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SC&A – January 6, 2016
 

Issue No. Issue SC&A Statement 

1 Reconstruction of doses in the 

absence of early health 

physics, industrial hygiene, 

and environmental records 

The absence of pre-1980s records brings into question the ability to adequately assign radiation doses during 

the early years at Pinellas. The improvements in radiological monitoring and bioassay methodology, 

instrumentation, and in health physics, industrial hygiene, and environmental control programs, contraindicate 

the use of 1980s documentation for determining radiation doses for the early years of plant operations. The 

assumptions incorporated into ORAUT-TKBS-0029-4 and ORAUT-TKBS-0029-5, given the absence of firm 

information, appear to be claimant favorable. However, the uncertainties associated with projections without 

documentary evidence may result in missing doses that may not be accounted for by the claimant-favorable 

assumptions indicated in the documents. 

Issue 1: Closed during the 11/19/2012 WG meeting: see transcript page 12. TBDs updated in 2011. 

SC&A response – 01/05/2016: concur. 

2 Potential doses from insoluble 

metal tritides not sufficiently 

addressed. 

The neutron tube manufacturing process required spray coating the inside of a glass tube with a thin metal film, 

resulting in the formation of insoluble stable metal tritides (SMTs), namely ScT2, ErT2, and TiT2. There is no 

internal documentation indicating that there were adequate means of detecting exposures or monitoring 

SMTs. No guidance is provided for estimating the exposure to metal tritides; in fact, Section 5.9.2, Metal 

Tritide Exposures, is reserved for later entry. The practice of destructive testing of neutron generators and the 

methodology for performing the testing make it possible that exposures to metal tritides occurred. Further 

discussion of the potential exposure pathway and doses should be included in ORAUT-TKBS-0029-5, when 

Section 5.9.2 is completed. 

This issue remains open – NIOSH plans on completing the tritide approach in December 2015. See 11/19/2012 WG meeting see transcript pages 13-26. 

SC&A response – 01/05/2016: concur 

3 MDCs and uncertainties for 

plutonium and bioassay 

measurements are 

inadequately addressed 

(ORAUT-TKBS-0029-5). 

ORAUT-TKBS-0029-5 should provide more information about how bioassay sample activity concentrations 

were calculated and the uncertainties associated with these values. NIOSH should provide information on the 

use of the values in Table 5.1 to calculate internal doses. 

Issue 3: Closed before the 11/19/2012 WG meeting: see transcript page 27. TBDs updated in 2011. 

SC&A response – 01/05/2016: concur. 

4 Assessment of personnel 

badging policy during early 

years needs further review. 

ORAUT-TKBS-0029-6 states: 

From 1960 to 1973, U.S. Atomic Energy Commission (AEC) annual exposure summary reports indicate 

that Pinellas had 27.5% of its labor force wearing dosimetry (377 of an average yearly labor force of 

1,372). During the 1980s, while the data are not completely available, from 370 to approximately 400 

of 1,650 to 1,975 workers (approximately 20%) were monitored for radiation dose. No documentation 

was found to show that all employees were monitored at some time during Pinellas operations. 

It is important to know who was considered a “radiation worker” and how they were selected for badging, as this has 

dose consequence. In that era, radiation hazards were not well recognized. This resulted in some workers not being 
 

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monitored during a period when not all radiation hazards were recognized. The TBD does not clearly address these 

issues by clarifying the basis for how monitoring was conducted, nor which worker categories were badged. These 

issues need to be reviewed and substantiation provided that the maximally exposed workers were badged, and that there 

is a means to estimate radiation dose to unmonitored support workers with access to production areas. Additionally, 

since many Pinellas records on facility monitoring, safety evaluations, investigations, etc., prior to 1980 are not available, 

the determination of the adequacy of badging assignment and allocation of unmonitored dose will be complicated. The 

impact of this absence of early information should be addressed. 

Issue 4: Closed during the 6/11/2009 WG meeting see transcript page 33. TBDs updated in 2011. 

SC&A response – 01/05/2016: Concur. Also, the DCAS coworker model that assigns the 95th percentile whole-body dose to all unmonitored workers 

obviates this issue. 

