes in their white paper: 

For those months that there was insufficiency in the data population for a 

95th-percentile calculation, the data for a number of months were combined for 

use in the analysis. (NIOSH 2012) 

Figures 4–6 visually depict the number of swipe samples by the intake periods shown in 

Tables 1–2 for rooms R-108 (Figure 4) and SW-8 (Figures 5–6). 

As shown in Table 1 and Figure 4, data compiled by NIOSH for room R-108 begin in June of 

1983 and extend to the end of 1989. Gaps in the available data occur from January 1983 to May 

1983, July 1986 to June 1988, and January 1989 to June 1989. No data were compiled for 1987, 

and the only year with an intake defined for each month was 1985. Intake evaluation periods 

averaged approximately 282 swipe samples each. Derived air concentrations are based on the 

surface activity concentration in μCi/m2

 and an RF of 3E-3/m. The actual 95th percentile surface 

concentration measurements are provided in the NIOSH evaluation and are not replicated here. 

This also applies to Table 2 for SW-8. 
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Table 1. Swipe Data Availability for Room R-108 (1983–1989) 

Year 

Intake 

Evaluation 

Period 

Number 

of Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Year 

Intake 

Evaluation 

Period 

Number 

of Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Jun–Aug 141 6.54E-03 Jan 349 1.80E-03 1983 

Sep–Dec 186 3.24E-03 Feb 320 1.65E-03 

Jan–Apr 246 2.43E-03 Apr 351 2.62E-03 

1984 May–Aug 264 2.64E-03 May 336 1.96E-03 

Sep–Dec 270 7.96E-03 

1986 

Jun 286 1.54E-03 

Jan 292 5.19E-04 1987 No Data NA NA 

Feb 282 1.36E-03 Jul 326 1.84E-03 

Mar 222 1.28E-03 Aug 365 2.42E-03 

Apr 316 1.75E-03 Sep 329 2.08E-03 

May 294 1.76E-03 Oct 321 1.54E-03 

Jun 236 1.17E-03 Nov 297 1.46E-03 

Jul 252 1.19E-03 

1988 

Dec 236 1.17E-03 

Aug 245 1.98E-03 Jul 305 2.23E-03 

Sep 264 2.19E-03 Aug 334 2.55E-03 

Oct 357 1.89E-03 Sep 292 1.24E-03 

Nov 292 1.65E-03 Oct 325 2.53E-03 

Nov 291 2.02E-03 

1985 

Dec 279 9.98E-04 

1989 

Dec 236 1.17E-03 

Figure 4. Number of Samples by Period for Room R-108 (1983–1989) 
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As shown in Table 3 and Figures 5–6, data compiled by NIOSH for room SW-8 begin in January 

of 1969 and extend to the end of 1989. The following gaps in the available swipe data were 

observed: 

 September 1969 

 December 1969 through September 1972 

 December 1972 through June 1975 

 September 1975 through May 1976 

 August 1977 through December 1977 

 All of 1980 

 March 1986 

 July 1986 through December 1986 

 September 1987 through December 1987 

 July 1988 through December 1988 

 July 1989 through December 1989 

During the earlier part of the evaluated period (1969 to 1979), intake periods were generally on a 

monthly basis and were generally on the order of 40–50 samples (the average sample size during 

this period was ~51). The smallest sample size observed was for October of 1972, which only 

used 12 samples to evaluate the 95th percentile surface contamination. There were only 3 cases 

during this earlier period in which data for more than 1 month were combined to allow for the 

calculation of the 95th percentile (July–August 1975, June–July 1976, and January–February 

1978). In each case, one of the paired months had less than 10 data points associated with it. 

The only year during this earlier period when each month contained enough data to be evaluated 

separately was 1979. 

During the later evaluated period (1980–1989), the number of swipe samples that were identified 

seem to increase, particularly starting in 1985 when the number of samples per month was 

consistently over 400 (this coincides with the availability of the raw swipe data instead of daily 

summary data). However, it is not clear why certain months were combined into a single intake 

period. For example, January and February of 1981 were evaluated based on 24 swipe samples 

for each month; however, the next intake period combines 4 months (March through June) with 

120 total samples. Closer examination of these 4 months shows that each month had at least 24 

samples, which were deemed an adequate number for the 2 preceding months (and twice the 

minimum number of samples used to analyze a given month in NIOSH’s analysis of the earlier 

period). From 1981 to 1984, no single month had less than 24 data points. Therefore, it is 

unclear why these months were combined into a single intake period instead of evaluated 

individually. 
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Table 2. Swipe Data Availability for Room SW-8 (1969–1989) 

Year 

Intake 

Evaluation 

Period 

Number of 

Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Year 

Intake 

Evaluation 

Period 

Number of 

Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Jan 44 4.40E-03 1980 No Data NA NA 

Feb 20 3.04E-03 Jan 24 6.63E-03 

Mar 306 6.18E-03 Feb 24 6.35E-03 

Apr 63 3.36E-03 Mar-Jun 120 4.43E-03 

May 81 4.29E-03 Jun-Oct 123 9.41E-03 

Jun 65 4.32E-03 

1981 

Nov-Dec 54 4.61E-03 

Jul 93 1.32E-02 Jan-Apr 129 7.81E-03 

Aug 131 3.34E-03 May-Aug 216 1.23E-02 

Oct 46 7.92E-03 

1982 

Sep-Dec 225 9.76E-03 

1969 

Nov 51 6.77E-03 Jan-Apr 189 7.11E-03 

1970 No Data NA NA May-Aug 234 8.44E-03 

1971 No Data NA NA 

1983 

Sep-Dec 189 1.14E-02 

Oct 12 8.97E-03 Jan-Apr 237 1.33E-02 1972 

Nov 75 4.27E-03 May-Aug 261 3.69E-03 

1973 No Data NA NA 

1984 

Sep-Dec 270 1.19E-02 

1974 No Data NA NA Jan 459 1.75E-03 

1975 July-Aug 21 3.53E-02 Feb 516 2.02E-03 

Jun-July 60 1.85E-02 Mar 359 2.01E-03 

Aug 30 8.73E-03 Apr 466 3.24E-03 

Sep 48 9.74E-03 May 482 2.26E-03 

Oct 51 1.62E-02 Jun 406 1.56E-03 

Nov 48 9.16E-03 Jul 448 1.59E-03 

1976 

Dec 45 5.76E-03 Aug 450 2.56E-03 

Jan 54 4.86E-03 Sep 423 3.96E-03 

Feb 51 6.28E-03 Oct 510 3.04E-03 

Mar 48 1.17E-02 Nov 379 3.33E-03 

Apr 51 7.70E-03 

1985 

Dec 335 1.37E-03 

May 57 8.28E-03 Jan 483 3.73E-03 

Jun 48 7.74E-03 Feb 438 2.47E-03 

1977 

Jul 54 8.17E-03 Apr 481 4.31E-03 

Jan-Feb 33 2.96E-03 May 461 1.70E-03 

Mar 36 4.21E-03 

1986 

Jun 449 2.57E-03 

Apr 32 5.83E-03 Jan 449 3.33E-03 

May 36 7.41E-03 Feb 432 5.26E-03 

Jun 45 2.83E-03 Mar 431 4.23E-03 

July 36 9.32E-03 Apr 466 4.74E-03 

Aug 42 6.16E-03 May 458 3.14E-03 

1978 

SEP 42 7.34E-03 

1987 

Jun 448 5.24E-03 
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Table 2. Swipe Data Availability for Room SW-8 (1969–1989) 

Year 

Intake 

Evaluation 

Period 

Number of 

Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Year 

Intake 

Evaluation 

Period 

Number of 

Swipe 

Samples 

95th Percentile 

Derived Air 

Concentration 

(μCi/m3

) 

Oct 42 9.38E-03 Jul 407 3.39E-03 

Nov 30 6.02E-03 Aug 492 3.01E-03 

Dec 39 5.60E-03 Jan 456 1.65E-03 

Jan 24 2.12E-03 Feb 300 4.48E-03 

Feb 33 6.66E-05 Mar 490 1.62E-03 

Mar 45 5.00E-03 Apr 480 1.42E-03 

Apr 24 4.78E-03 May 450 1.04E-03 

May 36 6.72E-03 

1988 

Jun 366 9.12E-04 

Jun 45 5.68E-03 Jan 449 1.34E-03 

July 39 2.05E-02 Feb 576 1.70E-03 

Aug 48 1.10E-02 Mar 474 1.21E-03 

Sept 33 7.47E-03 Apr 582 1.86E-03 

Oct 36 2.18E-03 May 470 1.63E-03 

Nov 42 2.57E-03 

1979 

Dec 27 2.52E-03 

1989 

Jun 349 1.94E-03 

Figure 5. Number of Samples by Period for Room SW-8 (1969–1979) 
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Figure 6. Number of Samples by Period for Room SW-8 (1980–1989) 

4.1.2 Availability of Additional Data Sources 

It is clear from the list of researched documents provided by NIOSH and the size of the files 

reviewed and transcribed that great effort went towards compiling the available swipe data. 

Nevertheless, SC&A performed an additional search of available documentation on the SRDB to 

determine whether additional data may now be available to fill in some of the gaps present in the 

data analysis and bolster the available sample sizes for months that already have data identified 

and compiled. 

SC&A was able to find one document (Connell 2009) for room SW-8 in 1980 that contained 

daily summary statistics (minimum, maximum, and average) of swipe data for select days and 

months. It is important to note that this type of summary data was used by NIOSH for time 

periods in which the raw swipe data were not available (years prior to 1985 for both R-108 and 

SW-8, with the exception of 1969 for SW-8 in which raw data were identified). Table 3 shows 

the number of potential data points for SW-8 in 1980 by month. 
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Table 3. Available Health Physics Trend Data for Room SW-8 in 1980 

Overview of Data Magnitude (cpm/100 cm2) Month Number of Data Points 

Minimum Value Maximum Value Average Value 

January 39 0 1,150 205.3 

February 39 0 3,743 658.9 

March 39 0 2,185 354.7 

April 33 11 2,771 594.4 

May 33 6 3,679 792.6 

June 0 - - - 

July 0 - - - 

August 0 - - - 

September 0 - - - 

October 6 67 2,000 616.7 

November 27 9 3,361 462.4 

December 18 52 6,593 1,528.3 

Source: Connell 2009 

For the years 1985 through 1989, NIOSH identified and compiled raw swipe data in calculating 

the 95th percentile surface contamination. Use of raw data is obviously preferable to the HP 

Trend Reports, which only contain the minimum, maximum, and average swipe results for a 

given day. However, raw data gaps have been found for several of the months from 1986–1989; 

therefore, it may be beneficial to use the HP Trend Reports to fill in the identified data gaps. 

Tables 4–7 show the available HP trend data for months with no raw data available. Therefore, 

additional data and reports exist that would help bolster the dataset already compiled by NIOSH. 

Table 4. Available 1986 HP Trend Data for Months with No Available Raw Data 

Room SW-8: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) 

Room R-108: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) Relevant 

Months

Number of 

Data Points* 

Min 

Value 

Max 

Value 

Average 

Value 

Min 

Value 

Max 

Value 

Average 

Value 

March 60 0 6,824 727.3 0 8,483 656.1 

July 63 0 12,571 1,117.0 0 5,293 442.9 

August 60 0 4,733 665.2 0 3,930 357.6 

September 63 0 5,047 734.7 0 2,250 353.7 

October 69 0 4,933 588.4 0 1,957 310.9 

November 54 0 2,829 424.4 0 2,700 239.7 

December 51 0 8,237 900.9 0 1,686 343.9 

*Applies to both rooms SW-8 and R-108 

Sources: Connell 2010b and 2010c 
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Table 5. Available 1987 HP Trend Data for Months with No Available Raw Data 

Room SW-8: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) 

Room R-108: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) Relevant 

Months

Number of 

Data Points 

in HP Trend 

Reports* Min 

Value 

Max 

Value 

Average 

Value 

Min 

Value 

Max 

Value 

Average 

Value 

January 60 Raw data available 0 2,086 431.5 

February 60 Raw data available 0 2,867 512.6 

March 66 Raw data available 0 2,819 517.0 

April 63 Raw data available 0 3,200 464.7 

May 48 Raw data available 0 3,883 335.1 

June 66 Raw data available 0 16,076 601.4 

July 66 Raw data available 0 2,180 301.0 

August 63 Raw data available 0 6,266 550.7 

September 60 0 3,011 570.0 0 9,050 700.8 

October 60** 0 25,897 874.3 0 1,744 384.6 

November 66 0 16,843 667.7 0 1,270 230.4 

December 63 0 4,287 591.8 0 14,626 748.2 

* Applies to both rooms SW-8 and R-108 except where noted 

** Value applies to room SW-8, room R-108 value is 51 

Sources: Connell 2010e and 2010f 

Table 6. Available 1988 HP Trend Data for Months with No Available Raw Data 

Room SW-8: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) 

Room R-108: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) Relevant 

Months

Number of 

Data Points* Min 

Value 

Max 

Value 

Average 

Value 

Min 

Value 

Max 

Value 

Average 

Value 

January 60 Raw data available 0 1,469 286.7 

February 63 Raw data available 0 1,786 273.7 

March 57 Raw data available 0 4,691 407.4 

April 30 Raw data available 0 1,997 215.0 

May 63 Raw data available 0 3,014 383.4 

June 66 Raw data available 0 4,174 625.3 

July 60 0 11,727 519.6 Raw data available 

August 54 0 53,223 2,101.4 Raw data available

September 63 0 2,269 363.0 Raw data available

October 63 0 4,253 405.8 Raw data available

November 51 0 7,222 414.3 Raw data available

December 36 0 3,389 258.9 Raw data available

*Applies to both rooms SW-8 and R-108 

 Sources: Connell 2010g and 2010h
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NOTICE:

Table 7. Available 1989 HP Trend Data for Months with No Available Raw Data 

Room SW-8: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) 

Room R-108: 

Overview of the Magnitude of 

Available Results (cpm/100 cm2

) Relevant 

Months

Number of 

Data Points* Min 

Value 

Max 

Value 

Average 

Value 

Min 

Value 

Max 

Value 

Average 

Value 

January 48 Raw data available 0 2,809 280.5 

February 45 Raw data available 0 4,199 503.7 

March 51 Raw data available 0 7,784 687.2 

April 30 Raw data available 0 1,276 320.2 

May 36 Raw data available 43 4,588 503.4 

June 66 Raw data available 31 20,136 792.8 

July 42 0 1,869 273.6 Raw data available 

August 39 0 2,313 351.7 Raw data available

September 30 0 2,265 277.0 Raw data available

October 15 0 574 135.2 Raw data available

November 48 0 1,864 276.9 Raw data available

December 30 0 1,129 212.5 Raw data available

*Applies to both rooms SW-8 and R-108 

Sources: Connell 2010i and 2010j 

4.1.3 Dose Calculation Inconsistencies Identified in Spreadsheets 

NIOSH has derived annual 50-year committed organ dose values by calculating monthly intakes 

based on the 95th percentile surface contamination (and associated air concentration) in each 

respective room. These monthly intakes are then summed to get an annual intake value, which 

can then be converted to a committed dose using appropriate dose conversion factors. However, 

annual doses appear to be underestimated for years in which data do not exist for all 12 months. 

Further complicating the annual dose calculations is the fact that when data for multiple months 

were combined to derive a single 95th percentile value, intakes were calculated assuming only a 

single month’s exposure time. An example of each of these calculational errors is shown below 

based on the methodology presented in NIOSH 2011a (the “extreme” bounding case). 

Example 1: Underestimation of Annual Doses for Years with Data Gaps 

For this example, the annual dose calculation for SW-8 in 1972 is considered. Data for 1972 

were limited to October (12 samples) and November (75 samples); these were treated by NIOSH 

as two discrete intake periods. Table 8 details the calculational steps taken by NIOSH to derive 

the annual dose for 1972. 
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Table 8. Steps Used by NIOSH in Calculating Doses for 1972 

Step Description Assumed Parameter Values Calculation Step Com

1 Raw data are compiled Various swipe results N/A Starting point for the ann

Multiple raw floor swipecpm/100 cm2. 

2 Account for detector efficiency Detector Efficiency: 4% Divide raw values by 0.04 Values converted to dpm3 Convert dpm to μCi Conversion Factor: 2.22E+06 dpm/μCi Divide values by 2.22E+06 Values converted to μCi/4 Apply resuspension factor 

Resuspension factor: 

3E-03 m-1

Unit Conversion: 

μCi/100 cm2 × 

(100 cm/m)2

Multiply values by 100 and 3E-03 m-1

Resuspension factor is apconcentration based on eagiven in μCi/m3. 

5 

Calculate 95th

percentile air 

concentration 

N/A 

October 95th percentile concentration: 

8.97E-03 μCi/m3

November 95th percentile concentration: 

4.27E-03 μCi/m3

Calculated airborne conclognormal distribution andeviation are calculated. the 95th percentile air con

6 Calculate monthly intake 

Breathing Rate: 

1.2 m3/hr 

Exposure Time: 

167 hrs/month 

October Intake: 

8.97E-03*(1.2)*(167) = 1.79 μCi 

November Intake: 

4.27E-03*(1.2)*(167) = 8.54E-01 μCi 

Exposure time based on 212 months = 167 hours/m

`7 Calculate annual intake N/A October Intake + November Intake 1.79 + 8.54E-01 = 2.65 μCi Annual intake is only ba

exposure (167*2= 334 hoyear). 

