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Miller, Diane M.

From: Charles Owens
Sent: Friday, April 22, 2005 1:24 PM

To:
Ce:

NIOSH Docket Office

karen.long@mail.house.gov; kim_taylor@bunning.senate.gov; scott_raab@mcconnell.senate.gov;
foleypw@pgdp.usec.com

Subject: RE: Paducah Gaseous Diffusion Plant Site Profile 030

Please accept the following questions and concerns regarding the Paducah Gaseous Diffusion Plant Site Profile

#030

Technical Basis Document-Site Description

1.

In Section 2.3, the second paragraph indicates the following with regard to the reactor tails material: “The
percentage of PGDP cascade feed material from reactor tails averaged 17% during the periods this
material was used, ranging from 3% in 1965 to 65% in 1973.”

a. What is the reference for these percentages?

b. Rather than just indicating the percentage, a table indicating the amount in pounds along
with a percentage would be useful

c. The percentage indicated in this section is not in agreement wit the percentage indicated in

the Internal dose section of the Paducah site profile (page 6, section 5.2) which indicates the
19% of feed was reactor tails (which is referenced as DOE 2000)

In Section 2.3, the end of the third paragraph indicates “High Radiation Areas” existed near the fluorination
towers and ash receivers.

a. How is “High Radiation Area” defined? Current regulatory definition?

b. Do you have any survey data that would give the reader a sense of the exposure levels?

Section 2.3 paragraph 5 indicates that there were two cascade improvement/upgrade programs (1958-

4962 and 1973-1981). These were significant because of possible worker exposure to transuranics while

the cascade systems were open. We feel strongly that there was a very good potential for transuranic

exposure during these activities, but we are a little concerned that the TRU concentrations associated with

these operations are not defined within this section or more importantly, within the Internal Dose section.
a. Has NIOSH defined the TRU concentrations related to these activities?

Section 2.3, top of page 7, has several lines indicating that there was documentation supporting the
presence of Np, Tc, and Pu; however, the original source documents were not referenced. It is unclear
whether all these statements are contained within the document referenced at the end of the paragraph
(Bechtel Jacobs 2001).

Pages 7 - 9 include information regarding levels of exposure as a function of area and job (including data
in 2-1 and 2-2). Much of this information appears to come from a report co-authored by PACE and the
University of Utah. However, a closer examination of the PACE/Utah report makes it very apparent that
key qualifiers in how the data and conclusions within the report should be used were not included. Some
of these qualifiers include:

a. Page 49 of the PACE/Utah report indicates in the synopsis that the rankings are based on
potential radiation exposure and are not necessarily indicative of individual worker exposures.

b. Page 50 of the PACE/Utah report says, “The intent here is to provide a general overview
and first pass ranking of the potential for exposure to both external radiation and internal
radiation.”

c. Page 55 of the PACE/Utah report says, “Preliminary spot checks of provided electronic

database indicate that the electronic data may be incomplete and/or inaccurate.” The report
goes on to say that, the Team strongly recommends the review of the original dosimetry
records.

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d. Page 69 indicates that “A recent verification effort of the external dosimetry databases
(‘History Tapes”) showed a large number of discrepancies (reference 47 within the
PACE/Utah report)

e. Page 69 states, “. . . the information in the databases should not be used to estimate

individual doses.” Further, a QA/QC of the data is recommended.
Given all of the above qualifiers and clarifications, we question whether the summary data, based on potentially
flawed and unverified data, is appropriate for use in dose reconstruction.

Has NIOSH performed any validation of the data within these databases?

Does NIOSH believe that this information can be used for doses reconstruction without first validating the
database data?

Technical Basis Document for the PGDP-Occupational Internal Dose

1. We are concerned that Carol Berger, the identified subject expert for this report, has done previous health
physics consulting work for the Paducah site contractor. Can NIOSH indicate whether Carol Berger’s past
work included consulting work for Paducah? Did she author the referenced IT report?

2. Section 5.2, page 6, Table 5-1, presents fractions of neptunium and plutonium by plant location. The table
seems to be taken from a previous assessment report (IT Corporation 1992); however, it is unclear, from
the original assessment study, what the source of this data was.

a. Can NIOSH provide the source documents used to assemble the information in the table?

b. Can NIOSH explain why the value for Cascade (general) — zero, differs from Buildings C-333
and C-337 (which are cascade buildings)? Maybe if the source information were available
this would be more understandable.

3. Section 5.2, page 7, between table 5-2 and Table 5-3 says: “Dust samples from a variety of process
systems in 1989 were analyzed for their isotopic content.” Then it goes on to say “Table 5-3 summarizes
the results for selected process areas at the plant that dose reconstructors can use in the absence of
employee-specific information to evaluate the total uranium bioassay data collected after 1953 (Baker

1987, pp 6-8).”

a. What is the reference for the 1989 data? Is this data consistent with the Baker report data
used in table 5-3?

b. The second sentence suggests table 5-3 can be used in the absence of employee specific
data. Is there ANY employee specific data regarding Np or Pu exposures? Any before
1989?

c. Table 5-3 lists radionuclide concentrations in units of nCi/microgram and table 5-4 lists

radionuclide concentrations in units of nCi/g. Are the units in table 5-3 supposed to be the
same as in 5-4 (the correct units?)

4. Table 5-4 is labeled “Default isotopic distribution”

a. It appears that these are default maximum values. Again, in deriving these maximums was
the 1989 reported activity concentrations considered?
b. Were other data, cited in the PACE/Utah report and derived from HP investigation reports

considered in establishing a maximum?

5. Based on the site profile document, how does NIOSH intend for individual dose reconstructors to apply
TRU activity concentrations (mentioned in table 5-4) when considering an individuals’ urinalysis data? Are
the activity concentrations applied to the urine data before estimating intakes or are intakes of uranium
estimated and then the activity fractions applied to that data?

6. Have the site profile authors compared intake estimates derived based on available urine data versus
estimates based on air sampling data with regard to all radionuclides of concern?

Technical Basis Document for PGDP- Occupational External Dose

1. Section 6.5.1 discusses estimating missed photon deep dose and appears to rely upon data summarized

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with the PACE/ Utah 2000 report. Again, it should be pointed out that we believe that the PACE/Utah

report cautions against just this type of use of this data without further investigation and verification of
the data.

Thank you for your consideration of these comments and concerns, and | will anticipate your timely response.
Sincerely,

Leon Owens

Worker Health Protection Program - Coordinator

United Steelworkers Local 5-0550 (formerly PACE Local 5-0550)
Paducah, KY

4/28/2005