5 Problems with personnel 

dosimetry. 

Section 6.2.2 of ORAUT-TKBS-0029-6 states, 

This analysis was unable to locate specific designs of the film dosimeters used for 

approximately the first 20 years (1957 to 1974) at the Pinellas Plant, and there is limited 

documentation that indicates there was an early relationship with Nuclear-Chicago (GEND 

2004a). 

Table 6-5 on page 16 of ORAUT-TKBS-0029-6 assigns a missed dose of 0.24 rem for beta-photons (monthly) 

for badges used during this time period. This assignment of missing dose evidently assumes that the badges 

used during this time period were equivalent to those provided by Nuclear-Chicago. Additional discussion is 

needed on the uncertainty associated with the assumed missing dose, given that the origin of the dosimetry is 

not clearly established. 

Issue 5: Closed during the 6/11/2009 WG meeting see transcript page 51. TBDs updated in 2011. 

SC&A response – 01/05/2016: “In abeyance” at 6/11/2009 meeting. Discussed again at 11/19/2012 meeting. 

Remaining open sub-issue was the basis for the LOD of 10 mrem for the post-1974 period in Table 6-9 of TBD-6 instead of SC&A-recommended 20 mrem 

(see Attachment 2 of “SC&A Pinellas Plant Work Group Update November 19, 2012, Teleconference meeting” for a description of Issue 5 as it stood prior to 

the November 19, 2012, meeting. That document is available on the DCAS website.) 

Post-1974 sub-issue discussed on pp. 44–50 of the 11/19/2012 transcript, p. 50: NIOSH (Brian Gleckler) was going to look into the basis for an LOD of 

10 mrem instead of SC&A-recommended 20 mrem. On 151207, I asked Joe Zlotnicki (SC&A, former VP of Landauer) through email to respond. He 

indicated that 10 mrem is probably acceptable for 30–250 keV photons, but is concerned that the gamma spectrum from an RTG source would be hardened. 

SC&A is still looking into this and will be prepared to discuss at the February 2016 WG meeting. 

6 The decontamination and 

decommission (D&D) era of 

Pinellas operations is not 

sufficiently addressed. 

Monitoring practices, particularly internal dosimetry, are not specified in the TBD for the D&D period (1995– 

1997) at the Pinellas Plant. A number of questions present themselves that are not addressed by the existing 

Pinellas Site Profile. What specific external and internal monitoring program was established for D&D 

operations, and how effectively was it implemented? With the use of first-, second-, and third-tier 

subcontractors, to what extent were these workers “captured” in the site’s dosimetry program, and were their 

records maintained? How would the coworker dose model be applied for unmonitored workers located 

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adjacent to D&D operations; was resuspension of radioactive particulates an on-site issue during D&D? 

Buildings at Pinellas were designed and constructed to provide ventilation systems, fumehoods, and 

gloveboxes to minimize inhalation uptakes by workers. As demolition workers began to remove walls and 

dividers, and to remove these contaminated fumehoods, gloveboxes, and ventilation systems, these 

engineering controls were breached and no longer became effective in minimizing inhalation uptakes. 

Contamination within the ventilation ductwork would have been an additional source of uptakes. Not always 

being aware of the presence of radionuclides in specific demolition areas and/or researcher-handling areas 

made it difficult to adequately prevent, monitor, and detect uptakes of these radionuclides. 

Issue 6: Closed during the 6/11/2009 WG meeting see transcript page 51. TBDs updated in 2011. 

SC&A response – 01/05/2016: Open; discussed at the 11/19/2012 WG meeting. SME from January 2012 interviews indicated that all the contract employees 

were monitored by Pinellas RadSafe, before, during and after the D&D operations. Issue remained open pending NIOSH receipt of confirmatory D&D 

monitoring records from Albuquerque (11/19/2012 transcript, pp. 53–54). 

7 Missing internal dose 

estimation methods for 

unmonitored workers, e.g., 

maintenance and support 

personnel, not provided. 