8 Convert intake to committed lung dose 

Dose conversion factor: 

3.68E-03 rem/μCi 

Unit conversion: 

1,000 mrem/rem 

2.65*(1000)*(3.68E-03) = 9.74 mrem 

CDE to the lung 

Derived CDE dose for thannual intake, which is r2 months of exposure. 
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Note that the value obtained from Table 8 (9.74 mrem CDE to the lung) is consistent with the 

value reported on page 28 of NIOSH 2012. Since this value is based on only 2 months’ worth of 

exposure, the actual annual dose would be much higher if data were available for the remaining 

months. If we assume the average monthly intake for the remaining months is 1.325 μCi 

(2.65/2), then the total intake for 1972 could be estimated at 15.9 μCi (1.325*12). This results in 

a new CDE to the lung of 58.5 mrem, which is a factor of 6 higher than the reported dose. 

Example 2: Underestimation of Annual Doses where Data for Multiple Months have been 

Pooled Together 

As noted earlier in this report and in the NIOSH white paper, for situations where a given month 

did not have sufficient data to calculate the 95th percentile, the data for multiple months may be 

pooled together to determine the appropriate air concentration. For this example, the annual dose 

for room SW-8 in 1983 will be examined. The reader is referred to Table 8 for the calculational 

steps taken to reach an annual dose; the difference here is that intakes are not calculated using a 

single month’s data, but rather multiple consecutive months in the given year. A tabulation of 

the main values reported by NIOSH for this year is given in Table 9. 

Table 9. Values Reported by NIOSH in Annual Dose Calculation for 1983 

Intake Period Considered 

Derived 95th Percentile Air 

Concentration 

(μCi/m3

) 

Associated Intake* 

(μCi) 

CDE to the Lung** 

(mrem) 

January–April 7.11E-03 1.42E+00 5.23E+00 

May–August 8.44E-03 1.69E+00 6.20E+00 

September–December 1.14E-02 2.28E+00 8.40E+00 

Annual Totals: 5.39E+00 1.98E+01 

* Intake derived by multiplying 95th air concentration by 1.2 (m3/hour) and 167 (hours) 

** CDE to the lung based on DCF value of 3.68 mrem/μCi 

Similar to Example 1, the issue is that a full year of exposure has not been considered. In this 

example, 3 intake periods are considered, each representing 4 months; however, the actual 

intakes are based only on 1 month of exposure (167 hours for each intake period). If each 

calculated intake in Table 10 is extrapolated to the full exposure period it represents, the 

resulting CDE to the lung increases from 1.98E+01 mrem to 7.93E+01 mrem (factor of 4). 

These types of ‘exposure time’ errors are pervasive in the NIOSH calculations, owing to the 

large number of years with data gaps and/or several months of data being pooled together. 

Tables 10 and 11 provide corrected intakes adjusted to full-year exposures. Please refer to 

Attachment 1 for the actual calculation of the extrapolated intakes. 
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Table 10. Original NIOSH Intakes Compared to Adjusted Intakes for a Full Year 

Exposure for Room R-108 

Year Original NIOSH 

Intake (μCi) 

Intake Adjusted to 

Full Year (μCi) 

Ratio (Adjusted/ 

Original) 

1983 1.96E+00 1.12E+01 5.71E+00 

1984 2.60E+00 1.04E+01 4.00E+00 

1985 3.56E+00 3.56E+00 1.00E+00 

1986 1.92E+00 4.60E+00 2.40E+00 

1987 Data not compiled/analyzed

1988 2.11E+00 4.22E+00 2.00E+00 

1989 2.35E+00 4.70E+00 2.00E+00 

Table 11. Original NIOSH Intakes Compared to Adjusted Intakes for a Full Year 

Exposure for Room SW-8 

Year Original NIOSH 

Intake (μCi) 

Intake Adjusted to 

Full Year (μCi) 

Ratio (Adjusted/ 

Original) 

1969 1.14E+01 1.36E+01 1.20E+00 

1970 Data not available and/or compiled

1971 Data not available and/or compiled

1972 2.65E+00 1.59E+01 6.00E+00 

1973 Data not available and/or compiled

1974 Data not available and/or compiled

1975 7.07E+00 8.48E+01 1.20E+01 

1976 1.36E+01 2.97E+01 2.18E+00 

1977 1.09E+01 1.88E+01 1.71E+00 

1978 1.34E+01 1.40E+01 1.04E+00 

1979 1.47E+01 1.47E+01 1.00E+00 

1980 Data not available and/or compiled

1981 6.28E+00 1.55E+01 2.47E+00 

1982 5.98E+00 2.39E+01 4.00E+00 

1983 5.39E+00 2.16E+01 4.00E+00 

1984 5.79E+00 2.32E+01 4.00E+00 

1985 5.75E+00 5.75E+00 1.00E+00 

1986 2.96E+00 7.11E+00 2.40E+00 

1987 6.48E+00 9.72E+00 1.50E+00 

1988 2.23E+00 4.46E+00 2.00E+00 

1989 1.94E+00 3.88E+00 2.00E+00 
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As shown in Tables 10 and 11, the reported annual intakes have been underestimated by up to a 

factor of 12 (1975). Likewise, the calculated organ CDEs would also change in proportion to the 

increase in intake. NIOSH reports the highest dose commitment to select organs observed using 

the compiled swipe data in Table 5 of their white paper. SC&A has recreated the information 

from Table 5 in Table 12 of this report, which includes the new ‘maximum’ organ doses when 

the annual intake values are scaled to a full year of exposure. 

Table 12. Comparison of Limiting Organ CDEs Based on NIOSH Intake Estimates 

versus Intake Estimates Extrapolated to a Full Year of Exposure 

Organ 

NIOSH Limiting CDE 

Organ Doses - mrem 

(based on data from 1979) 

Adjusted CDE Organ Doses 

to Full Year - mrem 

(based on data from 1975) 

Lung 54.1 311.7 

LN (ET) 177 1,022.3 

LN (TH) 266 1,532.2 

AI 162 931.3 

ET 0.189 1.1 

U.L.I. 2.52 14.5 

LLI 7.37 42.5 

SI 0.424 2.4 

Colon 4.62 26.6 

4.1.4 Brief Evaluation of Potential Transcription Errors 

In preparation for the Mound Work Group meeting held on November 7, 2011, SC&A compiled 

available Health Physics Trend Reports for the years in the early 1980s (1981–1984), which 

currently had no swipe data associated with the SMT exposure model. These same source data 

were transcribed by NIOSH in their most recent tritide model, which is the subject of this review. 

Therefore, it was possible to evaluate potential transcription errors by comparing the two 

independently compiled datasets and resolving any inconsistencies by referencing the hardcopy 

records. This analysis of potential errors is the subject of this section (and also Attachment 2). 

A summary of the error analysis is presented in Table 13. 

Three types of “errors” were analyzed and described below: 

(1) Transcription errors: Data points were transcribed from the hardcopy records; 

however, one or more of the digits were incorrect. 

(2) Missing data: Data points were missed when compiling relevant data from the 

hardcopy records. 

(3) Duplicate data: The same sample values appear more than once in the compiled 

dataset, likely a result of the repetition of sample analysis sheets within the source 

documents. 
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Table 13. Overview of Transcription Error Analysis for the Years 1981–1984 

Analysis Category Total Number Identified Percent of Total

Total Data Compiled by NIOSH 1981–1984 3,402* N/A 

Transcription Errors 56 1.7% 

Under-reported Samples 37 1.1% 

Over-reported Samples 19 0.6% 

Change in Net CPM for the Entire Dataset with 

Transcription Errors Corrected N/A -2.7% 

Missing Data 54 1.6% 

Duplicate Data 81 2.4% 

* Note: The total number of data available from 1981 to 1984 would change from 3,402 to 3,375 

if duplicate entries are removed and missing entries are included. 

As seen in Table 13, the number of transcription errors was relatively low at only 1.7%. While a 

higher percentage of these transcription errors resulted in the samples being under-reported, the 

net effect of these errors actually resulted in the total counts per minute (cpm) for the dataset 

being reduced by 2.7%. The number of data points missing from the NIOSH compilation was 

also relatively low at 1.6% and can generally be correlated with a “missed page” in the source 

documents. As mentioned previously, the duplication of data points in the NIOSH dataset is 

likely the result of specific pages of the HP summary reports being repeated in the source 

documents. A description of each error found, along with the associated reference to the 

hardcopy source documents, can be found in Attachment 2. 

4.1.5 Evaluation of Additional Data Compiled in NIOSH 2012 

On March 30, 2012, NIOSH released a white paper titled, Potential Stable Metal Tritide 

Exposures at the Mound Laboratory (NIOSH 2012), which presented a revised methodology for 

evaluating tritide exposures. This revised methodology also included additional data from rooms 

SW-13 and SW-150 to supplement the earlier dataset, which covered rooms R-108 and SW-8. 

Unlike the original data evaluation, which analyzed the data on a monthly basis (or, when 

unavailable, grouped several months together), the swipe data for SW-13 and SW-150 were 

grouped and analyzed by year. 

A potential concern with this type of approach is that the annual derived values could be unduly 

weighted by months that contained more sampling data, but may not have been representative of 

the normal conditions throughout the year. As part of its review of this additional dataset, SC&A 

broke down the data by month to compare the relative magnitude of the swipe data when 

weighted by month versus pooling all of the data into a single annual dataset. This comparison, 

as well as the overview of data coverage for rooms SW-13 and SW-150, are shown in Tables 14 

and 15, respectively. The comparisons of calculated annual average values versus the monthly 

weighted average values are plotted in Figures 7 and 8. 

As seen in Table 14, data for SW-13 extended from 1974 to 1989, with the largest temporal gap 

being an 8-month period from the end of 1988 into 1989. The comparison of the ratio of the 

annual average values to the monthly weighted values was fairly consistent with the highest 
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discrepancies occurring in 1975 and 1985, in which the monthly weighted values were 21% and 

28% higher, respectively. 

Table 14. Overview of Available Surface Contamination Swipe Results for 

Room SW-13 by Year 

Overview of Sampling Quantitative Results (cpm/100 cm2) 

Year 

# Months 

with 

Sampling 

Data 

Average # 

Samples per 

Sampled 

Month 

# Consecutive 

Months with 

No Sampling 

Yearly 

Average 

Average 

Weighted by 

Month 

Ratio 

(Weighted by 

Month/Grouped) 

1974 11 6 1 2729.8 2646.6 0.97 

1975 7 6 4 2637.4 3204.3 1.21 

1976 6 7 6 884.8 800.7 0.90 

1977 12 9 0 1727.4 1658.9 0.96 

1978 12 10 0 1209.6 1388.7 1.15 

1979 12 15 0 420.8 392.0 0.93 

1980 8 11 4 363.8 382.2 1.05 

1981 12 11 0 537.4 531.8 0.99 

1982 12 11 0 955.7 969.1 1.01 

1983 12 10 0 1932.3 2008.6 1.04 

1984 12 8 0 1542.8 1554.8 1.01 

1985 12 154 0 474.5 606.5 1.28 

1986 4 201 6 369.3 344.7 0.93 

1987 10 469 2 303.7 303.5 1.00 

1988 4 510 6 398.2 400.2 1.00 

1989 6 468 8* 329.7 302.6 0.92 

*8 consecutive months with no sampling include 2 months at the end of 1988 

Figure 7. Comparison of the Annual Average Surface Contamination versus the 

Monthly Weighted Average Annual Surface Contamination for Room SW-13 
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As seen in Table 15, data for room SW-150 extended from 1968 to 1989, with the largest 

temporal gap being 10 months beginning in late 1987 and extending into 1988. Similar to 

SW-13, the comparison of the ratio of the annual average results versus the monthly weighted 

annual results showed generally good agreement. The largest discrepancies occurred in 1978 

and 1985, in which the monthly weighted average was 35% and 26% higher, respectively. 

 

Table 15. Overview of Available Surface Contamination Swipe Results for 

Room SW-150 by Year 

Overview of Sampling Quantitative Results (cpm/100 cm2) 

Year 

# Months 

with 

Sampling 

Data 

Average # 

Swipes per 

Sampled 

Month 

# Consecutive 

Months with 

no Sampling 

Yearly 

Average 

Average 

Weighted by 

Month 

Ratio 

(Weighted by 

Month/Grouped) 

1968 12 8 0 3282.1 3218.7 0.98 

1969 9 70 3 550.0 535.7 0.97 

1970 12 8 0 2436.1 2438.8 1.00 

1971 12 8 0 3347.5 3643.9 1.09 

1972 12 8 0 1983.1 1840.1 0.93 

1973 12 8 0 1876.2 1698.0 0.91 

1974 12 8 0 1866.1 1804.6 0.97 

1975 12 9 0 1951.4 1837.9 0.94 

1976 5 10 7 3009.2 2990.0 0.99 

1977 12 9 0 3198.5 3263.1 1.02 

1978 12 9 0 1564.2 2118.0 1.35 

1979 12 12 0 439.1 433.4 0.99 

1980 8 11 4 236.7 263.3 1.11 

1981 12 11 0 318.2 313.6 0.99 

1982 12 11 0 740.5 735.6 0.99 

1983 12 16 0 1020.1 1049.4 1.03 

1984 12 20 0 1294.1 1296.7 1.00 

1985 12 197 0 474.8 598.7 1.26 

1986 4 334 6 325.7 328.7 1.01 

1987 8 497 4 187.0 184.9 0.99 

1988 6 485 10* 235.8 241.8 1.03 

1989 6 460 6 132.2 131.8 1.00 

*10 consecutive months with no sampling include 4 months at the end of 1987 
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Figure 8. Comparison of the Annual Average Surface Contamination versus the 

Monthly Weighted Average Annual Surface Contamination for Room SW-150 

As shown in Tables 14 and 15, the temporal data coverage for rooms SW-13 and SW-150 is 

generally complete, with gaps extending no longer than 8 and 10 months, respectively. Though 

the ratio of the annual average and the monthly weighted average was generally consistent, 

NIOSH should examine the feasibility of evaluating the data on a monthly basis to maintain 

consistency with the previous data analysis for rooms R-108 and SW-8. 

NIOSH 2012 presents a case study example, which applies their model to a hypothetical worker 

scenario. Specifically, the case study assumes a worker was exposed for 2 years to the highest 

observed levels of annual contamination for each room (R-108, SW-8, SW-13, and SW-150) 

with the dose evaluated 10 years after the exposure. NIOSH 2012 presents the results of this 

case study in Table 1 of their white paper (presented below as Figure 9). 
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Figure 9. Recreation of NIOSH 2012 Table 1 

A review of the case study shows that similar errors occur in this dose calculation as were 

identified in Section 4.1.3 of this report. Specifically, derived intakes have not been extrapolated 

to a full year. This is particularly significant for rooms SW-13 and SW-150, since the data has 

been pooled together into a single annual dataset, though derived intakes are based on only a 

single month of exposure time. If these errors are corrected, the resulting doses that are shown in 

Figure 9 would increase to the values shown in Table 16. Table 17 shows the ratio of the 

corrected values in Table 16 to the original values shown in Figure 9. Based on these updated 

values, the limiting lung dose at the 95th percentile for room SW-150 is approximately 

3.73 mrem. It is noteworthy that the corrected 95th percentile lung dose is notably higher than 

the 1-mrem threshold cited by NIOSH at the last work group meeting. 

 

Table 16. SC&A Corrected Potential SMT Doses to the Lung Based on NIOSH 2012 

Case Study Example 

Best Estimate (50th Percentile) Bounding (95th Percentile) 

Room 12 Year Dose 

(Year 1) 

11 Year Dose 

(Year 2) 

12 Year Dose 

(Year 1) 

11 Year Dose 

(Year 2) Total Total 

SW-150 0.48 0.47 0.95 1.91 1.82 3.73 

SW-13 0.46 0.34 0.80 1.49 1.3 2.79 

R-108 0.02 0.03 0.05 0.10 0.28 0.37 

SW-8 0.04 0.13 0.17 0.51 2.26 2.77 
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Table 17. Ratio of SC&A Corrected Case Study Lung Doses shown in Table 16 to 

Original NIOSH 2012 Case Study Values shown in Figure 9 

Best Estimate (50th Percentile) Bounding (95th Percentile) 

Room 12 Year Dose 

(Year 1) 

11 Year Dose 

(Year 2) Total 12 Year Dose (Year 1) 

11 Year Dose 

(Year 2) Total 

SW-150 12.0 11.8 11.9 11.9 12.1 12.0 

SW-13 11.5 11.3 11.4 12.4 11.8 12.1 

R-108 1.0 3.0 1.7 1.0 4.0 2.2 

SW-8 2.0 1.2 1.4 1.7 11.9 5.8 

4.1.6 Concluding Statements on Data Adequacy and Completeness 

Based on the review of the underlying data presented in Sections 3.2.1–3.2.4, SC&A concludes 

that the dataset is complete and adequate for rooms R-108 beginning in 1983 and SW-8 

beginning in 1976. Any chronological gaps that were identified were generally on the order of a 

few months and can likely be analyzed using surrogate data from previous intake periods. 

