Draft White Paper 

SC&A REVIEW OF ISSUES RELATED TO RECONSTRUCTION OF 

DOSES FOR WORKERS EXPOSED TO RECYCLED URANIUM AT 

FERNALD – A SECOND WHITE PAPER 

 

Contract No. 200-2009-28555 

Revision 0 

Prepared by 

John Stiver, MS, CHP 

Robert Alvarez 

Robert Barton III 

Harry Chmelynski, PhD 

James Werner 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

 February 2011 

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 Description: 

A Second White Paper: 

Recycled Uranium at Fernald 

Effective Date: 

Draft – February 4, 2011 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 0 (Draft) 

SC&A Review of Issues Related to Reconstruction of 

Doses for Workers Exposed to Recycled Uranium at 

Fernald – A Second White Paper 

Page 2 of 89 

Task Manager: ___________________ Date: 

 John Stiver, MS, CHP 

Supersedes: 

N/A 

Project Manager: _________________ Date: 

 John Mauro, PhD, CHP 

Reviewer: 

 John Mauro, PhD 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 02/04/2011 Initial issue 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................5 

Statement of Purpose .......................................................................................................................8 

1.0 Historical Milestones Leading Up to This Review..............................................................9 

2.0 Summary of Findings.........................................................................................................10 

2.1 Previous Findings...................................................................................................10 

2.2 Summary of Additional Findings from This White Paper Report.........................11 

3.0 Background – Transuranics and Fission Products in Recycled Uranium..........................13 

3.1 Historical Overview...............................................................................................13 

3.2 Fernald Site Process Descriptions and Workplace Exposure Conditions..............15 

4.0 NIOSH Default RU Contaminant Values – Basis and Applicability ................................19 

4.1 Dosimetric Implications of the Default Levels......................................................19 

4.2 Health Physics Practices at Fernald – Implications for RU Doses........................20 

4.3 Basis for NIOSH Defaults .....................................................................................27 

4.3.1 Basis for the 10 ppb Guideline for Plutonium ...........................................27 

4.3.2

......................................................................................30 

Basis for NIOSH Np-237, Tc-99, and Fission Product Defaults 

(other than Tc-99)

4.3.3 Additional Commentary on DOE 2000b ...................................................37 

5.0 Site-Specific Data – Air Concentrations and Feed Material Measurements .....................44 

5.1 1985 Dust Collector and Scrubber Solution Samples (Fernald 1987)...................44 

5.1.1 Dust Sampling Process ..............................................................................45 

5.1.2 Gaps and Limitations in the Dust Collector and Scrubber Data................47 

5.1.3 Attributes of the Dust Collector and Scrubber Data ..................................49 

5.1.4 Lognormal Fit to Dust Collector Data .......................................................53 

5.2 Perimeter Air Sampling Data (Fernald 1987 and DOE 1985)...............................56 

5.3 Air Samples and Swipes - Plants 4 and 8 ..............................................................57 

5.4 PUREX UNH Data from Hanford .........................................................................60 

5.5 Other Data Sources Reviewed by SC&A ..............................................................62 

6.0 References..........................................................................................................................64 

Attachment 1: Expanded Analysis of Lognormal Versus Bootstrap Means in Fernald 

Recycled Uranium Data.....................................................................................................68 

Attachment 2: Additional Information Concerning Dust Collector Samples Taken in 1985 

and Presented in Appendix B of NIOSH White Paper ......................................................71 

Attachment 3: Normal Score Plots for Dust Data.........................................................................74 
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LIST OF TABLES 

Table 1. Percent of Total Uranium Activity Added to Air Monitoring Sample .........................19 

Table 2. RU Dose Ratios Greater than Unity Given the NIOSH Default Ratios........................20 

Table 3. Recycled Uranium Summary Values by Process Subgroups........................................31 

Table 4. Dust Collector and Scrubber Samples with High Concentration Ratios.......................50 

Table 5. Parameters of Lognormal Distributions Fitted to Filter Dust Ratios............................54 

Table 6. Boundary Air Sampling Results – 1983 .......................................................................57 

Table 7. Plant 4 – Sample Comparison.......................................................................................58 

Table 8. Plant 8 – Sample Comparison.......................................................................................59 

Table 9.

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

Analytical Data on Five Shipments from West Valley to Fernald Suspected of 

Containing Elevated Neptunium Levels

Table 10.