It is not clear from the internal dosimetry TBD (ORAUT-TKBS-0029-5), how dose estimation would be 

performed for maintenance and support workers who were not classified as radiation workers and who had 

access to Pinellas Plant radiological operations. Section 5.9.1 of ORAUT-TKBS-0029-5 contains the 

statement: 

All HTO and Plutonium potentially exposed workers have likely been monitored. 

The basis for this statement needs justification, particularly in light of the fact that tritium use and contamination 

were common in many Pinellas areas that may have been assessable to maintenance and, possibly, 

administrative personnel. However, no guidance is provided in this TBD with respect to missed dose 

calculations for unmonitored workers in the category of support personnel, whose actual jobs (contamination 

spill cleanup, equipment maintenance, janitorial functions) and whose access to various Pinellas buildings may 

have led to radionuclide exposures over their job history. It is also not clear how the designation of 

“radiological worker” was historically defined at Pinellas, and how workers were selected on this basis for 

bioassay for various operations. 

Issue 7: Closed see 11/19/2012 WG meeting see transcript, p. 55. TBDs updated in 2011. 

SC&A response – 01/05/2016: concur: 

However, there is some confusion here. The issue closed on p. 55 of the 11/19/2012 transcript was not Finding 7 (above) from the original issues matrix. 

Rather, it was the 7th item that SC&A was tasked to look at during the October 2011 WG meeting (TBD-3 issues). 

Finding 7 from the original matrix (missing internal dose estimation methods for unmonitored workers), TBD-5 Rev. 02 addresses SC&A’s concerns. Our 

review of the tritide model is underway and will be delivered before the February 2016 WG meeting. The NIOSH "whole-body dose" coworker model includes 

a tritium component in addition to neutron and external gamma dose assigned at the 95th percentile. That, in combination with no documented plutonium 

exposure potential (Issue 3) and the closure of secondary Issue 2 regarding Ni-63 and C-14, appears to address other aspects of Finding 7. 

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8 Potential for missed dose for 

depleted uranium. 

Section 2.3.2 contains a discussion of depleted uranium, including the statement: 

The depleted uranium metal was fully contained inside the storage flask, and no information 

could be found to indicate that depleted uranium metal was released during plant operations 

(Ward, p. 12). 

Interviews with a former employee raised the possibility of loose depleted uranium (DU) contamination in an 

area of Building 100. There were no bioassay programs in place to determine internal dose from exposure to 

DU, thus DU internal exposure could represent a significant source of unmonitored exposure. There is 

minimal information in ORAUT-TKBS-0029-2 on the production of the tritium beds, so it is not possible to 

discern if the process involves operations that could lead to internal exposures. Further discussion of the DUrelated process is in order. 

Issue 8: Closed during the 6/11/2009 WG meeting; see transcript, p. 51. TBDs updated in 2011. 

SC&A response – 01/05/2016 Concur - discussed pp. 58–64 of the 6/11/2009 WG transcript. Cutting of DU beds took place in Milwaukee, not at Pinellas. 

9 The TBD fails to adequately 

define and assess 

occupational medical 

exposure. 

The current guidelines, as presented in Kathren and Shockley (2003), go a long way to assuring that all 

occupational medical exposures are reasonably included in determining the overall dose estimations for 

claimants. Unfortunately, the interpretation, to date, by the contractor, ORAU, has not been applied 

conservatively to be claimant favorable. The occupational medical dose TBD (ORAUT-TKBS-0029-3) 

assumes an interpretation, which also has been considered and applied at other sites, such as the Mound Plant, 

Los Alamos National Laboratory (LANL), and Paducah. To this extent, the assumption that medical 

procedures are limited to only one pre-employment chest x-ray and chest x-rays which are part of routine 

physical exams, may substantially underestimate worker medical exposure when evaluating occupational 

medical exposure. 