Similarly, the dataset for rooms SW-13 and SW-150 are complete, with data gaps never 

extending more than 10 months, and were generally on the order of 6 months or less. Many 

years contained data for all 12 months for these rooms. 

However, if possible, NIOSH would benefit from a discussion of the identified gaps in the 

context of exposure conditions both before and after the periods without data to assure that any 

surrogate approach is accurate and appropriate. 

4.2 REVIEW OF DETECTOR EFFICIENCY AND TRITIUM AIR SAMPLE 

FILTERS FOR SMTS 

4.2.1 Evaluation of 4% Detector Efficiency 

NIOSH provided an analysis of the Mound Lab SMT issue in an e-mail of October 14, 2011 

(NIOSH 2011b), with an attachment titled “PC5 Eff.docx.” This was a 1-page document that 

provided a summary of the methods used by NIOSH to derive a tritium counting efficiency of 

4% for the PC-5 gas-flow proportional counter (PC) from swipes by comparing the response of 

the PC-5 to a liquid scintillation counter (LSC); i.e., the recorded swipe results obtained by the 

PC-5 would be divided by 0.04 to obtain the tritium dpm value for the swipe. 

NIOSH used documents from the SRDB that contained data sheets with both the PC-5 cpm 

values and the LSC dpm values recorded for the same swipes for the years 1990 and 1991. 

These documents are: 

Table #1 SRDB Numbers

 81787, pp. 8–247 (Connell 2010k)

 81788, pp. 2–628 (Connell 2010L) 

 81907, pp. 425–700 (Connell 2010m) 

 81908, pp. 58–62 (Connell 2010n) 

 81909, pp. 2–692 (Connell 2010o) 
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A sample of 356 of these data pairs was transcribed for evaluation in the spreadsheet titled, 

“Mound LSC & PC5 comparison” (NIOSH 2011c). These data pairs are contained in the 

following documents: 

Table #2 SRDB Numbers

 81787, pp. 28–38, 44, 50, 60, 70, 80, 90, 100, 110 (Connell 2010k) 

 81788, pp. 2, 20 (Connell 2010L) 

These data pairs were sorted according to the observed [PC-5 (CPM)]/[LSC (DPM)] values and 

it was found that 277 pairs fit the criteria of this value, being less than 0.20 (i.e., <20%); this 

value was selected because efficiencies greater than this for a PC-5 system would indicate betas 

of greater than the maximum energy of 17 keV (tritium). The correlation of these data was 

moderately strong, with a Variance table P-value less than 0.05. The R-Squared statistic 

indicates that the linear model as fitted explains 38% of the variability in the PC-5 data. 

SC&A’s Evaluation

SC&A reviewed the above-listed and other relevant documents, and spot checked some of the 

efficiency values using the raw data. SC&A analyzed the data (removing zero PC-5 counts and 

those with ≥ 20% efficiency, as previously discussed) and arrived at an efficiency of 

approximately 10%; i.e., #dpm = PC-5 (cpm)/0.10. The relationship is illustrated in Figure 10, 

which also plots the values of 4% and 10% of the LSC dpm values. 

PC-5 cpm vs. LSC dpm

0

100

200

300

400

500

51

117176248308360429537652774917

110813871708228031486790

LSC (dpm)

PC-5 (cpm)

PC-5 (cpm) 4% of dpm 10% of dpm

Figure 10. PC-5 (cpm) vs. LSC (dpm) and 4% and 10% of LSC dpm Values 
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As can be seen from this figure, the PC-5 system appears to have an efficiency that is reasonably 

represented by the 10% efficiency line. Ranking the data provides a median efficiency of 10.2% 

and a 50th percentile of 9.8%. The NIOSH-recommended PC-5 efficiency of 4% is, therefore, 

very conservative, but claimant favorable. However, SC&A did have the following questions 

concerning the data used: 

(1) What was the criterion applied to the data pairs in the documents listed in Table 1 SRDB 

Numbers above to arrive at the list of documents and page numbers in Table 2 SRDB 

Numbers above? 

(2) Were the main areas emphasized in the data used representative of surfaces in R-108 and 

SW-8 during the 1980s? 

4.2.2 Tritium Air Sample Filters for SMT 

A continuous air sampler for tritium usually consists of an ionization chamber (IC) in which air 

is continuously drawn through the IC by an air pump connected to the outlet of the IC. The inlet 

air port of such a system must have a filter to prevent dust and other particles from entering the 

IC and causing interference and false positive readings. These inlet filters are designed to trap 

most all particulate matter, letting only gaseous materials pass through the IC. Airborne SMT 

would be trapped on the inlet filter, and theoretically could be analyzed for particulate tritium 

contents to determine SMT concentration in the sampled air. However, in practice, this is a very 

difficult process because of the many variables present, especially for the very low average 

energy of tritium betas (~5 keV). Dust loading would vary and affect the detection of the tritium 

beta particles, as would the depth of the SMT in the filter medium. Variation in the 

concentrations of other beta-emitting interfering radionuclides (natural and man-made) would 

also interfere with the tritium analyses. Additionally, release of the SMT from the filter 

contaminants and the filter medium causes changes in the count rate as a function of time. 

Counting the filters for SMT by PC or LSC, under controlled conditions, has not been successful 

in the documents reviewed (Sullivan 1996; Powers 1998; Sharfi 2000). Therefore, it would be 

expected to be very difficult to obtain any quantitative relationship of SMT air concentration to 

PC, or LSC, count rates from filters on IC inlets, or any filter, from the 1980s or 1990s. 

4.3 REVIEW OF RESUSPENSION FACTOR 

The STC bounding methodology proposed by NIOSH depends to a large extent on the integrity 

and applicability of the selected resuspension factor (RF). The RF is simply an empirically 

determined ratio of the air concentration of radioactive material above a surface (Bq/m3

) to the 

concentration on the surface (Bq/m2). However, there is some ambiguity in the denominator of 

this calculation. If the surface contamination is based on swipe samples, the denominator is 

removable contamination. If the surface contamination is based on estimates of the total amount 

of dust or radioactive material surfaces, the denominator is the total amount of radioactivity or 

dust per unit surface area. Regulatory Guide 1.86 (NRC 1974) recommends that the 

resuspendable (or readily removable) amount of radioactivity on a surface is about 20% of the 

total amount of radioactive material on a surface. Therefore, the product of the tritide surface 

contamination with an appropriately selected RF, taking into consideration how the level of 
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surface contamination was determined, yields an estimate of the airborne tritide concentration to 

which workers may have been exposed.12 

In its initial evaluation of resuspension factors that would place an upper bound on airborne 

tritides due to resuspension processes, NIOSH originally elected to use an RF of 3E-3/m (i.e., 

3E-3 Bq/m3 per Bq per m2). SC&A’s original review of that RF (in the withheld predecessor to 

this paper) concluded that 3E-3/m was certainly bounding, if not implausibly high, especially 

when used to derive an annual average airborne loading of tritides. In its white paper dated 

March 30, 2012, NIOSH elected to use a more plausible, but still bounding, RF of 5E-5/m. This 

section of SC&A’s report presents a review of this revised RF, as adopted by NIOSH for use in 

determining the airborne levels of metal tritides relative to metal tritides on contaminated 

surfaces, as determined by swipe samples at Mound.13 

It must be kept in mind that RFs are used primarily after operations cease and there is no source 

of radioactivity being injected directly into the ambient working environment by leakage or other 

processes associated with operations. It is not apparent that NIOSH is restricting the use of the 

RF approach to post-operational scenarios, where the air can only become contaminated by 

resuspension processes. 

NIOSH selected an RF of 5E-5/m by citing ORAUT-OTIB-0070, Dose Reconstruction During 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities (ORAUT 2012). SC&A 

had previously reviewed OTIB-0070 in support of the Procedures Subcommittee, and, after a 

number of meetings and exchanges of white papers, SC&A concurred with the commitments 

made by NIOSH to revise OTIB-0070, which included the use of an RF of 5E-5/m. In the 

interest of full documentation, SC&A revisits this subject here. 

One of the most widely referenced reports dealing with the subject of RFs is DOE Handbook: 

Airborne Release Fractions/Rates and Respirable Fractions for Nonreactor Nuclear Facilities

(DOE 1994). This report, in turn, cites the seminal paper on this subject, Particle Resuspension: 

A Review (Sehmel 1980). SC&A reviewed this paper, the source documents cited in this paper, 

and more recent publications on this subject. We found that an RF of 5E-5/m represents a 

scientifically sound upper bound of the average annual RFs that might have been experienced 

during the residual period at any facility and applicable only if the residual surface 

contamination, as determined at the facility, is based on total deposited radioactivity. As 

used in the white paper presented by the NIOSH contractor, we are concerned that the RF of 

5E-5/m will be used during operational periods, when direct airborne leakage is possible, and 

12 In addition, it could be argued that the resuspension factor, in combination with knowledge of the levels 

of surface contamination, could be used to estimate airborne concentration of radionuclides from both resuspension 

of surface contamination and from direct airborne contamination due to the direct release of aerosols into the air 

(e.g., leakage of aerosols during processing) if the resuspension factor selected for use was originally derived under 

the following conditions: (1) operations that introduced radioactive materials directly into the air were taking place, 

(2) quasi-equilibrium was established between surface and airborne activity, and (3) the conditions under which the 

resuspension factor was derived are similar to the conditions under which the resuspension factor is being employed. 13 A significant portion of the material provided in this report was originally provided in an unpublished 

draft document titled, Radiological Assessment for Clearance of Equipment and Materials from Nuclear Facilities – 

Main Report (NRC 1998). SC&A used the material in this unpublished draft report as a starting point for the 

preparation of this report.
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applied to measures of surface contamination that are based on swipe samples without any 

correction factor to adjust for the difference between total surface contamination and removable 

surface contamination (i.e., swipe sample data). The following briefly summarizes the literature 

on indoor RFs in order to provide the Mound Work Group with the basis of this conclusion. 

Measured RFs vary over very wide ranges. Kennedy and Strenge (1992) reported RFs from 

approximately 1E-11 to 1E-2 m-1, which suggests that resuspension is a complex process of 

several parameters, and that the specific conditions present at the time of measurement are 

critical. For modeling purposes, an RF is a lumped parameter that is used to account for a 

complex combination of mechanisms that are poorly understood, but whose net effect is 

observed in the real world. 

The RF is affected by a number of physical factors that include the following: 

 Type of disturbance 

 Intensity of disturbance 

 Time since deposition 

 Nature of the surface 

 Particle size distribution 

 Climatic conditions 

 Type of deposition 

 Chemical properties of the contaminant 

 Surface chemistry 

 Room geometry and characteristics 

A general discussion of these factors is provided in Beyeler et al. (1999).

When choosing an appropriate value for an RF, one must consider the nature of contamination 

on the surface (e.g., how tightly it is bound to the surface) and balancing the driving forces that 

cause the material on the surface to become airborne with the mechanisms that remove the 

material from the air. Clearly, the concept of RFs applies to solid particles and does not apply to 

gases. 

The primary force that will resuspend particles indoors can be expected to be mechanical forces 

associated with rubbing and abrasion of surfaces. These forces are typically associated with 

human activity. In buildings, air currents caused by normal ventilation or by vibrations are not 

expected to be a major cause of resuspension of particles (NRC 2002, also referred to as 

NUREG-1720). Moreover, RFs determined from mechanical disturbance can be an order of 

magnitude higher than RFs determined with only air currents (Beyeler et al. 1999). Higher RFs 

were measured when driving forces were increased and when surface contamination was loosely 

bound and easily removable (NUREG-1720). It is important to assess the types and intensity of 

the applied driving forces in order to select appropriate RF values for any dust inhalation 

exposure scenario. 

How the surface radioactivity is bound to the surface will have a major effect on the RF. For 

particles to become airborne, the bond between the particles and the surface (e.g., floor or wall) 
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must be broken by the driving forces. Particles that are tightly bound to the surface are not easily 

resuspended, whereas particles that are loosely bound, like freshly deposited material, will be 

more easily resuspended. Tightly bound particles require greater mechanical force to break the 

bonds and become resuspended. For similar surface radioactivity levels and particle size 

distributions, surfaces with a large portion of tightly bound particles will yield smaller RFs. 

As discussed in Beyeler et al. (1999), resuspension appears to be generally higher for smaller 

diameter particles. For example, Beyeler et al. (1999) found that the RF decreases with particle 

diameter in the range of 1 to 5 microns. The distribution of particle size may also change with 

time as mechanical forces are applied. 

Although larger particles may be resuspended, gravitational settling removes them from the air 

more rapidly than smaller particles. Note also that particles larger than about 50 microns 

aerodynamic median activity diameter (AMAD) are readily cleared from the ET region and do 

not appreciably contribute to tissue dose in the respiratory tract (ICRP 1994a). Particles smaller 

than 50 μm AMAD comprise the “respirable fraction.” Nevertheless, larger particles can be 

important, because they can be measured as “removable” by wipe tests, leading to the erroneous 

conclusion that a higher fraction of resuspendable particles may be present that can actually 

contribute to dose. In this context, significant removable activity as larger particles may cause 

the RF to be underestimated (NUREG-1720). Since the RF is a ratio, the numerator is equivalent 

to the measured airborne concentration, whereas the denominator is set equal to the measured 

surface activity. 

SC&A’s review of the literature on indoor resuspension factors that can be considered 

appropriate for the resuspension of metal tritides is summarized in Table 18. The range of RFs 

cited in Table 18 is 2 E-8 m-1 to 4 E-3 m-1. The reported data are generally from (1) operating 

facilities; (2) facilities undergoing D&D; (3) facilities that have ceased operations, but have 

residual contamination on surfaces that was being resuspended due to worker activities; and 

(4) from experiments that examined resuspension of liquid- or powder-contaminated material 

that had been uniformly applied to clean surfaces in a laboratory-like setting. As best we can 

tell, the RFs cited in Table 18 were determined based on the total amount of radioactivity or dust 

on a surface and not the amount that is removable. This distinction is important, because if the 

starting point for driving airborne radioactivity by the use of RFs is swipe sample data (i.e., 

removable contamination), as is the case for the tritide data, the resuspension factors, as reported 

in Table 18, should be multiplied by an adjustment factor. As mentioned above, the NRC 

recommends using an adjustment factor of 5 to account for the difference between RFs based on 

removable versus total surface contamination. This would seem to imply that the range of RFs 

in Table 18 might require an adjustment factor of about 5 when applied to surface contamination 

reported in terms of removable contamination; i.e., the adjusted range of RFs would therefore be 

about E-7 m-1 to 2 E-2 m-1. 

The highest values are typically associated with inefficient ventilation, excessive mechanical 

disturbance, or dusty conditions. Typically, the purpose of these studies was to help determine 

radiation protection safety guidelines for loose residual surface radioactivity. 
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Table 18. Representative Reported Indoor Resuspension Data* 

Reference Resuspension factor or range Comments

Barns (1959) 4E-5 m-1 (confined space) 

2E-6 m-1 (open air) 

Reported for “dusty operations;” 10-5 m-1

recommended for most laboratory work. 

Breslin et al. (1966) About 3E-6 Based on average activities on surfaces and in air at a 

uranium processing plant during operations. 

Eisenbud et al. (1954) 1E-7 to 5E-7/m Based on average activity on surfaces and in air 

observed at an operating uranium and radium 

processing facility. 

Fish et al. (1967) 1.9E-4/m Based on experimental data where zinc sulfide and 

cupric sulfide powder (1–3 microns mass median 

diameter) was spread onto asphalt tile floors and 

painted drywall. Measurements made 10 minutes 

after sweeping the surfaces and without ventilation. 

Ikezawa (1980) Mean value of 1.8E-E-4/m 

during D&D activities 

Measurements made during the cleanup of a room 

after the accidental release of plutonium from a hot 

cell. 

Nardi (1999) Average RF of 1.7E-7/m 

during D&D 

Average values observed during the decontamination 

using shot-blasting of a room contaminated with 

Co-60 and Cs-137, and no ventilation. 

Ruhter and Zurliene (1988) 5.5E-8 to 1.1E-7/m Measurements made during the cleanup of the TMI 2 

Auxiliary Building 6 months after the accident. 

Spangler (1988) 4.25E-7 to 7.79E-6/m Uranium storage area during handling of containers. 

Stewart (1967) 1E-6 m-1 (quiescent 

conditions) 

1E-5–1E-4 m-1 (“operational” 

conditions) 

Based on a review of numerous outdoor experimental 

studies. The author believes these findings are 

generally applicable to indoor environments. The 

report indicates that excessively high particulate 

resuspension values indoors are likely to indicate 

some degree of inefficiency in the ventilation system. 

Glauberman et al. 1967 5E-5/m to 1E-2/m Measurements made at a uranium metals machining 

facility under a broad range of operations: (1) sources 

of air with and without contamination other than 

resuspension, (2) with and without operating building 

ventilation, (3) varying levels of surface disturbance. 

Brunskill (1967) 2E-4–4E-3 m-1 Numerous measurements in small rooms at Windscale 

(mixture of radionuclides) with various types of 

personnel movement, including introduction of loose 

contamination on coveralls. Lower recommended 

values were measured for a large area of “loose” 

contamination on concrete; “much smaller” values 

were found for linoleum floor. 