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

Summary Statistics for Plutonium and Thorium Contaminant Data in Shipments 

Between West Valley and Fernald
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ABBREVIATIONS AND ACRONYMS 

Advisory Board 

or ABRWH Advisory Board on Radiation and Worker Health 

ADU Ammonium diuranate 

AEC Atomic Energy Commission 

AM Arithmetic Mean 

Bq becquerel 

BZ Breathing Zone 

CAM Continuous Air Monitor 

CCZ Clothing Control Zone 

cpm counts per minute 

DAC derived air concentration 

DC dose coefficient 

DOE U.S. Department of Energy 

dpm disintegrations per minute 

DU depleted uranium 

EEOICPA Energy Employees Occupational Illness Compensation Act of 2000 

EM Environmental Management (DOE Office of) 

EU Enriched uranium 

FMPC Feed Materials Production Center 

FEMP Fernald Environmental Management Project 

g gram 

GA General Area 

GDP Gaseous diffusion plant 

GM Geometric Mean 

GSD Geometric Standard Deviation 

kg kilogram 

LOD limit of detection 

μCi microcuries 

M&O Management and operations 

m3 cubic meter 

MDL Minimum detectable level 
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MgF2 magnesium fluoride 

mL milliliter 

MPC maximum permissible concentration 

MT metric tons 

MTU Metric tons uranium 

NCG National Lead Company of Ohio Concentration Guide 

NFS Nuclear Fuel Services 

NIOSH National Institute for Occupational Safety and Health 

NLCO National Lead Company of Ohio 

NLO National Lead of Ohio 

NU Natural uranium 

OR Oak Ridge 

ORAUT Oak Ridge Associated Universities Team 

ORO Oak Ridge Office 

PDF portable document format 

PGDP Paducah Gaseous Diffusion Plant 

POOS Plutonium out of specification 

ppb parts per billion 

ppm parts per million 

PTA plant test 

PUREX Plutonium URanium EXtraction 

pCi picocuries 

RCZ Respiratory Control Zone 

RU Recycled Uranium 

SA specific activity 

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

SD Standard Deviation 

SEC Special Exposure Cohort 

SOP Standard Operating Procedure 

SRDB Site Research Database 

SR Savannah River 

SRS Savannah River Site 
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Sv sievert 

TBD Technical Basis Document 

TBP Tri-butyl phosphate 

TRU Transuranics 

U uranium 

UF4 uranium tetrafluoride 

UF6 uranium hexafluoride 

UNH Uranyl nitrate hexahydrate 

UO2 uranium dioxide 

UO3 uranium trioxide 

U3O8 black oxide 

WMCO Westinghouse Materials Company of Ohio 
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STATEMENT OF PURPOSE 

This second white paper on recycled uranium (RU) was prepared by SC&A in response to an 

action item from the Advisory Board on Radiation Worker Health (the Board) that emerged from 

the Fernald Work Group meeting held on November 9, 2010, in Cincinnati, Ohio. The first 

aspect of that action item was that SC&A provide a formal response outlining the basis for the 

conclusion that the subgroup process means derived from the U.S. Department of Energy (DOE) 

Ohio Field Office Report (DOE 2000b) and reported in Table 5 of the NIOSH white paper, Dose 

Reconstruction Considerations for RU Contaminants at Fernald (NIOSH 2008), do not provide 

a firm basis for bounding default levels of transuranics (TRU) and fission products in RU. While 

SC&A believes that our white paper submitted to the Board in March 2009 entitled, SC&A’s 

Review of Issues Related to Reconstruction of Doses for Workers Exposed to Recycled Uranium 

at Fernald: Commentary on the NIOSH White Paper (SC&A 2009), adequately presents our 

position on this issue, we have nonetheless restated key unresolved points from that report and 

included additional information to support the basis for our conclusions. 

The Board also requested that SC&A provide a focused review of available data pertaining to 

measurements of TRU and fission products in RU at Fernald for their applicability in assessing 

whether the default levels reported in Table 10 of NIOSH 2008 are bounding in the context of a 

Special Exposure Cohort (SEC) petition. As such, our review addresses the ability of NIOSH to 

bound the RU dose (or estimate a dose more accurately than a bounding dose) for all workers in 

the proposed SEC class, which extends from 1951 to 1989, the year in which production 

activities at Fernald ceased permanently. 