In more recent documentation, OTIB-0006, Revision 3 (Kathren and Shockley 2005), it is concluded that 

other examinations should be included, such as special screening exams (e.g., respiratory protection, beryllium 

workers, asbestos workers, etc.) and termination exams. The occupational medical TBD does not recognize 

this change from the previous Revision 2 of the OTIB, and also assumes that special chest radiography for 

respirator certification, beryllium and asbestos workers, and food handlers are accomplished as part of the 

routine physicals. This is not documented in the medical TBD. Another factor not discussed in the TBD is 

the potential and impact of x-ray procedures utilized by medical authorities to do special screenings that are 

performed outside the frequency suggested in the TBD. 

The TBD (ORAUT-TKBS-0029-3) makes the conclusion that chest examinations are often quite limited after 

1974, after which KUBs were no longer taken in addition to chest x-rays. It is suggested the policy was every 

5 years before age 40, and every 3 years after age 40, but nothing is documented. To the contrary, there is 

ample evidence that chest x-rays were often provided on a voluntary basis to nearly all workers, usually on an 

annual basis. The majority of workers had chest x-rays as a routine at DOE sites until the mid-1980s, when 

federal guidelines warning against routine screening were first being enforced. 

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After discussion with NIOSH personnel, it was their decision to limit occupational medical exposure to those 

chest exams described above, and to conclude all other exposure as part of worker background. SC&A 

believes such an interpretation is not claimant favorable to those most at risk. Our concern is that specified 

“high-risk” workers, those most likely exposed to radiation and beryllium, would be at risk of having an 

incomplete dose assessment, if not all radiation associated with medical screening for job-related activities 

were included. Since all radiation provides some risk, and arguably is cumulative, workers warrant 

consideration of all forms of work-related x-ray exposure to be claimant favorable. SC&A believes NIOSH 

should review its interpretation of included medical exposure, and should reasonably adopt a broader 

interpretation of occupational medical dose, as provided in the most recent version of the OTIB (Kathren and 

Shockley 2005). 

Issues 9, 10 and 11: Closed at the 6/11/2009 WG meeting see transcript page 64-68. TBDs updated in 2011. 

SC&A response – 01/05/2016 Concur. Actually closed out at the November 19, 2012, WG telcon. See transcript p. 54. 

Related to our review of the TBD-3 revision. That revision was not available until after the October 2011 WG meeting. Our subsequent review of the TBD 3 

revision closed out Findings 9–11 and Secondary Finding 1 from the original issues matrix, all of which were related to TBD-3. 

10 Techniques and protocols 

increase uncertainty of DCFs 

listed in the TBD. 

The TBD in Section 3.2 fails to describe adequately all the information upon which to establish beam quality 

for x-ray units in use from 1957–1997. In 1972, the site documented installation of a single phase GE 225 

unit. There is only limited documentation to show that the GE 225 unit, in use from 1972 through 1997, had 

added filtration; approximately 3.5 mm of AL, as first measured by the Pinellas Health Department in 1972. 

In the absence of definitive tube output measurements, the TBD directs the use of default values and DCFs 

derived from ICRP Report No. 34 (ICRP 1982). These values are then applied to determine organ doses using 

Tables A.2 through A.8 of ICRP Report No. 34 (ICRP 1982). An issue of concern is that the DCFs are 

derived using a default HVL of 2.5 mm Al for Type 1 units, in use from 1946–1980. 

The occupational medical TBD (ORAUT-TKBS-0029-3) provides little documentation to support the assumed 

techniques and protocols applied to calculate the dose, which is mainly derived from NCRP Report 102. The 

TBD states that a PA chest x-ray was typically the only view. An undocumented assumption in the TBD is 

that exams required only a PA view. SC&A has inquired whether definitive protocols existed to validate that 

chest exams included PA views and LAT views, only on a limited basis after 1974. NIOSH has 

acknowledged in other TBD reviews that the lack of verifiable protocols is a generic problem at many sites, 

has planned to search all available records, and will include pertinent records and references in any future 

revision of this section of the TBD. 

The occupational medical TBD is also deficient, in that little documentation exists to validate x-ray protocols, 

equipment maintenance and upkeep records prior to 1972. 

Issues 9, 10 and 11: Closed at the 6/11/2009 WG meeting; see transcript pp. 64–68. TBDs updated in 2011. 