Jones and Pond (1967) 2E-8–5E-5 m-1

5E-5 m-1 (recommended for 

worst practical conditions) 

Results of extensive plutonium (oxide and nitrate) 

experimental studies performed indoors on a wide 

variety of surfaces. Estimated that 10%–20% of total 

airborne radioactivity was respirable. Suggested that 

recommended value could be an order of magnitude 

lower for average conditions. 

Dunster (1967) 2E-6–4E-5 m-1

2E-6 m-1 (recommended safe 

value for long-term use) 

Highest values from digging through dusty building 

rubble and in an enclosed and unventilated space. 
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Table 18. Representative Reported Indoor Resuspension Data* 

Reference Resuspension factor or range Comments

Spangler and Willis (1967) 4E-5 m-1 (derived) This value is calculated using equation for equilibrium 

airborne concentration in a small room from a surface 

concentration and recommended values appropriate 

for calculating 40-hr maximum permissible 

concentration (MPC) levels. The authors used 

published resuspension rates (hr-1), room sizes and 

ventilation rates to derive RFs. 

Healy (1971) 1E-3 to 1E-8/m (includes 

indoors and outdoors) 

Cites a wide range of values reported by other 

researchers. 

Gibson and Wrixom (1979) 2E-6–4E-5 m-1 Refers to studies performed by others. The lower 

value was used in original calculation of derived 

working limits (DWL) for active area surfaces and 

might be inappropriate for widespread contamination 

on dusty surfaces. The higher value was obtained 

from measurements in a confined space and is 

suggested for general use. 

IAEA (1970) 2E-6–3E-3 m-1

5E-5 m-1 (recommended) 

Recommended value is suggested as appropriate for 

general conditions of contamination on surfaces. 

Because of confounding factors, this effectively 

reduces the recommended value by 2.5 for use in 

calculating DWL values. 

Kennedy et al. (1981) 2.5E-5 m-1 (derived) This value is calculated using the equation for 

airborne concentration, assuming ventilation rate of an 

open transport truck and resuspension rate for a 28 m2

room. 

Kennedy and Strenge (1992) 1E-6 m-1 (recommended) Based on a review of resuspension literature. 

Recommended as a reasonably conservative default 

value to be applied to total surface concentration. 

IAEA (1992) 1E-6 m-1 (recommended) This value is recommended for use in assessing reuse 

of tools and equipment. Used a transfer factor of 0.01 

to account for the fraction of the residual surface 

radioactivity that is available for resuspension. 

Chen (1993) 1 E-6 m-1 No justification given (based on use in Kennedy and 

Strenge 1992).

Draft NUREG-1720 

(NRC 2002) 

Lognormal distribution with 

mean of 3.7 E-7 m-1 and 90th

percentile of 9.6 E-7 m-1

NRC staff analyzed literature and recent field data 

considering realistic assumptions about 

decommissioned facilities and building occupancy for 

the DandD code. Resuspension factor values best 

represent cleaned and aged surfaces. 

* Many of the reports cited in this table include a review of other reports and also the results of measurements and 

experiments performed by the authors. In many cases, large numbers of resuspension factors are cited for a broad 

range of operational, post-operational, D&D, and experimental conditions. SC&A selected the results that we 

believe best apply to the issues of interest to this report. 

 

The use of RFs near the high end is likely conservative (even when adjusted for removable 

contamination) based on consideration of the respirable fraction of resuspended contamination. 

In one of the few studies where particle size has been measured, Jones and Pond (1964) reported 

that measurements of air concentration were often biased by a few highly active large particles. 

In their study on resuspension of plutonium, they concluded that only 10% to 20% of the total 

airborne radioactivity would be respirable. In theory, this factor tends to counterbalance the 

adjustment needed to account for the removable fraction discussed above. 
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Another complicating factor is that the residual surface radioactivity is probably not uniform. 

Several studies (Dunster 1967; IAEA 1970; Healy 1971) discuss how this issue relates to 

resuspension values. Healy (1971) points out that in most cases, resuspension has been 

measured for uniformly contaminated surfaces and uniformly applied resuspension forces. 

Healy suggests that air concentrations are more strongly related to the total amount of surface 

contamination present, rather than the amount on any one limited area, and that basing allowable 

surface contamination limits on the highest surface levels may be too conservative. 

There are many other factors that contribute to the uncertainty in resuspension that are not 

addressed here because of lack of information. These include temperature, humidity, type and 

roughness of surface material, degree and effectiveness of mechanical disturbance, weathering 

processes, and the chemical state of the contamination and substrate to which it adheres. The 

effect of changes in many of these factors on resuspended air particle concentrations is intuitive 

(e.g., an increase in the size of the contaminated area would likely result in an increase in the 

resuspended air concentration); however, the degree and direction of the effect of other factors 

(e.g., specific surface conditions) is not so clear. 

Based on this relatively brief review of the literature, it is apparent that the variabilities and 

uncertainties in resuspension factors are enormous. In addition, one could raise questions 

regarding whether the data upon which the RFs in the reported literature apply to metal tritides 

(i.e., none of the data cited above are based on metal tritide measurements). Notwithstanding 

these issues, SC&A believes that, given adequate swipe sample data, the RF approach can be 

used to predict average annual airborne concentrations using swipe sample data. However, the 

value selected by NIOSH’s contractors of 5E-5/m should be increased by about a factor of 5 to 

2.5E-4/m to account for the fact that the starting point for this calculation is swipe data and not 

total surface contamination. In addition, we recommend that the RF approach be limited to time 

periods when there was no possibility of direct leakage of tritides to the atmosphere associated 

with tritide operations; i.e., an RF of 2.5E-4/m should be used only during the residual period. 

4.4 REVIEW OF DOSE CONVERSION FACTORS 

According to NIOSH 2012, dose conversion factors (DCFs) for use in deriving annual organ 

dose commitments from intakes of SMTs were calculated using the Integrated Modules for 

Bioassay Analysis (IMBA) code. IMBA was developed to meet the NIOSH requirements under 

EEOICPA, and implements the biokinetic models in International Commission on Radiological 

Protection (ICRP) Publications 68 (ICRP 1994b) and 71 (ICRP 1995). NIOSH uses guidance for 

calculating intake and dose from SMTs in ORAUT-OTIB-0066 (ORAUT 2007), which 

implements the recommendations for SMT aerosols in ICRP 1995. Because intakes were 

calculated based on air concentrations rather than urine bioassay, however, the modifications to 

the urine bioassay model discussed in ORAUT-OTIB-0066 were not necessary for this 

application. IMBA was used to generate a table of annual dose equivalents (rem) per unit 

activity intake [microcuries (μCi)] for Type S, 5-μm AMAD SMTs for 9 target organs. DCFs 

were calculated for the 9 organs from the respiratory and GI tracts that were projected to receive 

the highest total doses over an extended period (50 years). Table 19 lists the 9 organs and is 

taken from Table 4 of NIOSH (2012). According to NIOSH, the IMBA calculations can be 
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extended to any modeled organ or for any period. Table 5 of NIOSH 2012 provides annual 

DCFs for each of the 9 organs out to 50 years post-intake, as well as the 50-year CDE. 

Table 19. Target Organ Designations and Descriptions 

        Source: NIOSH 2012, Table 4 

Organ Description 

SI Small intestine 

ULI Upper large intestine 

LLI Lower large intestine 

ET Extrathoracic region 

Lung Lung 

Colon Colon 

LN(ET) Lymphatics and lymph nodes that drain the ET region 

AI Alveolar interstitial region 

LN(TH) Lymphatics and lymph nodes that drain the thoracic region 

As part of this review, SC&A attempted to replicate the NIOSH DCFs in units of rem per μCi 

inhaled for Type S, 5-μm AMAD SMTs for the 9 organs in Table 19, implementing ICRP 1994 

and 1995. SC&A used an ingestion absorption (f1) value of 0.01 for Type S tritiated particulates 

in adults, in accordance with Table 5.1.1b of ICRP Publication 71 (ICRP 1995). For this task, 

SC&A employed AIDE (Activity and Internal Dose Estimates, Version 7), a preferred code for 

calculating activities in compartments and committed doses due to occupational exposures, and 

for performing intake and dose estimates using bioassay data. AIDE Version 7 is used by ICRP 

and has several advantages over IMBA, including the option to select independent kinetics for 

parent-progeny relationships. Additionally, it has all the latest updates from ICRP and is the 

only software that has the National Council on Radiation Protection and Measurements (NCRP) 

wound model. Using AIDE, SC&A was able to replicate the NIOSH DCFs to within 99.4% and 

concludes that the NIOSH DCFs were developed correctly. The SC&A DCFs are presented in 

Table 20. In summary, we have no findings related to NIOSH’s development of the DCFs for 

use in deriving annual organ doses from intakes of SMTs. 

NOTICE:
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Table 20. Dose (rem) from 1 μCi Intake 

Year SI AIDE ULI AIDE LLI AIDE ET AIDE Lung AIDE Colon AIDE LN(ET)AIDE AI 

1 2.75E-05 1.65E-04 4.82E-04 8.30E-07 1.05E-03 3.01E-04 2.16E-04 3.2 4.22E-07 2.27E-06 6.55E-06 7.01E-07 6.64E-04 4.11E-06 5.12E-04 1.3 2.72E-07 1.45E-06 4.18E-06 7.89E-07 4.55E-04 2.62E-06 6.67E-04 1.4 1.76E-07 9.32E-07 2.68E-06 8.14E-07 3.19E-04 1.68E-06 7.34E-04 9.5 1.16E-07 6.02E-07 1.73E-06 8.02E-07 2.29E-04 1.09E-06 7.49E-04 6.6 7.67E-08 3.92E-07 1.12E-06 7.69E-07 1.69E-04 7.07E-07 7.33E-04 5.7 5.16E-08 2.58E-07 7.36E-07 7.25E-07 1.28E-04 4.63E-07 7.00E-04 3.8 3.54E-08 1.72E-07 4.88E-07 6.75E-07 9.91E-05 3.07E-07 6.58E-04 2.9 2.48E-08 1.16E-07 3.28E-07 6.25E-07 7.89E-05 2.07E-07 6.13E-04 2.

10 1.78E-08 8.00E-08 2.24E-07 5.76E-07 6.42E-05 1.42E-07 5.67E-04 1.11 1.31E-08 5.63E-08 1.56E-07 5.28E-07 5.31E-05 9.93E-08 5.22E-04 1.12 9.95E-09 4.06E-08 1.12E-07 4.84E-07 4.46E-05 7.12E-08 4.79E-04 1.13 7.76E-09 3.01E-08 8.21E-08 4.43E-07 3.80E-05 5.25E-08 4.38E-04 1.14 6.17E-09 2.29E-08 6.16E-08 4.04E-07 3.26E-05 3.95E-08 4.01E-04 9.15 5.02E-09 1.78E-08 4.75E-08 3.69E-07 2.81E-05 3.06E-08 3.66E-04 8.16 4.17E-09 1.42E-08 3.75E-08 3.37E-07 2.44E-05 2.42E-08 3.34E-04 7.17 3.51E-09 1.16E-08 3.02E-08 3.07E-07 2.13E-05 1.96E-08 3.05E-04 6.18 2.99E-09 9.57E-09 2.48E-08 2.80E-07 1.86E-05 1.61E-08 2.78E-04 5.19 2.57E-09 8.03E-09 2.06E-08 2.55E-07 1.63E-05 1.35E-08 2.54E-04 4.20 2.22E-09 6.80E-09 1.75E-08 2.33E-07 1.44E-05 1.14E-08 2.31E-04 4.21 1.93E-09 5.83E-09 1.48E-08 2.12E-07 1.26E-05 9.70E-09 2.11E-04 3.22 1.69E-09 5.00E-09 1.27E-08 1.93E-07 1.11E-05 8.31E-09 1.92E-04 3.23 1.48E-09 4.33E-09 1.10E-08 1.76E-07 9.80E-06 7.18E-09 1.75E-04 2.24 1.30E-09 3.75E-09 9.37E-09 1.61E-07 8.64E-06 6.17E-09 1.60E-04 2.25 1.15E-09 3.26E-09 8.19E-09 1.46E-07 7.63E-06 5.38E-09 1.46E-04 2.26 1.01E-09 2.86E-09 7.23E-09 1.33E-07 6.74E-06 4.74E-09 1.33E-04 1.27 8.90E-10 2.48E-09 6.14E-09 1.22E-07 5.96E-06 4.05E-09 1.21E-04 1.28 7.87E-10 2.18E-09 5.41E-09 1.11E-07 5.27E-06 3.57E-09 1.10E-04 1.
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Table 20. Dose (rem) from 1 μCi Intake 

Year SI AIDE ULI AIDE LLI AIDE ET AIDE Lung AIDE Colon AIDE LN(ET)AIDE AI 

NOTICE

wever, th

29 6.96E-10 1.91E-09 4.73E-09 1.01E-07 4.66E-06 3.12E-09 1.01E-04 1.30 6.14E-10 1.68E-09 4.09E-09 9.21E-08 4.12E-06 2.72E-09 9.17E-05 1.31 5.46E-10 1.47E-09 3.55E-09 8.39E-08 3.65E-06 2.36E-09 8.35E-05 1.32 4.86E-10 1.26E-09 3.18E-09 7.65E-08 3.23E-06 2.09E-09 7.62E-05 9.33 4.23E-10 1.14E-09 2.77E-09 6.97E-08 2.87E-06 1.84E-09 6.94E-05 8.34 3.81E-10 9.89E-10 2.32E-09 6.35E-08 2.54E-06 1.56E-09 6.33E-05 7.35 3.35E-10 8.64E-10 2.14E-09 5.79E-08 2.25E-06 1.41E-09 5.77E-05 6.36 2.98E-10 7.62E-10 1.86E-09 5.28E-08 2.00E-06 1.24E-09 5.26E-05 5.37 2.67E-10 6.59E-10 1.59E-09 4.81E-08 1.78E-06 1.06E-09 4.79E-05 5.38 2.36E-10 5.91E-10 1.41E-09 4.38E-08 1.58E-06 9.43E-10 4.37E-05 4.39 2.07E-10 5.23E-10 1.23E-09 4.00E-08 1.40E-06 8.26E-10 3.98E-05 3.40 1.88E-10 4.66E-10 1.05E-09 3.64E-08 1.25E-06 7.15E-10 3.63E-05 3.41 1.65E-10 3.98E-10 9.55E-10 3.32E-08 1.11E-06 6.37E-10 3.31E-05 3.42 1.45E-10 3.41E-10 8.64E-10 3.02E-08 9.87E-07 5.66E-10 3.01E-05 2.43 1.31E-10 3.07E-10 6.82E-10 2.76E-08 8.79E-07 4.68E-10 2.75E-05 2.44 1.19E-10 2.73E-10 6.37E-10 2.51E-08 7.83E-07 4.29E-10 2.50E-05 2.45 1.05E-10 2.39E-10 5.91E-10 2.29E-08 6.98E-07 3.90E-10 2.28E-05 1.46 9.38E-11 2.05E-10 4.55E-10 2.09E-08 6.22E-07 3.12E-10 2.08E-05 1.47 7.96E-11 2.05E-10 4.09E-10 1.90E-08 5.55E-07 2.93E-10 1.90E-05 1.48 7.39E-11 1.71E-10 3.64E-10 1.73E-08 4.96E-07 2.54E-10 1.73E-05 1.49 6.54E-11 1.36E-10 3.64E-10 1.58E-08 4.42E-07 2.34E-10 1.58E-05 1.50 6.25E-11 1.25E-10 2.73E-10 1.44E-08 3.95E-07 1.89E-10 1.44E-05 1.

SI AIDE ULI AIDE LLI AIDE ET AIDE Lung AIDE Colon AIDE LN(ET)AIDE AI 

CDE 2.88E-05 1.72E-04 5.01E-04 1.32E-05 3.65E-03 3.13E-04 1.20E-02 1.
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4.5 REVIEW OF ORIGINAL EXCEL SPREADSHEET 

This section presents a comprehensive review of the spreadsheet, “SMT exposures in R-108 SW8 10-6 in 1980s.xls,” which was presented and discussed at the November 7, 2011, work group 

meeting. Subsequent to that meeting, an additional spreadsheet was produced titled, “SMT 

exposures in R-108 SW-8 10-6 pre 1980.xls,” which complemented the NIOSH 2011a white 

paper analysis. This spreadsheet presented additional data and analysis for years prior to 1985. 

With the release of NIOSH 2012 in March of 2012, a third spreadsheet was produced which 

contained data for rooms SW-13 and SW-150 titled, “SW-13 SW-150 1960s-1990s 3-12.xls.” 

The two previous spreadsheets were also updated to reflect the changes in dose parameters 

presented in NIOSH 2012. 

Although this section focuses on the first spreadsheet produced, the subsequent calculation 

spreadsheets produced had the similar structure and analysis; many of the findings related to 

annual dose calculations are also applicable to these later spreadsheets. 

