1

NIOSH Response to SCA’s January 12, 2012 Memo Report on 

Adequacy and Completeness of Mound Internal Dosimetry 

May 29, 2012 

On January 12, 2012, Joseph Fitzgerald of SC&A issued a memo titled, “Adequacy and 

Completeness of Mound Internal Dosimetry – Work Group Issues”. This memo summarized 

SC&A’s view of the status of internal dosimetry issues under discussion by the Mound Working 

Group (MWG). At its meeting on April 10, the MWG requested that NIOSH respond to this memo. 

That response is contained in this document. 

SC&A’s memo contained the following recommendation: 

“SC&A recommends that the Work Group accept the NIOSH SEC Evaluation Report 

conclusion that it can reconstruct internal doses after 1959 (with the exception of radon, 

thoron, and their daughter products covered by the existing SEC class) with sufficient 

accuracy, notwithstanding the identified outstanding questions that remain to be resolved as 

identified in Attachment 1. This recommendation is also qualified by the outstanding SEC 

relevant questions that remain regarding thorium, polonium, and tritides that have been 

identified.” 

However, in Table 1 of their memo, SC&A also characterized the following issues as having a status 

of “open”. The interpretation of these two apparently conflicting conclusions is not clear to NIOSH. 

We have responded below to each item SC&A characterized as remaining open in Attachment 1 of 

their memo. In the table below, we have reproduced those issues SC&A assigned an open status 

(those SC&A recommended closed are not reflected in the table below). We have added a column to 

the table to provide the NIOSH assessment of each issue. 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working 

Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or 

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

preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 

USC §552a and has been cleared for distribution. 
SC&A Document / 

Reference 

Issue description Proposed Current Status NIOSH Assessment (5-7-1

SC&A 2009a, Section 3.2 Thorium bioassay data Open (thorium being NIOSH agrees that the thorium-232 isPartial coverage in SC&A o Uncertainties and reviewed by NIOSH remains open. However, since Januar2010 (gross alpha & anion concerns regarding analytical SC&A issued this memo, NIOSH has exchange) methods prior to 1970. No thorium dose-reconstruction documen

specific procedure for 1959– 1967. o Procedures not evaluated 

2012), and SC&A responded on May NIOSH is currently evaluating SC&A

for effectiveness or response. plausibility. o Radium daughter analysis of limited value – cannot assume equilibrium. o Thorium urinalysis and modeling. o Unusual forms of thorium (YY). 

SC&A 2009b, Section 3.6 Other radionuclide data 

(SC&A data comparison) o ~95% of data found for selected individuals was collected in 1990 and later. Pre-1990 results included uranium, thorium, and curium. o Majority of pre-1990 

Open NIOSH responded in detail to these co

its November, 2009 report, NIOSH EvData Adequacy and Completeness IssMound Laboratory, and again in its Areport, NIOSH Evaluation of Data AdCompleteness Issues at the Mound LaSection 3.6 of SC&A’s 2009 report diseveral radionuclides (i.e., Th-227, Th

results not available in MESH. o Data comparison was difficult – units and radionuclides did not always 

230, Th-232), uranium (i.e., U-232, U234, U-235, U-238), Ra-226, Cm-242Ac-227, Pu-242, Am-241, Bi-207, Bi-60, Cs-137, Sr-90. NIOSH has addresthese in their 2009 and 2011 reports, a

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcom

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless s

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has be
match (e.g., monitoring April, 2012 report on Th-232 dose daughter to evaluate parent). reconstruction. o Volume corrections were not possible in many cases. 

SC&A 2009c, Section 4.6 Secondary/Other radionuclide 

data (MJW evaluation) o Some results were not associated with a name, social security number, or HP number. o Results with no units. o Result attributed to 2 or 3 different radionuclides. o Information was poorly documented, often approximate at best. o Questionable use of surrogate bioassay. o Inconsistent / conflicting interpretation. o Insufficient data to determine need for Phase II assessment. 

Open NIOSH has already responded to thes

our August, 2011 paper (NIOSH Resp

SC&A 2009c, Section 4.0 Tritium logbooks are missing 

for 1976 and 1977 (MJW evaluation) o HTO dose data is available in MESH; the raw bioassay data is missing. o Cannot apply NIOSH model for estimating tritide dose without the bioassay data. 

Open NIOSH is currently in the process of a

SEC class through the 83.14 process f1, 1975 through December 31, 1976. Tbioassay data for 1977 are not missing 74280). 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcom

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless s

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has be
SC&A 2009d, SC&A o Interpretation of tritium Open (addressed in Issue NIOSH agrees that the tritide issue rem2009e, Section 3.3 bioassay data and exposure to 

stable metal tritides. o Unresolved concerns regarding feasibility of dose reconstruction for STCs. o Cannot appreciate scope of tritium program without classified references. 

#6) However, since January 12 when SC&

this memo, NIOSH has provided a resdated March 30, 2012. 

SC&A 2009a, Section 3.6, Tritium bioassay data adequacy Open NIOSH agrees that the tritide issue remSC&A 2009d o Do not have algorithm for 

early dose calculations. o Compounds other than HTO were apparently not considered in bioassay. 

However, since January 12 when SC&this memo, NIOSH has provided a resdated March 30, 2012. No algorithm tritium dose calculations is necessary, NIOSH has the tritium bioassay logbo

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcom

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless s

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has be