SC&A response – 01/05/2016 Concur. See response to issue 9. 

The occupational medical TBD relies on a very limited review of archived medical records to establish 

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11 Frequency and type of x-ray 

exposure is uncertain. 

frequency assumptions. The assumption of one chest radiograph (PA) every 3 to 5 years is not reasonably 

conservative, in that workers could essentially request an x-ray, or be subject to special screening exams. The 

frequency of screenings, and number and type of workers receiving x-rays does vary from site to site. 

The occupational medical TBD in Section 3.2 provides no documentation or references to support the 

assumption that only a limited group of workers received x-ray exams more frequently than every 5 years after 

1974. To the contrary, up until about 1985, most DOE sites performed chest x-rays almost on a voluntary 

basis. DOE medical program reviews documented, during the early 1990s, showed many sites still used chest 

radiography as a general screening exam. Most workers accepted chest x-rays, even though the job did not 

require it. Also, the assumption that workers in special exposure categories, such as beryllium workers, were 

given chest x-rays only as part of their routine physical is not well documented and not consistent with special 

screening guidelines. The TBD applies no conservative assumption to cover such exams. 

The occupational medical TBD in Section 3.2 states that photofluorography (PFG) units, although generally 

available up to the late 1950s at most DOE sites, were not documented as being used at the Pinellas Plant. The 

undocumented absence of PFG units at Pinellas clearly has significant dose implications to workers who may 

have been given much higher doses from PFG units. The PFG unit provides a dose to the worker greater by a 

factor of 5–6, more than that delivered by conventional radiography. The TBD does not provide 

documentation for the types of equipment in use at Pinellas prior to 1972. SC&A believes it is not claimant 

favorable to instruct dose assessors to assume only PFG unit use from 1957–1960. To be fully claimant 

favorable, it would be appropriate to instruct dose assessors to use an annual dose of 3.0 rem per year for chest 

radiographs, in accordance with guidelines set forth (Kathren 2005) until the review of medical records 

evidenced no further use of a PFG unit at Pinellas. 

Issues 9, 10 and 11: Closed at the 6/11/2009 WG meeting; see transcript pp. 64–68. TBDs updated in 2011. 

SC&A response – 01/05/2016 Concur. See response to issue 9. 

Secondary 

Issue 1 

Additional factors contribute 

to uncertainties related to 

occupational medical 

exposures. 

The Occupational Medical Dose TBD does not consider dose impacts due to less than optimal use of 

technology, such as using screens, grids, or bucky systems. The TBD does not consider these elements as 

potential contributions to uncertainty. 

The TBD does consider the potential contribution to dose that may have resulted in less than optimal use of 

collimation, at least prior to 1972, as stated in Section 3.3.2 of the TBD. Unresolved is the concern that the 

DCFs are derived from ICRP (1982), and therefore are not comparable in terms of beam quality, which varies 

from unit to unit. These factors can contribute greatly to the dose to the chest and other organs; for the unit in 

other TBDs in operation prior to 1997, little or no documentation exists. NIOSH has indicated in other TBDs 

that it will continue to search for other available records to better define equipment use and beam quality, and 

include it as appropriate in an updated version of the TBD. 

Uncertainty is defined in the TBD as being due to measurement error and variation in kilovoltage, tube 

current, timers, and the skin-to-surface distance (SSD). This approach is quite similar to the uncertainty 

analyses documented in other DOE site profiles. The conclusion in this TBD and others is that dose 

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reconstructors for exposure prior to 1997 should use an uncertainty factor of +30%. SC&A believes the 

uncertainty correction factor of 2.0 being applied at other sites is more appropriate for use. 

SC&A agrees that the TBD conservatively estimates these essential aspects of an uncertainty review. 

Unresolved is the contribution to uncertainty in dose, due to other errors introduced by lack of quality controls 

in processing equipment and lack of adherence to established Standard Operating Procedures. A reasonable 

estimate of these contributions to uncertainty would be an evaluation of retake rates per examination type. 

NIOSH should revisit the potential for significant retake rates and evaluate its potential effect on dose as part 

of future revisions of this TBD, especially as it relates to prior to 1972. 