4.5.1 Sheet ‘CDE Summary’ 

Equation 2-3 presented the methodology used to calculate the annual dose from the monthly 

calculated tritide intake. Equation 2-3 assumes that there are sufficient swipe data to allow for 

tritide intakes to be calculated for every month of the year. Unfortunately, with the exception of 

1985 for both SW-8 and R-108, there are insufficient swipe data for some of the months. Thus, 

an adjustment to equation 2-3 is needed in order to calculate an annual dose using data from less 

than 12 months. Equation 4.5-1 is a proposed adjustment; it simply multiplies the sum of the 

tritide intakes for the months with swipe data by the ratio of 12 to the number of months with 

data. There are other adjustments that could be used, but equation 4.5-1 is used for this study. 

D = (4.5-1) 

Where: D = Annual tritide dose (mrem) 

DCF = Tritide inhalation dose factor (rem/μCi) 

1,000 = Conversion factor (mrem/rem) 

12 = Number of months in a year 

Nm = Number of months with swipe data 

Im = Tritide intake for month, m (μCi/month) 

Table 21 illustrates the effect that equation 4.5-1 would have on the NIOSH-calculated annual 

dose for LN(TH). The top third of Table 21 simply repeats the NIOSH-calculated annual 

LN(TH) CDE for 1985 through 1989 for SW-8 and R-108. The middle third of Table 21 shows 

the number of months for which swipe data are available and were used by NIOSH in the 

calculation of the annual dose. The bottom third of Table 21 shows the annual LN(TH) CDE for 

1985 through 1989 for SW-8 and R-108 revised using equation 4.5-1. 
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Table 21. Annual Dose Adjusted for the Number of Months with Swipe Data 

NIOSH Reported Dose LN(TH) CDE (mrem/yr) 

Years R-108 SW-8 

1985 64.1 103.7 

1986 34.6 53.4 

1987 0.0 116.8 

1988 38.7 40.2 

1989 45.9 36.4 

Number of Months with Swipe Data 

Years R-108 SW-8 

1985 12 12 

1986 5 5 

1987 0 8 

1988 6 6 

1989 6 6 

SC&A Adjusted Dose LN(TH) CDE (mrem/yr) 

Years R-108 SW-8 

1985 64.1 103.7 

1986 83.0 128.2 

1987 0.0 175.3 

1988 77.5 80.5 

1989 91.8 72.8 

4.5.2 Sheet ‘SRDB Search Summary’ 

The data contained in columns C and F of this sheet are incorrect. The correct data are given in 

columns U and AI of sheet ‘CDE Summary.’ Columns C and F of sheet ‘SRDB Search 

Summary’ should be changed to link back to columns U and AI of sheet ‘CDE Summary.’ 

However, since the data in columns C and F of sheet ‘SRDB Search Summary’ are only used to 

generate the chart shown on the sheet, this does not affect any of the results. 

4.5.3 Sheets ‘R108 1985,’ ‘R108 1986,’ ‘R108 1988,’ ‘R108 1989,’ ‘SW8 1985,’ 

‘SW8 1986,’ ‘SW8 1987,’ ‘SW8 1988,’ and ‘SW8 1989’ 

These sheets calculate the 95th percentile air concentration using the equations described in 

Section 3.0, and the data from sheets ‘Raw Data R-108’ and ‘Raw Data SW-8,’ described in 

Sections 4.1.2 and 4.1.5, and assuming a lognormal data distribution. Rather than check every 

calculation performed on each of these sheets, SC&A has used the Excel “Percentile” function 

and the data from sheets ‘Raw Data R-108’ and ‘Raw Data SW-8’ to calculate the 95th percentile 

air concentration. Rather than make any assumption regarding the form of the data distribution, 

the Excel “Percentile” function simply finds the datum that has 5% higher values and 95% lower 

values. Thus, it is not expected that the Excel “Percentile” function-calculated 95th percentile air 

concentrations would exactly match the NIOSH-calculated values using an assumed lognormal 

distribution, but agreement should be within a factor of 2. Any results that differ by more than a 
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factor of 2 would indicate that something was wrong with the 95th percentile air concentration 

calculation. 

Table 22 shows the results of this check. The top third of Table 22 simply reproduces the 

NIOSH-calculated 95th percentile air concentrations from the spreadsheets for both the SW-8 and 

R-108 rooms from 1985 to 1989. The middle third of Table 22 shows the 95th percentile air 

concentrations calculated using the Excel “Percentile” function, while the bottom third shows the 

ratio of the two derived air concentrations (NIOSH/Excel) as a function of percentage. 

Table 22. Check of 95th Percentile Air Concentration 

SW-8 NIOSH Calculated R-108 NIOSH Calculated 

1985 1986 1987 1988 1989 1985 1986 1988 1989 

Jan 1.75E-03 3.73E-03 3.33E-03 N.D. N.D. 5.19E-04 1.80E-03 N.D. N.D. 

Feb 2.02E-03 2.47E-03 5.26E-03 N.D. N.D. 1.36E-03 1.65E-03 N.D. N.D. 

Mar 2.01E-03 N.D. 4.23E-03 N.D. N.D. 1.28E-03 N.D. N.D. N.D. 

Apr 3.24E-03 4.31E-03 4.74E-03 N.D. N.D. 1.75E-03 2.62E-03 N.D. N.D. 

May 2.26E-03 1.70E-03 3.14E-03 N.D. N.D. 1.76E-03 1.96E-03 N.D. N.D. 

Jun 1.56E-03 2.57E-03 5.24E-03 N.D. N.D. 1.17E-03 1.54E-03 N.D. N.D. 

Jul 1.59E-03 N.D. 3.39E-03 1.65E-03 1.34E-03 1.19E-03 N.D. 1.84E-03 2.23E-03 

Aug 2.56E-03 N.D. 3.01E-03 4.48E-03 1.70E-03 1.98E-03 N.D. 2.42E-03 2.55E-03 

Sep 3.96E-03 N.D. N.D. 1.62E-03 1.21E-03 2.19E-03 N.D. 2.08E-03 1.24E-03 

Oct 3.04E-03 N.D. N.D. 1.42E-03 1.86E-03 1.89E-03 N.D. 1.54E-03 2.53E-03 

Nov 3.33E-03 N.D. N.D. 1.04E-03 1.63E-03 1.65E-03 N.D. 1.46E-03 2.02E-03 

Dec 1.37E-03 N.D. N.D. 9.12E-04 1.94E-03 9.98E-04 N.D. 1.36E-03 2.14E-03 

Total 2.87E-02 1.48E-02 3.23E-02 1.11E-02 9.67E-03 1.77E-02 9.57E-03 1.07E-02 1.27E-02 

SW-8 Excel Calculated R-108 Excel Calculated 

1985 1986 1987 1988 1989 1985 1986 1988 1989 

Jan 1.49E-03 2.74E-03 2.79E-03 N.D. N.D. 4.72E-04 1.25E-03 N.D. N.D. 

Feb 1.57E-03 2.12E-03 4.67E-03 N.D. N.D. 1.54E-03 1.08E-03 N.D. N.D. 

Mar 2.10E-03 N.D. 4.05E-03 N.D. N.D. 1.07E-03 N.D. N.D. N.D. 

Apr 2.95E-03 5.07E-03 4.58E-03 N.D. N.D. 1.48E-03 2.28E-03 N.D. N.D. 

May 1.88E-03 1.58E-03 3.25E-03 N.D. N.D. 1.44E-03 1.66E-03 N.D. N.D. 

Jun 1.50E-03 2.53E-03 4.55E-03 N.D. N.D. 9.66E-04 1.21E-03 N.D. N.D. 

Jul 1.54E-03 N.D. 3.69E-03 1.85E-03 1.26E-03 9.68E-04 N.D. 1.62E-03 2.13E-03 

Aug 2.77E-03 N.D. 3.17E-03 4.17E-03 1.64E-03 1.81E-03 N.D. 1.99E-03 2.68E-03 

Sep 3.86E-03 N.D. N.D. 1.83E-03 1.31E-03 2.39E-03 N.D. 1.71E-03 1.25E-03 

Oct 2.95E-03 N.D. N.D. 1.44E-03 1.78E-03 1.69E-03 N.D. 1.73E-03 2.99E-03 

Nov 2.78E-03 N.D. N.D. 1.02E-03 1.30E-03 1.26E-03 N.D. 1.15E-03 1.87E-03 

Dec 1.21E-03 N.D. N.D. 7.47E-04 1.29E-03 8.78E-04 N.D. 1.01E-03 1.81E-03 

Total 2.66E-02 1.40E-02 3.08E-02 1.11E-02 8.58E-03 1.60E-02 7.47E-03 9.22E-03 1.27E-02 
Effective Date: 

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Table 22. Check of 95th Percentile Air Concentration 

SW-8 NIOSH to Excel Ratio R-108 NIOSH to Excel Ratio 

1985 1986 1987 1988 1989 1985 1986 1988 1989 

Jan 117% 136% 119% N.D. N.D. 110% 144% N.D. N.D. 

Feb 129% 116% 112% N.D. N.D. 88% 152% N.D. N.D. 

Mar 96% N.D. 104% N.D. N.D. 120% N.D. N.D. N.D. 

Apr 110% 85% 103% N.D. N.D. 118% 115% N.D. N.D. 

May 120% 108% 97% N.D. N.D. 122% 118% N.D. N.D. 

Jun 104% 102% 115% N.D. N.D. 121% 128% N.D. N.D. 

Jul 103% N.D. 92% 89% 106% 123% N.D. 114% 105% 

Aug 93% N.D. 95% 107% 103% 110% N.D. 122% 95% 

Sep 102% N.D. N.D. 88% 92% 92% N.D. 122% 100% 

Oct 103% N.D. N.D. 99% 104% 112% N.D. 89% 85% 

Nov 120% N.D. N.D. 102% 125% 130% N.D. 127% 108% 

Dec 113% N.D. N.D. 122% 151% 114% N.D. 134% 118% 

Total 108% 105% 105% 101% 113% 111% 128% 116% 100% 
Effective Date: 

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5.0 EVALUATION OF VARIABLES AND UNCERTAINTIES USED ON 

MOUND LABORATORY SMT DOSE ESTIMATIONS 

5.1 INTRODUCTION 

While NIOSH’s first white paper (NIOSH 2011a) presents an upper limit to the potential organ 

dose from SMT at the ML, the second white paper (NIOSH 2012) presents what NIOSH 

considers a best-estimate approach. The two papers obviously derive results that are very 

different (i.e., several hundred mrem to the maximally exposed organ [LN(TH)] in the first paper 

and about 1 mrem to the lung in the second paper, a difference of 2 orders of magnitude). 

Therefore, SC&A was concerned with the dependence of the results obtained on the 

parameters/variables selected in deriving the estimated doses from SMT at the ML. To address 

this issue, SC&A performed a brief qualitative evaluation of the impact of selecting certain 

parameter/variable values out of a range of values for use in deriving estimated doses from SMT 

at the ML. This analysis does not include uncertainties in the stated values, such as count rates, 

constants, statistical analyses, etc., as these would be secondary to the wide range of possible 

values for the major parameters evaluated here. 

5.2 SC&A’S EVALUATION OF PARAMETERS/VARIABLES USED IN 

ESTIMATING SMT DOSES 

Annual Organ Dose Estimate

The basic equation used for deriving the estimated annual SMT dose is provided on page 3 of 

NIOSH 2011a and page 12 of NIOSH 2012: 

where: 

D is the internal organ annual dose (mrem/y); CPC-5 is the contamination swipe 

data as counted by a PC-5 proportional counter (cpm/100 cm2); EffPC-5 is the 

counter efficiency (cpm/dpm); CF is the conversion factor equal to 4.505 × 10-7

μCi/dpm; the constant, 100, converts 100 cm2

 to m2; RF is the resuspension factor 

defined as the ratio between the airborne concentration of a pollutant per cubic 

meter directly over a contaminated surface and the areal pollutant surface 

contamination (m-1); Br is the worker’s breathing rate equal to 1.2 m3

/hr (ICRP 

1994a); T is the exposure time equal to 2,000 working hr/yr; and DCF is the dose 

conversion factor for Type S, 5-μm activity median aerodynamic diameter 

(AMAD) SMT for the target organ (mrem/μCi). 

As can be seen from analyzing this equation, the resulting annual dose depends linearly, either 

proportionally or inversely proportionally, on several variables; the rest of the components are 

simply standard conversion factors. The items of interest for this evaluation are listed below. 

Also listed is the possible range of their values that will be considered. 
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1. Cpc-5 – per 100 cm2 – The recorded count rate (cpm) of the counter used to count the 

tritium swipes, with the assumption that an area of 100 cm2 was swiped using a consistent 

method. However, the persons swiping the surface may vary their area/pressure, and the 

swipes obtained may not be representative of the wider area of concern. Therefore, a 

reasonable assumption is that these variations could cause the results to change by a 

factor of 2 less up to a factor of 2 greater than normal during the routine activity of taking 

many swipes over time; hence, the recorded results (normalized to a preset pressure and 

100 cm2) may be a factor of 0.5x or 2.0x the true value. 

2. Effpc-5 – The efficiency of the PC-5 counter (dpm/cpm). NIOSH determined this factor 

by comparing 292 swipe values that were counted at ML using both the PC-5 counter and 

the liquid scintillation counter (LSC), and incorporates an average energy self-absorption 

factor (SAFe) for the LSC activity determination. As shown in Figure A-13, page 29, of 

NIOSH 2012, this variable has a range of 0.001 to 0.05, with a mean value of 0.011 and a 

GSD of 2.2 (NIOSH used a rounded value of 1% in their dose estimates). A reasonable 

range for this variable would be to use the GSD of 2.2, which would result in an 

efficiency range of 0.005% to 2.2%. 

3. RF – The Resuspension Factor defined as the ratio between the airborne concentration of 

a pollutant per cubic meter directly over a contaminated surface and the areal pollutant 

surface contamination (unit = m-1). This variable could have a wide range of values; 

from 1E-6/m recommended by the NRC (NIOSH 2012, page 30), to 5E-5/m used by 

NIOSH in the second paper (NIOSH 2012), to 3E-3/m used by NIOSH in the first paper 

(NIOSH 2011a). However, the variance of this parameter in a given situation (e.g., in a 

given room over a 1-year time period) would most likely not vary throughout this large 

range, but instead vary about a mean value. Considering the discussion in Section 4.3 of 

this report concerning the use of the RF factor, a reasonable range would be a factor of 5 

below and a factor of 5 above the value recommend by NIOSH of 5E-5/m (NIOSH 

2012). 

4. Br - Worker’s breathing rate of 1.2 m3

/hr. This value is fairly constant and could vary 

between 1.0 m3

/hr to 1.25 m3/hr. NIOSH used a value of 1.2 m3/hr in the SMT dose 

estimations. 

5. T - Exposure time of 2,000 working hr/yr. These values could range from 40 hr/wk at 

50 wk/y (2,000 hr/y) at the lower end to 50 hr/wk at 52 wk/y (2,600 hr/y) at the upper end 

for workers constantly exposed. 

6. DCF - Dose Conversion Factor for Type S, 5-μm AMAD SMT for the target organ in 

units of mrem/μCi. Although NIOSH assumes an AMAD of 5 μm, the DCF is highly 

dependent on the particle size. Table E.5-11 of DOE (2008, pdf pg. 195) demonstrates 

that the DCFs for a given SMT compound can vary by about a factor of 10 over a range 

of particles sizes of 0.5 to 10 μm AMAD. Based on Table E.5-11 of DOE 2008, and the 

discussion in Section 6.0 of this report, it can be assumed that an adjustment factor could 

range from 0.2x to 5x the median value. 
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These are the items of most interest in this evaluation and are those that could have different 

values, depending on the values selected by the person performing the dose estimate. Table 23 

provides a summary of these items, their possible range of values, and their potential impact on 

the resulting estimated SMT dose. 

Table 23. SMT Dose Parameters and Ranges 

Parameter Dependence Lower 

Value 

NIOSH 

2012 Value 

Upper 

Value 

Impact on Resulting 

Dose Value 

Cpc-5 factor Inversely Prop 2.0 1.0 0.5 0.5x to 2.0x 

Effpc-5 Inversely Prop. 0.022 0.01 0.005 0.46x to 2.2x 

RF Proportional 1E-05/m 5E-5/m 2.5E-04/m 0.2x to 5.0x 

Br Proportional 1.00 m3

/hr 1.2 m3hr 1.25 m3/hr 0.83x to 1.04x 

T Proportional 2000 hr/y 2000 hr/y 2600 hr/y 1.0x to 1.30x 

DCF adj. Proportional 0.2 1.0 5 0.2x to 5.0x

Total impact using lower and upper values = 0.008x to 149x 

Total impact using lower and upper values w/constant RF or DCF = 0.04x to 30x 

 

Committed Organ Dose Estimate

NIOSH’s Case Study – NIOSH used a case study (see pages 5–6 of NIOSH 2012) to illustrate 

the committed organ dose to the lung, one of the organs that receive the greater dose from SMT. 

This case study consisted of a 2-year exposure period using the larger of the potential SMT 

intakes (both location and years) and deriving the committed organ dose after a 10-year latent 

period. The 95th and 50th percentile annual doses (for 50 years) are listed in Table 6, pages 38–

39, and are summarized for a 10-year latent period in Table 1, page 6, of NIOSH 2012. For the 

lung, the maximum (Room SW-8) committed dose for a 2-year exposure and 10-year latent 

period was 0.48 mrem at the 95th percentile level and 0.12 mrem at the 50th percentile level. 