The Occupational Medical Dose TBD does not show that Pinellas applied dose minimization principles to 

reduce medical exposures. The document also does not assess or consider the likely exposure to workers who 

are referred to offsite medical facilities for follow-up. The TBD states that review of selected medical records 

and files did not reasonably show or match expected x-ray exam frequency and type of exam, as shown in 

Table 3.1.1. Little evidence exists to document the number of x-ray exams provided to the average worker, or 

for special exposure needs. 

See Issues No. 9 and 11. This secondary issue was completed with the disposition of the primary issues. 

SC&A response – 01/05/2016 Concur. See response to issue 9. 

Secondary 

Issue 2 

Inadequate descriptions for 

certain plant operations 

The Site Description TBD, ORAUT-TKBS-0029-2, provides information on plant operations as they relate to 

understanding the source and relative magnitude of radionuclide doses. The information is sufficiently 

complete in the case of operations involving tritium, krypton, and plutonium. The TBD inadequately 

describes operations involving Ni-63, C-14, and particularly DU and metal tritides. The TBD should be 

revised to provide the reader with a greater understanding of processes utilizing the indicated nuclides. 

See Issue No. 7. This secondary issue was completed with the disposition of the primary issues. 

SC&A response – 01/05/2016 Concur. 

Ni-63 and C-14 aspects in abeyance as of 6/11/09 pending addition of new information to the TBD. Incorporated into TBD-5 Rev. 1 (Apr 2011). 

DU issue closed – no longer relevant (see Finding 8) 

Secondary 

Issue 3 

Perimeter tritium monitoring 

stations 

Tritium air monitoring stations were operated on the perimeter of the site for a major part of the plant 

operating history. Up to six samplers were continuously operated and collected samples for determining 

tritium gas and oxide airborne concentrations. The existence of these stations is not mentioned in ORAUTTKBS-0029-4. This is a missed opportunity to verify the modeling results by comparing them to measured 

values. 

This secondary issue was closed during the June 11, 2008, WG meeting. 

SC&A response – 01/05/2016. Concur. Discussion on 6/11/08, transcript pp. 127–131. information provided in Section 4.4.1 of TBD-4 Rev. 01 (7/15/2011) 

Secondary Inadequacy of ORAUTTKBS-0029-4, Section 4.4 – 

This section is inadequate and needs to be reworked to more adequately address the topic it is intended to 

discuss, i.e., uncertainty. The discussion in this section centers on factors that affect the quantity of dose 

calculated, and not the uncertainty associated with estimates. While it may not be possible to quantify the 

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Issue 4 Uncertainty uncertainty of estimated doses, a more relevant discussion on the relative magnitude and factors affecting 

uncertainty is needed. 

This secondary issue was completed with the completion of the primary issues. 

SC&A response – 01/05/2016. Concur. Discussed pp. 131–132 of 6/11/2008 transcript. More information provided in TBD-4 Rev. 01, Section 4.5. 

Secondary 

Issue 5 

Rejection of plutonium 

bioassay results based on 

plutonium-238-to-plutonium239 ratios, and non-detectable 

plutonium-239 

In ORAUT-TKBS-0029-5, two conditions for rejection of a positive plutonium bioassay result as follows: 

The ratio of 238Pu to 239Pu in a bioassay sample must be about 5:1 (±20%) or 238Pu is detected 

while 239Pu is not detectable. 

The meaning of “(±20%)” in this statement is not clear. Does it mean the range of ratios to be rejected is from 

4 to 6? This inclusion needs further explanation. 

The application of these criteria to plutonium bioassay results for the 3 years discussed in the TBD (1988, 

1989, and 1990) was responsible for approximately 30% of the samples being designated as non-positive. The 

high degree of uncertainty associated with alpha spectrometry results at the levels of Pu-238 expected in 

bioassay samples makes the use of such a ratio as a reason for rejecting a positive Pu-238 questionable. 