(Note: The text on page 2 of NIOSH 2012 that states, “The bounding and best estimate annual

dose equivalents to the lung associated with intakes of the SMT are 0.48 mrem and 0.12 mrem, 

respectively” appears to be incorrect in that it should read “committed” instead of “annual” 

according to Table 1, page 6 of NIOSH 2012). 

Changes in Exposure Period – Changes in the exposure period would change the committed dose 

to an organ approximately as a linear function for a given intake scenario (derived 95th percentile 

concentration for a room/year combination). In other words, if the exposure period was 1 year 

instead of 2 years, the dose would be approximately one-half the stated dose; if the exposure was 

4 years instead of 2 years, the dose would be approximately twice the stated dose. 

Changes in Latent Period – Changes in the latent period would have a smaller impact on the 

committed dose; i.e., a shorter latent period would decrease the committed dose, and a longer 

latent period would increase the committed dose, but not substantially. The annual organ dose 

values decrease steadily as a function of time (as illustrated in the vertical column of Table 6, 

page 38, of NIOSH 2012; therefore, an additional 10-year latent period does not add an equal 

amount of committed dose. 
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This qualitative analysis of the impact of exposure and latent periods on SMT doses will be 

further evaluated quantitatively in the next section. 

5.3 SC&A’S EVALUATION OF VARIABILITY IN THE DERIVED CASE STUDY 

DOSE BASED ON EXPOSURE DURATION AND LATENCY TIME AFTER THE 

EXPOSURE 

NIOSH 2012 presented a case study example that calculated the lung dose to a worker 10 years 

after a 2-year exposure. The intakes for the 2-year exposure were based on the years with the 

highest observed contamination by room. Of the four rooms with data compiled by NIOSH, 

room SW-150 had the highest observed contamination values. These derived doses14 for all the 

target organs identified in NIOSH 2012 are shown in Table 24. It is worth noting that the “lung” 

dose was not the limiting target organ in the case study example, but rather “Al,” the 

alveolar/interstitial region of the lung, at approximately 93 mrem. The dose to the lower large 

intestine (LLI) was also higher than the derived lung dose. 

Table 24. Calculated Doses based on NIOSH Case Study for Room SW-150 

Target Organ 95th Percentile 

Dose (mrem) 

50th Percentile 

Dose (mrem) 

Lung 3.721 0.951 

SI 0.27 0.07 

ULI 1.58 0.41 

LLI 4.63 1.19 

ET 0.07 0.02 

Colon 2.90 0.74 

LN(ET) 64.30 16.47 

Al 92.88 23.80 

LN(TH) 82.19 21.05 

In order to quantify the variability in the derived doses based on the case study example, SC&A 

performed similar calculations while varying the exposure duration and latency time after the 

exposure. Similar to the NIOSH case study example, the years with the highest 

contamination/intake values were used for each exposure duration example. The results for the 

calculated lung dose are shown in Table 25 which presents the respective dose values along with 

the ratio to the original case study value (shown in parenthesis). As seen in Table 25, the lung 

dose increases by as much as a factor of 4 if the exposure duration and latency time for the case 

study were increased to 10 years and 20 years, respectively. 

 14 Note: the lung dose values in Table 24 for SW-150 differ from the values presented in NIOSH 2012 

Table 1 due to an error in the original calculation that did not extrapolate intakes to a full year. The doses presented 

in Table 1 have been extrapolated to a full year of exposure. Refer to Section 4.1.5 for further discussion.
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Table 25. Calculated Lung Dose (mrem) as a Function of Exposure Duration and 

Latency Time for Room SW-150 

(Ratio with base case shown in parenthesis) 

Exposure Duration in Years Intake 

Percentile 

Years of 

Latency 

After 

Exposure 2 3 5 10 

10 3.72* (1.00) 5.58 (1.50) 8.66 (2.33) 14.43 (3.88) 

95 15 3.90 (1.05) 5.90 (1.58) 9.06 (2.43) 14.87 (4.00) th 

20 3.98 (1.07) 5.94 (1.60) 9.15 (2.46) 14.99 (4.03) 

10 0.95* (1.00) 1.39 (1.45) 2.08 (2.18) 3.45 (3.62) 

50 15 1.00 (1.05) 1.44 (1.52) 2.16 (2.26) 3.54 (3.71) th 

20 1.02 (1.07) 1.47 (1.55) 2.19 (2.30) 3.59 (3.76) 

*NIOSH base case values 

Tables 26 and 27 present the ratio of the calculated dose for the remaining organs versus the 

NIOSH case study example. Table 26 presents the ratio of doses based on the 95th percentile 

intake values, and Table 27 is based on the 50th percentile intake values. 

Table 26. Ratio of Remaining Target Organ Doses to NIOSH Base Case 

Values by Exposure Duration and Latency after Exposure based on 95th

Percentile Contamination 

Years of Latency Exposure Duration in Years 

After Exposure Target Organ 2 3 5 10 

S. I. 1.00* 1.49 2.29 3.73 

U. L. I. 1.00* 1.49 2.29 3.73 

L. L. I. 1.00* 1.49 2.29 3.73 

E. T. 1.00* 1.53 2.50 4.57 

Colon 1.00* 1.49 2.29 3.73 

LN(ET) 1.00* 1.54 2.52 4.66 

Al 1.00* 1.50 2.33 3.87 

10 

LN(TH) 1.00* 1.54 2.55 4.85 

S. I. 1.00 1.49 2.29 3.73 

U. L. I. 1.00 1.49 2.29 3.73 

L. L. I. 1.00 1.49 2.29 3.73 

E. T. 1.25 1.89 3.00 5.20 

Colon 1.00 1.49 2.29 3.73 

LN(ET) 1.28 1.94 3.07 5.35 

Al 1.05 1.56 2.41 3.97 

15 

LN(TH) 1.33 2.03 3.24 5.78 
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Table 26. Ratio of Remaining Target Organ Doses to NIOSH Base Case 

Values by Exposure Duration and Latency after Exposure based on 95th

Percentile Contamination 

Years of Latency Exposure Duration in Years 

After Exposure Target Organ 2 3 5 10 

S. I. 1.00 1.49 2.29 3.73 

U. L. I. 1.00 1.49 2.29 3.73 

L. L. I. 1.00 1.49 2.29 3.73 

E. T. 1.41 2.12 3.31 5.60 

Colon 1.00 1.49 2.29 3.73 

LN(ET) 1.46 2.19 3.42 5.79 

Al 1.07 1.59 2.45 4.02 

20 

LN(TH) 1.57 2.37 3.74 6.43 

*NIOSH base case values 

Table 27. Ratio of Remaining Target Organ Doses to NIOSH Base Case Values by 

Exposure Duration and Latency after Exposure based on 50th Percentile Contamination 

Years of Latency Exposure Duration in Years 

After Exposure 

Target 

Organ 2 3 5 10 

S. I. 1.00* 1.44 2.14 3.48 

U. L. I. 1.00* 1.44 2.14 3.48 

L. L. I. 1.00* 1.44 2.14 3.48 

E. T. 1.00* 1.49 2.35 4.27 

Colon 1.00* 1.44 2.14 3.48 

LN(ET) 1.00* 1.49 2.37 4.35 

Al 1.00* 1.45 2.18 3.62 

10 

LN(TH) 1.00* 1.50 2.40 4.54 

S. I. 1.00 1.44 2.14 3.48 

U. L. I. 1.00 1.44 2.14 3.48 

L. L. I. 1.00 1.44 2.14 3.48 

E. T. 1.25 1.84 2.81 4.86 

Colon 1.00 1.44 2.14 3.48 

LN(ET) 1.28 1.88 2.88 5.01 

Al 1.05 1.51 2.26 3.71 

15 

LN(TH) 1.33 1.97 3.04 5.40 

S. I. 1.00 1.45 2.14 3.49 

U. L. I. 1.00 1.44 2.14 3.48 

L. L. I. 1.00 1.44 2.14 3.48 

E. T. 1.41 2.06 3.11 5.23 

Colon 1.00 1.44 2.14 3.48 

LN(ET) 1.46 2.12 3.21 5.42 

Al 1.07 1.54 2.30 3.76 

20 

LN(TH) 1.58 2.30 3.51 6.01 

*NIOSH base case values 
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5.4 SUMMARY 

As can be seen from Table 23, the impact on the estimated SMT annual dose is most pronounced 

by the choice of the value of the resuspension factor and the DCF (which is dependent on the 

AMAD value selected). The selected values of the other parameters have a lesser impact on the 

estimated SMT annual dose. While SC&A does not advocate that all the parameters would be at 

one extreme or the other at the same time (or that the results need to be adjusted accordingly), 

this qualitative analysis illustrates that the resulting estimated SMT annual dose can vary by 

several orders of magnitude, depending on the values of the parameters selected, while using a 

model that has no site-specific or source term characterization data to bench-mark the results. 

When considering committed dose to an organ (as NIOSH did in their 2-year exposure and 

10-year latent period case study to illustrate that the committed lung dose was projected to be 

less than 1 mrem), an increase or decrease in the exposure time would increase or decrease the 

corresponding committed dose somewhat linearly, as illustrated in Tables 25 through 27 above; 

and a longer or shorter latent period would not generally have a large impact on the committed 

dose after the initial 5 to 10 years of a latent period. However, the important issue is that, as 

shown in Table 24 above, the lung (which NIOSH used in their 2012 paper) is not the organ that 

receives the greater dose from SMTs; the LLI, LN(ET), LN(TH), and Al all receive greater 

doses. 
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6.0 COMPARISON BETWEEN NIOSH AND DOE DOSE ESTIMATION 

METHODS FOR STCS 

6.1 PURPOSE 

The purpose of this section is to present a comparison between the methods to evaluate lung dose 

for “Insoluble Tritiated Particles” (ITP) presented in Doe Handbook – Tritium Handling and 

Safe Storage (DOE 2008) and the current NIOSH white paper, Potential Stable Metal Tritide 

Exposures at the Mound Laboratory (NIOSH 2012). Of particular focus is the characterization 

of dose to tissues of the respiratory tract (i.e., lung dose) in the context of the effect of self 

absorption on both the measurement technique and the radiation dose delivered to the lung. 

Comparison of the respective intake models will not be discussed, as both methods rely on 

adequate characterization of the airborne contamination. DOE 2008 relies on adequate direct air 

sampling (preferably breathing zone sampling) during operations with insoluble tritiated 

compounds. NIOSH 2012 relies on a resuspension model based on area surface contamination 

as measured by swipe data. Air monitoring for insoluble tritiated particles is not available for 

Mound during the period of interest; therefore, intake values derived from the resuspension of 

surface contamination are necessitated. 

6.2 COMPARISON OF DOE 2008 INSOLUBLE TRITIATED PARTICLE DOSE 

CHARACTERIZATION 

Self absorption occurs when the low-energy beta emissions from tritium deposit all of their 

energy within the particle and are not able to escape the particle surface. Self absorption of low 

energy beta emissions (nominally 6 keV) in particulate tritides affects both the ability to measure 

the contamination present in the particle and the amount of radiation dose that can be delivered 

to the lung from the particle. 

DOE 2008 presents adjustment factors, or “self absorption factors” (SAF), that can be used to 

adjust for the dose delivered to the lung, as well as adjustment to counting results. The most 

common detection system employed in tritium measurement is liquid scintillation counting 

(LSC). These two correction factors are labeled as the SAFe (adjustment to account for the 

fraction of energy available to impart dose to the lung) and SAFβ (adjustment to account for the 

fraction of betas emitted that escape the particle surface and are counted in the LSC system) and 

are derived based on the methods described in Kropf 1998. Self absorption of tritium beta 

emissions in ITP is strongly correlated with particle size. Self-absorption factors (SAFs) vary as 

a function of respirable (<10 m AMAD) particulate size and material by a factor of 

approximately 10. 

These two correction factors SAFe and SAFβ are shown in Tables 28 and 29, respectively, for 

selected ITP compounds, and are used in DOE 2008 to adjust the DCFs applied in a typical 

effective dose calculation. Unadjusted committed equivalent lung DCFs for the example ITP 

compounds are presented in Table 30. 
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Table 28. SAFe Various ITP Materials and Polydisperse (σg = 2.5) 

Particle Size Distributions (in AMAD) 

SAFe vs. Particle Size [AMAD(m), σg=2.5] Base Material* 

10 5 2 1 0.5 

Organic [(CH2)n] 0.305 0.474 0.707 0.841 0.925 

Rust [FeO(OH)] 0.231 0.381 0.614 0.768 0.879 

Ti H2 0.215 0.362 0.594 0.753 0.871 

Zr H2 0.180 0.312 0.541 0.714 0.852 

Hf H2 0.142 0.260 0.490 0.680 0.842 

* Variable amounts of elemental hydrogen are isotopically tritium. 

Source: DOE 2008, Table E.5-9 

Table 29. SAFβ for Various ITP Materials and Polydisperse (σg = 2.5) 

Particle Size Distributions (in AMAD) 

SAF vs. Particle Size [AMAD(m), g=2.5] Base Material* 

10 5 2 1 0.5 

Organic [(CH2)n] 0.205 0.333 0.535 0.677 0.789 

Rust [FeO(OH)] 0.140 0.244 0.439 0.602 0.745 

Ti H2 0.133 0.231 0.423 0.590 0.739 

Zr H2 0.104 0.191 0.380 0.555 0.719 

Hf H2 0.077 0.154 0.343 0.529 0.707 

* Variable amounts of elemental hydrogen are isotopically tritium. 

Source: DOE 2008, Table E.5-10 

Table 30. Unadjusted Lung Committed Equivalent Dose DCFs (Sv/Bq) for Various 

ITPs and Particle Sizes (AMAD, σg = 2.5), Absorption Type S Assumed 

Lung DCF vs. Particle Size [AMAD (m), σg = 2.5] Base Material* 

10 5 2 1 0.5 

Organic [(CH2)n] 4.50 × 10-10 9.90 × 10-10 1.65 × 10-9 1.74 × 10-9 1.64 × 10-9

Rust [FeO(OH)] 4.51 × 10-10 1.00 × 10-9 1.71 × 10-9 1.98 × 10-9 2.29 × 10-9

Ti H2 4.51 × 10-10 1.00 × 10-9 1.74 × 10-9 2.07 × 10-9 2.52 × 10-9

Zr H2 4.53 × 10-10 1.01 × 10-9 1.81 × 10-9 2.30 × 10-9 3.07 × 10-9

Hf H2 4.56 × 10-10 1.03 × 10-9 1.94 × 10-9 2.70 × 10-9 3.87 × 10-9

* Variable amounts of elemental hydrogen are isotopically tritium. 

** DCF values calculated in DOE 2008 using the LuDEP software (NRPB 1999) which make no 

adjustment for self absorption. 

Source: DOE 2008, Table E.5-11 

A DCF adjusted for self absorption in the lung can be obtained simply by multiplying the 

committed dose equivalent DCFlung shown in Table 30 by the SAFe shown in Table 28. These 

adjustments to the DCF due to self absorption in the lung are displayed in Table 31. The DCFs 

developed for 5 AMAD particles are highlighted for comparison with the NIOSH-developed 

DCF values for a similar sized particle, as described below. 
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The approach described in NIOSH 2012 also accounts for self absorption as it affects 

measurement results and lung dose, though NIOSH relies exclusively on an energy correction 

factor (SAFee), as indicated on page 24 of NIOSH 2012: 

The SAFe is a better quantity for correction of LS counting efficiency because 

almost any amount of beta energy deposited in the LS cocktail will result in a 

count being recorded in the tritium “window.” The SAFe is also appropriate for 

dosimetry calculations because almost any amount of ionization from a beta 

decay that reaches living tissue can impart dose. 

NIOSH accounts for the effect of self absorption on measurements by deriving a detector 

efficiency that incorporates an LSC energy self absorption correction factor (SAFe). The 

detector efficiency distribution is described by a lognormal distribution with a geometric mean 

(GM) of 0.011 and a geometric standard deviation (GSD) of 2.2 and is applied to the 95th

percentile swipe count rates to yield an estimate of total activity intake in accordance with 

Equation A-1 of NIOSH 2012. 

NIOSH accounts for the effect of self absorption on lung dose by applying the GM of their SAFe 

distribution (0.12) to the lung DCF (NIOSH 2012, Table A-4). Equation A-8 of NIOSH 2012 is 

used to derive SAFe; the SAFe distribution is depicted in Figure A-10 of that document. The 

adjusted 50-year DCF for the lung in Table A-4 is 4.41 × 10-4 rem/μCi (1.19 × 10-10 Sv/Bq). A 

comparison of the lung DCF values in Table A-4 of NIOSH 2012 to those presented in NIOSH 

2011a confirms that the 2012 values were adjusted as stated. For example, the 50-year DCF for 

the lung in NIOSH 2011a is 3.68 × 10-3 rem/μCi. Multiplying this value by 0.12 yields the 

adjusted 50-year value of 4.41 × 10-4 rem/μCi from Table A-4. 

The values in Table 31 do not address the self absorption effect on the detector. It is important to 

remember that for comparison with the NIOSH 2012 method, the values in Table 31 would be 

used in conjunction with the “total activity” of tritium in the source particles, so adjustments 

would have to be made to account for self absorption in the measurement of the contamination. 