These results should be reviewed on an individual basis, in that the use of this criterion, because of the 

relatively large uncertainties associated with values near the detection limits for plutonium, could result in the 

rejection of positive Pu-238 results. At a minimum, this would have prevented an investigation into the 

circumstances that could have led to the positive result. 

See Issue No. 3. This secondary issue was completed with the disposition of the primary issues. 

SC&A response – 01/05/2016. Concur. 

Secondary 

Issue 6 

Plutonium solubility 

In ORAUT-TKBS-0029-5, page 16, the following statement is made: 

ICRP Publication 68 lists plutonium oxides as absorption type S (ICRP 1995, p. 83). A 

discussion of absorption type for plutonium oxides in ICRP 71 indicates that bioassay data 

from accidentally exposed workers to 238PuO2 could have been closer to type M (ICRP 1996, 

p. 329). 

Page 329 of ICRP 71 (ICRP 1996) also states that plutonium can have different lung clearance characteristics 

when inhaled as mixed metal oxide. The extent of increased dissolution/clearance depends on the metal and 

the relative proportions of plutonium to metal. Since there is an uncertainty on the definition of the solubility 

rates for Pu-238, and there is no clear definition of the solubility of the handled compound, the selection of the 

type of compound for dose reconstruction should be the one that is more claimant favorable. For some 

scenarios, the selection of Type M compound is not the claimant-favorable approach. 

This secondary issue was completed with the completion of the primary issues. 

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SC&A response – 01/05/2016. Concur 

Secondary 

Issue 7 

Assumptions relative to 

unmonitored workers 

ORAUT-TKBS-0029-6, Section 6.4.1, contains the following statement: 

The analysis assumed that unmonitored (i.e., nonradiation) workers did not receive a significant 

dose compared to monitored workers; therefore, assigning a photon dose distribution for each 

year based on the dose received by monitored workers would ensure a claimant-favorable 

estimate of any unmonitored worker dose. Based on the review of the available dosimetry 

data, employees with any significant potential for external dose exposure appear to have been 

routinely monitored, as evidenced by the large number of monitored individuals that routinely 

had doses below the reporting levels. Therefore, it is reasonable to assume that unmonitored 

workers received less dose than monitored workers at the Pinellas Plant. 

The fact that a large number of monitored individuals routinely had doses below reporting levels may give 

some level of comfort that workers with a significant potential for external dose were adequately monitored, 

but it is not proof. Neither does it lead to the automatic conclusion that unmonitored workers received less 

dose than monitored workers. These assumptions may be true, but can only be verified if there is reasonable 

certainty that unmonitored workers were not subjected to different exposure potential or conditions than 

monitored workers. For example, unmonitored maintenance and janitorial personnel could be exposed 

during routine maintenance, waste removal, and cleaning operations to levels that exceeded those of 

operational personnel. 

See Issue No. 4. This secondary issue was completed with the disposition of the primary issues. 

SC&A response – 01/05/2016. Concur 

Secondary 

Issue 8 

Assumptions relative to 

minimum detectable level 

adjustments to dosimetry for 

missed dose 

In Section 6.4.1.1, ORAUT-TKBS-0029-6, the following statement is made: 

Missed dose is primarily estimated on dosimeter results n (the number of zero or < MDL 

values) multiplied by MDL/2. The MDL is particularly important during the early years of 

operation, when MDLs were probably higher and the dosimeter exchange rate was monthly 

rather than quarterly. One option to estimate a claimant-favorable maximum potential dose is 

to multiply the MDL by the number of zero dose results. This will provide an estimate of the 

maximum missed dose to the worker. The following sections consider missed photon dose for 

dosimeter results less than the MDL according to facility or location, dosimeter type, year, and 

energy range. 

It is not clear from this discussion which approach was taken to adjusting dosimeter results in the analyses and 

Table 6-11, following this statement. A definitive statement indicating the selected approach should be made 

in this TBD. 

This secondary issue was completed with the disposition of the primary issues. 

SC&A response – 01/05/2016. Closed – language clarified in Section 6.4 of TBD-6 Rev. 1. 

Draft Pinellas Issues Matrix - Updated 9 SC&A – January 6, 2016