In NIOSH 2012, the detector efficiency is estimated to be 1% (0.011) to account for the self 

absorption effect in LSC measurement. Thus, the derived DCF values in Table 31 can be 

directly compared to the 50-year lung DCF value in Table A-4 of NIOSH 2012 [1.19 × 

10-10 Sv/Bq (4.41 × 10-4 rem/μCi)]. 

Table 31. Lung Committed Equivalent Dose DCFs (Sv/Bq) for Various ITPs and 

Particle Sizes (AMAD, σg = 2.5), Absorption Type S Assumed with 

SAFe Corrections Applied 

Lung DCF (w/ SAFe) vs. Particle Size [AMAD (m), σg = 2.5] Base Material* 

10 5 2 1 0.5 

Organic [(CH2)n] 1.37 × 10-10 4.69 × 10-10 1.17 × 10-09 1.46 × 10-09 1.52 × 10-09

Rust [FeO(OH)] 1.04 × 10-10 3.81 × 10-10 1.05 × 10-09 1.52 × 10-09 2.01 × 10-09

Ti H2 9.70 × 10-11 3.62 × 10-10 1.03 × 10-09 1.56 × 10-09 2.19 × 10-09

Zr H2 8.15 × 10-11 3.15 × 10-10 9.79 × 10-10 1.64 × 10-09 2.62 × 10-09

Hf H2 6.48 × 10-11 2.68 × 10-10 9.51 × 10-10 1.84 × 10-09 3.26 × 10-09

 * Variable amounts of elemental hydrogen are isotopically tritium.
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 (0.26/0.12). 

As can be seen, the adjusted lung DCF value used in NIOSH 2012 is bounded by the 

corresponding DCF for HfH2 developed for 5μm AMAD ITPs in DOE 2008. The ratio of the 

DOE to NIOSH values for HfH2 is 2.25 and is largely explained by the ratio of the 

corresponding SAFe values derived for each

At this point, there is a major divergence in the DOE and NIOSH approaches as applied to dose 

assessment. It is important to note that the approach taken in DOE 2008 is applied to effective 

dose (E50), while the NIOSH approach is concerned with equivalent organ dose. 

The effective dose (E) introduced in ICRP Publication 60 (ICRP 1991) is defined by a weighted 

sum of tissue equivalent doses: 

where wT is the tissue weighting factor for tissue T and Σ wT = 1. The sum is performed over all 

organs and tissues of the human body considered to be sensitive to the induction of stochastic 

effects. These wT values are chosen to represent the contributions of individual organs and 

tissues to overall radiation detriment from stochastic effects. DOE accounts for the combined 

effects of self absorption on measurement (observed activity) and lung dose from particulates in 

their effective dose DCFs (Table E.5-14 of DOE 2008). In contrast, to fulfill the requirements of 

EEOICPA, the NIOSH approach addresses individual annual organ doses summed from the 

onset of intake through the date of cancer diagnosis. Thus only the lung DCF is adjusted for 

SAFe in the NIOSH model; the effects of self absorption on measurement results are treated at 

the “front end” in equation A-1 to yield total activity intake to be applied to all organs and tissues 

of concern.

It is important to note that DOE 2008 concludes that using observed measurements of 

contamination rather than “actual activity” may be preferable in evaluating lung doses because of 

the lower variability in DCFs relative to particle size. Specifically, DOE 2008 states: 

Table [6] data indicate that the E50 DCFos, based on “observed” activity of ITPs 

of absorption type S, are less dependent on particle size than are the E50 DCFs, 

based on “actual” activity, from Table [5]. The assumption of a single particle 

size distribution would result in much smaller errors than noted above; for 

example, when using “observed” activity, E50 DCFs vary only by a factor of 

about 5 for particles ranging in sizes from 0.5 to 10 m AMAD. Compare this 

with a factor of 25 when using “actual” activity. 

... 

As noted above, the variability of E50 DCFo with material or particle size is not 

great (range is factor of 5). Therefore, using a conservative assumption of 

material and particle size distribution (5 m AMAD) is accurate within that 

factor for any material or particle size distribution; this assumption can be 

readily implemented when air monitoring is the method of intake assessment. A 

factor of dose overestimation (~ 2–10) is further applied when all captured 

tritiated particulates are assumed to be absorption type S and are measured by 

LSC. (DOE 2008, pp. 197 and 199) 
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6.3 CONCLUSION 

The DOE 2008 approach provides a methodology for quantifying effective dose from intakes of 

ITPs, whether the intake is based on the “observed activity” present in the original measurement 

or the “actual activity” present in the contamination. DOE 2008 concludes that a preferable 

method for calculating effective dose is to use the observed activity along with an appropriately 

modified DCF. NIOSH has adopted an approach in which the “actual activity” is quantified, and 

then the lung dose DCF is adjusted to account for reduced irradiation of respiratory tract tissues 

due to particulate self absorption. This is understandable, given the requirements under 

EEOICPA to calculate dose to organs and tissues associated with specified cancers, many of 

which are not affected by self absorption. It is noteworthy that the SAFe derived in NIOSH 2012 

yields lower doses to the lung than the method presented in DOE 2008 by a factor of 

approximately 0.45. 
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Page No. 

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

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

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

NOTICE:

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ATTACHMENT 1: EXTRAPOLATION OF INTAKES ASSUMING A FULL YEAR O

Room R-108 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action 

Jun–Aug 141 6.54E-03 1.31E+00 3.92E+00 Multiply original intake by 3 Sep–Dec 186 3.24E-03 6.48E-01 2.59E+00 Multiply original intake by 4 

Remaining Months N/A N/A N/A 4.66E+00 Average intakes from June to 

to account for missing month

Annual Totals N/A N/A 1.96E+00 1.12E+01 

1983 

Ratio: 5.71E+00 

Jan–Apr 246 2.43E-03 4.85E-01 1.94E+00 Multiply original intake by 4 

May–Aug 264 2.64E-03 5.27E-01 2.11E+00 Multiply original intake by 4 

Sep–Dec 270 7.96E-03 1.59E+00 6.37E+00 Multiply original intake by 4 

Remaining Months N/A N/A N/A N/A 

Annual Totals N/A N/A 2.60E+00 1.04E+01 

1984 

Ratio: 4.00E+00 

Jan 292 5.19E-04 1.04E-01 1.04E-01 No action taken 

Feb 282 1.36E-03 2.73E-01 2.73E-01 No action taken 

Mar 222 1.28E-03 2.57E-01 2.57E-01 No action taken 

Apr 316 1.75E-03 3.51E-01 3.51E-01 No action taken 

May 294 1.76E-03 3.52E-01 3.52E-01 No action taken 

Jun 236 1.17E-03 2.35E-01 2.35E-01 No action taken 

Jul 252 1.19E-03 2.39E-01 2.39E-01 No action taken 

Aug 245 1.98E-03 3.98E-01 3.98E-01 No action taken 

Sep 264 2.19E-03 4.39E-01 4.39E-01 No action taken 

Oct 357 1.89E-03 3.79E-01 3.79E-01 No action taken 

Nov 292 1.65E-03 3.30E-01 3.30E-01 No action taken 

Dec 279 9.98E-04 2.00E-01 2.00E-01 No action taken 

Remaining Months N/A N/A N/A N/A 

Annual Totals N/A N/A 3.56E+00 3.56E+00 

1985 

Ratio: 1.00E+00 
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Room R-108 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action 

Jan 349 1.80E-03 3.61E-01 3.61E-01 No action taken 

Feb 320 1.65E-03 3.30E-01 3.30E-01 No action taken 

Apr 351 2.62E-03 5.26E-01 5.26E-01 No action taken 

May 336 1.96E-03 3.92E-01 3.92E-01 No action taken 

Jun 286 1.54E-03 3.08E-01 3.08E-01 No action taken 

Remaining Months N/A N/A N/A 2.68E+00 Average intakes from January 

account for missing months 

Annual Totals N/A N/A 1.92E+00 4.60E+00 

1986 

Ratio: 2.40E+00 

Jul 326 1.84E-03 3.70E-01 3.70E-01 No action taken 

Aug 365 2.42E-03 4.86E-01 4.86E-01 No action taken 

Sep 329 2.08E-03 4.18E-01 4.18E-01 No action taken 

Oct 321 1.54E-03 3.09E-01 3.09E-01 No action taken 

Nov 297 1.46E-03 2.93E-01 2.93E-01 No action taken 

Dec 236 1.17E-03 2.35E-01 2.35E-01 No action taken 

Remaining Months N/A N/A N/A 2.11E+00 Average intakes from July to 

to account for missing month

Annual Totals N/A N/A 2.11E+00 4.22E+00 

1988 

Ratio: 2.00E+00 

Jul 305 2.23E-03 4.46E-01 4.46E-01 No action taken 

Aug 334 2.55E-03 5.11E-01 5.11E-01 No action taken 

Sep 292 1.24E-03 2.49E-01 2.49E-01 No action taken 

Oct 325 2.53E-03 5.07E-01 5.07E-01 No action taken 

Nov 291 2.02E-03 4.05E-01 4.05E-01 No action taken 

Dec 236 1.17E-03 2.35E-01 2.35E-01 No action taken 

Remaining Months N/A N/A N/A 2.35E+00 Average intakes from July to 

to account for missing month

Annual Totals N/A N/A 2.35E+00 4.70E+00 

1989 

Ratio: 2.00E+00 
Effective Date: 

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Room SW-8 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Jan 44 4.40E-03 8.80E-01 8.80E-01 No action 

Feb 20 3.04E-03 6.09E-01 6.09E-01 No action 

Mar 306 6.18E-03 1.24E+00 1.24E+00 No action 

Apr 63 3.36E-03 6.72E-01 6.72E-01 No action 

May 81 4.29E-03 8.57E-01 8.57E-01 No action 

Jun 65 4.32E-03 8.63E-01 8.63E-01 No action 

Jul 93 1.32E-02 2.64E+00 2.64E+00 No action 

Aug 131 3.34E-03 6.68E-01 6.68E-01 No action 

Oct 46 7.92E-03 1.58E+00 1.58E+00 No action 

Nov 51 6.77E-03 1.35E+00 1.35E+00 No action 

Missing Months N/A N/A N/A 2.27E+00 Average intakes from January to 

December, multiply by 2 to acco

Annual Totals N/A N/A 1.14E+01 1.36E+01 

1969 

Ratio 1.20E+00 

Oct 12 8.97E-03 1.79E+00 1.79E+00 No action 

Nov 75 4.27E-03 8.54E-01 8.54E-01 No action 

Missing Months N/A N/A N/A 1.32E+01 Average October and November 

10 to account for missing month

Annual Totals 2.65E+00 1.59E+01 

1972 

Ratio 6.00E+00 

July–Aug 21 3.53E-02 7.07E+00 1.41E+01 Multiply by 2 

Missing Months N/A N/A N/A 7.07E+01 Multiply original July–August in

Annual Totals 7.07E+00 8.48E+01 

1975 

Ratio 1.20E+01 
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Room SW-8 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Jun–July 60 1.85E-02 3.70E+00 7.40E+00 Multiply by 2 

Aug 30 8.73E-03 1.75E+00 1.75E+00 No action 

Sep 48 9.74E-03 1.95E+00 1.95E+00 No action 

Oct 51 1.62E-02 3.23E+00 3.23E+00 No action 

Nov 48 9.16E-03 1.83E+00 1.83E+00 No action 

Dec 45 5.76E-03 1.15E+00 1.15E+00 No action 

Missing Months N/A N/A N/A 1.24E+01 Average intakes from June to D

account for missing months 

Annual Totals 1.36E+01 2.97E+01 

1976 

Ratio 2.18E+00 

Jan 54 4.86E-03 9.72E-01 9.72E-01 No action 

Feb 51 6.28E-03 1.26E+00 1.26E+00 No action 

Mar 48 1.17E-02 2.34E+00 2.34E+00 No action 

Apr 51 7.70E-03 1.54E+00 1.54E+00 No action 

May 57 8.28E-03 1.66E+00 1.66E+00 No action 

Jun 48 7.74E-03 1.55E+00 1.55E+00 No action 

Jul 54 8.17E-03 1.63E+00 1.63E+00 No action 

Missing Months N/A N/A N/A 7.82E+00 Average intakes from January to 

account for missing months 

Annual Totals 1.09E+01 1.88E+01 

1977 

Ratio 1.71E+00 

Jan–Feb 33 2.96E-03 5.92E-01 1.18E+00 Multiply by 2 

Mar 36 4.21E-03 8.42E-01 8.42E-01 No action 

Apr 32 5.83E-03 1.17E+00 1.17E+00 No action 

May 36 7.41E-03 1.48E+00 1.48E+00 No action 

Jun 45 2.83E-03 5.67E-01 5.67E-01 No action 

July 36 9.32E-03 1.86E+00 1.86E+00 No action 

Aug 42 6.16E-03 1.23E+00 1.23E+00 No action SEP 42 7.34E-03 1.47E+00 1.47E+00 No action 

Oct 42 9.38E-03 1.88E+00 1.88E+00 No action 

Nov 30 6.02E-03 1.20E+00 1.20E+00 No action 

1978 

Dec 39 5.60E-03 1.12E+00 1.12E+00 No action 
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Room SW-8 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 1.34E+01 1.40E+01 

Ratio 1.04E+00 

Jan 24 2.12E-03 4.42E-01 4.42E-01 No action 

Feb 33 6.66E-05 1.39E-02 1.39E-02 No action 

Mar 45 5.00E-03 1.04E+00 1.04E+00 No action 

Apr 24 4.78E-03 9.95E-01 9.95E-01 No action 

May 36 6.72E-03 1.40E+00 1.40E+00 No action 

Jun 45 5.68E-03 1.18E+00 1.18E+00 No action 

July 39 2.05E-02 4.28E+00 4.28E+00 No action 

Aug 48 1.10E-02 2.29E+00 2.29E+00 No action 

Sept 33 7.47E-03 1.56E+00 1.56E+00 No action 

Oct 36 2.18E-03 4.55E-01 4.55E-01 No action 

Nov 42 2.57E-03 5.36E-01 5.36E-01 No action 

Dec 27 2.52E-03 5.25E-01 5.25E-01 No action 

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 1.47E+01 1.47E+01 

1979 

Ratio 1.00E+00 

Jan 24 6.63E-03 1.33E+00 1.33E+00 No action 

Feb 24 6.35E-03 1.27E+00 1.27E+00 No action 

Mar–Jun 120 4.43E-03 8.86E-01 3.54E+00 Multiply by 4 

Jul–Oct 123 9.41E-03 1.88E+00 7.52E+00 Multiply by 4 

Nov–Dec 54 4.61E-03 9.21E-01 1.84E+00 Multiply by 2 

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 6.28E+00 1.55E+01 

1981 

Ratio 2.47E+00 
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Room SW-8 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Jan–Apr 129 7.81E-03 1.56E+00 6.25E+00 Multiply by 4 

May–Aug 216 1.23E-02 2.47E+00 9.86E+00 Multiply by 4 

Sep–Dec 225 9.76E-03 1.95E+00 7.81E+00 Multiply by 4 

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 5.98E+00 2.39E+01 

1982 

Ratio 4.00E+00 

Jan–Apr 189 7.11E-03 1.42E+00 5.68E+00 Multiply by 4 

May–Aug 234 8.44E-03 1.69E+00 6.75E+00 Multiply by 4 

Sep–Dec 189 1.14E-02 2.28E+00 9.13E+00 Multiply by 4 

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 5.39E+00 2.16E+01 

1983 

Ratio 4.00E+00 

Jan–Apr 237 1.33E-02 2.67E+00 1.07E+01 Multiply by 4 

May–Aug 261 3.69E-03 7.38E-01 2.95E+00 Multiply by 4 

Sep–Dec 270 1.19E-02 2.39E+00 9.55E+00 Multiply by 4 

Missing Months N/A N/A N/A N/A 

Annual Totals N/A N/A 5.79E+00 2.32E+01 

1984 

Ratio 4.00E+00 

Jan 459 1.75E-03 3.50E-01 3.50E-01 No action 

Feb 516 2.02E-03 4.06E-01 4.06E-01 No action 

Mar 359 2.01E-03 4.03E-01 4.03E-01 No action 

Apr 466 3.24E-03 6.48E-01 6.48E-01 No action 

May 482 2.26E-03 4.52E-01 4.52E-01 No action 

Jun 406 1.56E-03 3.12E-01 3.12E-01 No action 

Jul 448 1.59E-03 3.20E-01 3.20E-01 No action 

Aug 450 2.56E-03 5.13E-01 5.13E-01 No action 

Sep 423 3.96E-03 7.93E-01 7.93E-01 No action 

Oct 510 3.04E-03 6.09E-01 6.09E-01 No action 

Nov 379 3.33E-03 6.66E-01 6.66E-01 No action 

Dec 335 1.37E-03 2.75E-01 2.75E-01 No action 

1985 

Missing Months N/A N/A N/A N/A 
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Room SW-8 

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Annual Totals N/A N/A 5.75E+00 5.75E+00 

Ratio 1.00E+00 

Jan 483 3.73E-03 7.47E-01 7.47E-01 No action 

Feb 438 2.47E-03 4.96E-01 4.96E-01 No action 

Apr 481 4.31E-03 8.63E-01 8.63E-01 No action 

May 461 1.70E-03 3.42E-01 3.42E-01 No action 

Jun 449 2.57E-03 5.15E-01 5.15E-01 No action 

Missing Months N/A N/A N/A 4.15E+00 Average intakes from January-F

multiply by 7 to account for mis

Annual Totals N/A N/A 2.96E+00 7.11E+00 

1986 

Ratio 2.40E+00 

Jan 449 3.33E-03 6.67E-01 6.67E-01 No action 

Feb 432 5.26E-03 1.05E+00 1.05E+00 No action 

Mar 431 4.23E-03 8.47E-01 8.47E-01 No action 

Apr 466 4.74E-03 9.50E-01 9.50E-01 No action 

May 458 3.14E-03 6.30E-01 6.30E-01 No action 

Jun 448 5.24E-03 1.05E+00 1.05E+00 No action 

Jul 407 3.39E-03 6.79E-01 6.79E-01 No action 

Aug 492 3.01E-03 6.03E-01 6.03E-01 No action 

Missing Months N/A N/A N/A 3.24E+00 Average intakes from January to 

account for missing months 

Annual Totals N/A N/A 6.48E+00 9.72E+00 

1987 

Ratio 1.50E+00 

Jan 456 1.65E-03 3.30E-01 3.30E-01 No action 

Feb 300 4.48E-03 8.98E-01 8.98E-01 No action 

Mar 490 1.62E-03 3.25E-01 3.25E-01 No action 

Apr 480 1.42E-03 2.85E-01 2.85E-01 No action 

May 450 1.04E-03 2.09E-01 2.09E-01 No action 

Jun 366 9.12E-04 1.83E-01 1.83E-01 No action 

Missing Months N/A N/A N/A 2.23E+00 Average intakes from January to 

account for missing months 

1988 

Annual Totals N/A N/A 2.23E+00 4.46E+00 
Effective Date: 

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Room SW-8 

NOTICE

wever, th

Year Original Intake Period # Samples 95th Percentile Air Concentration NIOSH Intake Corrected Intake Action Ta

Ratio 2.00E+00 

Jan 449 1.34E-03 2.68E-01 2.68E-01 No action 

Feb 576 1.70E-03 3.40E-01 3.40E-01 No action 

Mar 474 1.21E-03 2.43E-01 2.43E-01 No action 

Apr 582 1.86E-03 3.72E-01 3.72E-01 No action 

May 470 1.63E-03 3.27E-01 3.27E-01 No action 

Jun 349 1.94E-03 3.89E-01 3.89E-01 No action 

Missing Months N/A N/A N/A 1.94E+00 Average intakes from January to 

account for missing months 

Annual Totals N/A N/A 1.94E+00 3.88E+00 

1989 

Ratio 2.00E+00 
Effective Date: 

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Page No. 

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ATTACHMENT 2: DESCRIPTION OF TRANSCRIPTION ERRORS, 

MISSED DATA AND DUPLICATE ENTRIES 

QA 

Ref # Description Room Month-Y

1 Missing data: (2100, 7, 200), (152, 19, 80), (8791, 0, 649), (257, 0, 51), (199, 0, 68) R-108 Jun-83 2 Transcription error (720 incorrectly recorded as 7066) R-108 Sep-83 3 Transcription error (299 incorrectly recorded as 65) R-108 Nov-83 4 Transcription error (49 incorrectly recorded as 409) R-108 Nov-83 5 Transcription error: (95 incorrectly recorded as 45) R-108 Feb-84 6 The following data appear to have been duplicated : (135, 0, 25), (177, 24, 60), (180, 0, 67) and (166, 24, 50) R-108 May-87 Transcription error (32 incorrectly recorded as 82), (4896 incorrectly recorded as 4196) R-108 Jun-84 8 Transcription error (636 incorrectly recorded as 626) R-108 Jun-84 9 Transcription error (60 incorrectly recorded as 62) R-108 Jul-84 

10 Transcription Error (671 incorrectly recorded as 621) R-108 Jul-84 11 Transcription error (134 incorrectly recorded as 1304) R-108 Aug-84 12 Transcription error (14 incorrectly recorded as 4) R-108 Sep-84 13 Missing data: (424, 0, 151) Transcription error (29 incorrectly recorded as 5), (168 incorrectly recorded as 29) R-108 Sep-84 14 Transcription error (22 incorrectly recorded as 0) R-108 Oct-84 15 Transcription error (272 incorrectly recorded as 275) R-108 Oct-84 16 

The following data appear to have been duplicated: (55, 0, 25), (99, 0, 28), (107, 0, 54), (226, 58, 136), (433, 0, 103), (458, 0, 82), (486, 0, 81), (978, 6, 273), (1319, 28, 312), (1518, 82, 319) 

R-108 Dec-84 

17 Transcription error (6 incorrectly recorded as 0) R-108 Dec-84 18 Transcription error: (2080 incorrectly recorded as 280) SW-8 Aug-819 Three data appear to represent alpha smears not beta smears SW-8 Oct-81 20 Transcription error: (102 incorrectly recorded as 162) SW-8 Dec-821 Missing data: (857, 45, 215), (1577, 43, 332), (1544, 21, 208) SW-8 Mar-82 
Effective Date: 

July 06, 2012

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Page No. 

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QA 

Ref # Description Room Month-Y

22 Transcription error (59 incorrectly recorded as 51) SW-8 Jul-82 23 Transcription error (406 incorrectly recorded as 402) SW-8 Aug-82 24 Transcription error (3857 incorrectly recorded as 3887) SW-8 Aug-82 25 Transcription error (299 incorrectly recorded as 219) SW-8 Sep-82 26 Transcription error (147 incorrectly recorded as 128) SW-8 Nov-82 27 Transcription error (2928 incorrectly recorded as 2908) SW-8 Nov-82 28 Missing data: (3769, 0, 408) Transcription error: (175 incorrectly recorded as 875) SW-8 Feb-83 29 Transcription error: (878 incorrectly recorded as 866), (242 incorrectly recorded as 222) SW-8 Feb-83 30 

Missing data: (7, 502), (349, 40, 148) Transcription error: (1595 incorrectly recorded as 595), (52 incorrectly recorded as 54), 

(151 incorrectly recorded as 124), and (224 incorrectly recorded as 234) 

SW-8 Mar-83 

31 Transcription error: (323 incorrectly recorded as 423) SW-8 Mar-83 32 Transcription error: (154 incorrectly recorded as 254) SW-8 Apr-83 33 Missing data: (175) SW-8 Apr-83 34 Transcription error: (1099 incorrectly recorded as 1098) SW-8 Apr-83 35 Missing data (868, 13, 121) Transcription error: (30 incorrectly recorded as 306), (461 incorrectly recorded as 61) SW-8 Aug-83 36 Transcription error: (185 incorrectly recorded as 189) SW-8 Sep-83 37 Transcription error: (273 incorrectly recorded as 233) SW-8 Nov-83 38 Transcription error (17 incorrectly recorded as 7) SW-8 Jan-84 39 Missing data: (543, 5,104) Transcription error: (49 incorrectly recorded as 52) SW-8 Feb-84 40 Missing data: (826, 3 , 145) SW-8 Mar-84 41 Transcription error (86 incorrectly recorded as 36) SW-8 Apr-84 42 The following data appear to have been duplicated: (339, 0, 66), (501, 26, 159), (568, 0, 79) and (975, 33, 189) SW-8 May-843 Missing data: (413, 52, 136) SW-8 May-844 Missing data: (377, 13, 98) SW-8 May-8
Effective Date: 

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Page No. 

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QA 

Ref # Description Room Month-Y

NOTICE

wever, th

45 Transcription error (48 incorrectly recorded as 44) SW-8 Jun-84 46 Transcription error (812 incorrectly recorded as 312), (328 incorrectly recorded as 321) SW-8 Jun-84 47 Transcription error (8 incorrectly recorded as 1) SW-8 Jul-84 48 Transcription Error (1192 incorrectly recorded as 192) SW-8 Jul-84 49 Transcription error (30 incorrectly recorded as 32) SW-8 Aug-84 50 The following data appear to have been duplicated: (320, 6, 75), (357, 23, 167), (627, 18, 211) and (725, 0, 140) SW-8 Oct-84 51 Transcription error (1526 incorrectly recorded as 1626) SW-8 Oct-84 52 Transcription error (5100 incorrectly recorded as 50100) SW-8 Nov-84 53 Missing data (3700, 99, 735) Transcription error (332 incorrectly recorded as 231) SW-8 Nov-84 54 Transcription error (288 incorrectly recorded as 211) SW-8 Nov-84 55 The following data appear to have been duplicated: (636, 7, 156), (1236, 53, 253), (1441, 58, 241), (1605, 10, 281) and (1778, 111, 354) SW-8 Dec-84 56 Transcription error (485 incorrectly recorded as 415), (48 incorrectly recorded as 41), (585 incorrectly recorded as 515) SW-8 Dec-84 57 Transcription error (2854 incorrectly recorded as 2154) SW-8 Dec-84 58 Transcription error (281 incorrectly recorded as 211) SW-8 Dec-84 
Effective Date: 

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Revision No. 

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Page No. 

90 of 92

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

ATTACHMENT 3: DESCRIPTION OF DATA, INFORMATION, 

AND REPORTS IN THE SRDB 

Documents collected by NIOSH related to the EEOICPA dose reconstruction are contained and 

maintained in the Site Research Database (SRDB). SC&A performed a search of the SRDB in 

order to obtain background information on the metal tritide issue at Mound. In general, there are 

three types of documents that were searched for: (1) general information on tritides at Mound, 

(2) information on tritium (tritide) incidents at Mound, and (3) information on tritium 

contamination at Mound. There are a number of documents identified in the SRDB concerning 

the dose response to tritides, but since it has been decided to accept modeling tritides as Type S, 

those documents were not included in the present SC&A search of the SRDB. Likewise, the 

SRDB contains a number of documents related to tritides at other (non-Mound) sites, which were 

not included in the present review. Table A-1 presents a list of the Mound tritides-related SRDB 

documents that were identified, downloaded, and reviewed by SC&A for this background 

information gathering effort (additional documents were obtained by SC&A in order to perform 

other portions of this review, specifically for the Section 4.1 temporal and spatial data adequacy 

and completeness review). 

Based on the search and review of the SRDB for documents related to metal tritides at the 

Mound site, the following points can be made: 

(1) “Tritium (not tritides) came to Mound in ~1957... Didn’t have a particulate program until 

1959” – [Redacted] (Ulsh and Chew 2008 and SC&A 2006). 

(2) There was research and development work with tritides (SC&A 2006). 

(3) Mound published tritide research results beginning in the mid-1970s, if not before 

(Bowman and Attalla 1974). 

(4) NIOSH interviewed three tritide site experts in 2008; [Redacted] – [Redacted] Scientist 

1980–1994, contractor through 2000; [Redacted] – Physicist 1964–1995; [Redacted] – 

[Redacted] Engineer 1959–2003 (Ulsh and Chew 2008). 

(5) From time to time, incidents occurred with tritium and/or tritides (Rogers et al. 1993; 

Ricks 1973; MORE 1964, 1965, 1973a, and 1973b; Meyer et al. 1960; Kirk 1994 and 

1999. 

(6) The most important incident involving tritides was a 1972 glove failure on a single box in 

SW-13 (SC&A 2006, Appendix 7). This is probably also the Kirk incident discussed by 

[Redacted] and [Redacted] (Ulsh and Chew 2008). There is a 1970 incident report that 

sounds very much like this incident (Madding 1970) – could there be a mix-up in the 

date? 

(7) From these incident reports, maintenance in tritium areas was performed in protective 

“bubble suits.” 

(8) “Mound never deliberately handled unconfined particulate tritides. There were 

unintentional spills, but it was always doubly confined” – [Redacted] (Ulsh and Chew 

2008). 
Effective Date: 

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Revision No. 

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Page No. 

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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.

(9) It is possible to determine if a biosample is the result of inhalation or skin adsorption of 

tritium or inhalation of tritides, but tritides could be masked by HTO and/or H2 (Ulsh and 

Chew 2008). 

(10) Tritide workers identified by name (Ulsh and Chew 2008). 

(11) Continuous air monitors filter the air before counting; therefore, tritides would be 

removed and not included in air monitoring results. 

(12) No data prior to the early 1990s regarding tritide contamination levels. 

(13) SW-8, SW-9, SW-13, SW-150, SW-152, SW-24, and R-108 have the potential for SMT 

contamination (SC&A 2006). 

(14) SW-8 and R-108 last used to process tritides (recover tritium from tritides on dismantled 

boxes/hoods) (SC&A 2006). 

General Information: 

Tritium (Tritide) Incidents: The SRDB contains documentation on a number of incidents 

involving accidental tritium contamination and personnel exposures that have occurred at 

Mound. SRDB documentation for three Mound tritium incidents that specifically involved metal 

tritides was identified and reviewed.

Tritium Contamination: The review of the SRDB revealed that there is much tritium 

contamination information for the Mound plant; however, no airborne or surface contamination 

information specific to tritide contamination was identified for the Mound plant. Therefore, this 

lack of information makes it difficult to benchmark any tritide model developed by NIOSH for 

the Mound plant. 

Table A-1. SRDB Documents Reviewed for this Review 

Identifier Comments 

025502_ Accident Investigation Report No. 73-08 (Ricks 

1973) 

1973 tritium incident, SW-8 

026908_ Mound Technical Basis Document for Stable 

Tritiated Particulate and Organically Bound Tritium Vol 4. 

(Sharfi 2001) 

026975_Radiological Controls for Work Involving Stable 

Tritiated Particulates and Organically Bound Tritium (Collas 

1999) 

039682_ (Powers 1998) 

048319_Properties of Aged Metal Tritides (McConville et al. 

1994) 

048822_ Correspondence File, Incident Reports 

(Environmental and Worker) (Kirk 1999) 

Incidents, see pages 64 (1978 tritide) and 101 

(1981 tritium) 

048837_Investigation of the Contamination Tracking 

Incident in SW_R Tritium Complex (Rogers et al. 1993) 

1993 tritium incident, referred to in Interview 

Notes (055962) 

048857_SW-209 Contamination Incident Report (Kirk 1994) 1994 tritium incident 

050849_Stable Tritiated Particulates (STPs) White Paper 

(Trent 1999) 
Effective Date: 

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Table A-1. SRDB Documents Reviewed for this Review 

Identifier Comments 

NOTICE:

055962_Interview with [Redacted], [Redacted], and 

[Redacted] (Ulsh and Chew 2008) 

Good background information: can identify tritides 

from biosample, 

059275_SW Health Physics Trend Sheets, August 13, 1978 

– December 28, 1978 (Ulsh 2009) 

Only data, no explanation 

081876_SW Building Contamination Surveys 1985 

(Connell 2010a) 

Only data, no explanation 

081912_SW Building Contamination Surveys 1987 (Connell 

2010d) 

Only data, no explanation 

081939_SW Health Physics Trend Sheet, Tritium Air and 

Wipe Results, 1977, part 2 (Weaver 2010a) 

Only data, no explanation 

081940_SW Health Physics Trend Sheet, Tritium Air and 

Wipe Results, 1977, part 1 (Weaver 2010b) 

Only data, no explanation 

46056_Calculation Of Tritium Dose From Insoluble 

Particulates (McConville and Woods 1995) 

[Redacted] – Woods paper, referred to in 

Interview Notes (055962) 

039681_Characterization of Particulate Tritium Sources 

(EG&G 1995) 

039716_Discussion of Hafnium Tritide Dosimetry and 

Proposal Path Forward for Assigning Dose with Mound 

(D.G. Draper), Sandia National Laboratory, Lovelace 

Respiratory Research Institute, Los Alamos National 

Laboratory - M.E. Schillaci (Connell 2008) 

Comments on some report: can identify tritides 

from biosample, 76+1 workers exposed to tritides 

Final Safety Analysis Report for the SW-R Tritium Complex 

(EG&G 1994) 

39891_Health Physics Technician Training Tritium 

Monitoring (Anderson no date) 

80159_Incidents (MORE 1973a) 1973 tritium incidents – bubble suit, skin 

contamination, not inhalation 

039686_Information Regarding the Workplace Indicators 

and Bioassay Limitations When Dealing with Stable Metal 

Tritides (Sirois 1998) 

39690_Metal Tritide Questions – Responses (Draper 1997) 

039693_Particulate Tritium Issues at Mound – (Draper 

1996) 

039721_PARTICULATE TRITIUM ISSUES AT MOUND 

(Sullivan 1996) 

Transmittal of Draper to DOE 

46475_Report of Accident Investigation of the F Column 

Tritium Incident in the SW-8 Area (Meyer et al. 1960) 

1960 tritium incident 

SiteResearch – Tritide, Mound SRDB search results for “tritide” 

SiteResearch – Tritium, Mound SRDB search results for “tritium” 

039680_Survey of SW Building for Particulate Tritium 

before Decontamination 

Tritium Incident in SW 142 (MORE 1973b) 1973 tritium gas incident 

Tritium Incident in SW (MORE 1964) 1964 “minor” tritium incident 

46949_Tritium Surface Contamination (Sienkiewicz 1985)