The principal dataset that SC&A was requested to review is for dust samples collected at several 

buildings at Fernald in 1985 and reported in Appendix B of NIOSH (2008). SC&A also 

identified three other site- and process-specific datasets that bear on this issue. They are 

continuous air monitor (CAM) samples collected at six locations along the Fernald site perimeter 

in 1983 (DOE 1985); air filter and smear samples collected in Plants 4 and 8 in 1989 (Bassett et 

al. 1989), and levels of Pu-239 and Np-237 reported in batches of uranyl nitrate hexahydrate 

(UNH) from the PUREX Plant at Hanford in 1970–1971 (ARH 1969a, 1969b, 1969c, 1970a, 

1970b, 1972a, and 1972b; Ward 1968). This last dataset, while several steps removed from what 

workers may have experienced at Fernald, is important for assessing the adequacy of production 

specifications and controls that NIOSH claims were in place and rigidly adhered to during that 

timeframe that Fernald received RU shipments.
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1.0 HISTORICAL MILESTONES LEADING UP TO THIS REVIEW 

A brief summary review of the historical background of recycled uranium white paper exchanges 

and associated discussions is appropriate and should help place this response in proper 

perspective. 

During the Fernald work group meeting held on October 28, 2008, SC&A was tasked with 

reviewing the NIOSH white paper on RU. The direction provided by the Board stated that 

SC&A should focus on the appropriateness of the default values selected for RU contaminants 

(Plutonium-239/240 (referred to herein as Pu-239), Neptunium-237 (Np-237), and Technecium99 (Tc-99) and whether the selected values are bounding for all workers for all time periods. 

SC&A’s white paper on this issue (SC&A 2009) identified 11 deficiencies (findings) in the 

NIOSH white paper, which were the subject of extensive discussion in the January 29, 2010, 

work group meeting. SC&A 2009 and the discussion provided in the January 29, 2010, meeting 

transcript thoroughly describe SC&A’s concerns regarding RU. During the January 2010 work 

group meeting, NIOSH stated that it was not prepared at that time to address the various issues 

raised, but agreed to prepare a response. 

Prior to the November 9, 2010, work group meeting, NIOSH submitted the report, Response to 

SC&A Findings related to the White Paper on Recycled Uranium at Fernald - October 2010, 

(NIOSH 2010) which provided NIOSH’s position on each of the 11 findings in SC&A 2009. 

The 11 findings and NIOSH’s responses to them were the subject of intensive discussion at the 

November 9, 2010, meeting. Two principal unresolved issues that emerged from that meeting 

prompted the Board’s request for this second white paper. First, SC&A provided a compelling 

argument as to why the 19 subgroup process means derived in DOE 2000b do not provide a firm 

basis for bounding defaults for TRU and fission products. Second, SC&A’s preliminary review 

of the dust collector data reported in Appendix B of NIOSH 2008 indicates that the NIOSH 

default values may not be bounding for some classes of workers in some facilities during the 

proposed SEC period.
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2.0 SUMMARY OF FINDINGS 

2.1 PREVIOUS FINDINGS 

SC&A 2009 identified several findings (deficiencies) in NIOSH 2008 regarding RU that have 

not been resolved. Findings 3 through 5, Finding 10, and Finding 11 are most pertinent to the 

scope of this second white paper and are replicated as follows: 

Finding 3: The exact amount of RU processed in any given year is not directly 

connected to dose reconstruction procedures or results. However, the assignment 

of trace contaminant concentrations in the absence of a resolution of major 

materials accounting discrepancies may remain questionable, especially for those 

time periods for which no trace contaminant data are available. 

Finding 4: A corollary of the above findings is that the suitability of the use of 

the materials balance analysis done by the DOE for developing bounding dose 

estimates (or dose estimates more accurate than that) for the purposes of the 

Energy Employees Occupational Illness Compensation Program Act (EEOICPA) 

has not been adequately established. 

Finding 5: NIOSH has not taken into account the RU originating in the Hanford 

U Plant during the period of uranium recovery from high-level waste. This RU 

may have characteristics in regard to trace radionuclides, including fission 

products that are very different from the ratios that NIOSH proposes to use. The 

validity of the ratios in the NIOSH paper for RU originating in the U Plant 

(directly or via some other DOE facility) has not been established. .... 

Findings 10 and 11 from SC&A 2009 are unresolved findings related to the attribution of 

surrogate data to site processes and the statistical analysis used to justify the default values. 

Finding 10: NIOSH has not analyzed the underlying raw data or the many 

assumptions in the DOE Ohio field office analysis of the RU data for its 

applicability to dose reconstruction (rather than to a materials balance exercise). 

The use of assumptions about the similarity of materials streams in regard to 

trace contaminant values—that is, of surrogate data—without an actual 

examination of the underlying processes at the facilities from which the RU 

originated and the period in which they originated, is questionable in a dose 

reconstruction context, as well as in an SEC context.

Finding 11: A preliminary review of the analysis in DOE 2000b indicates that 

the bootstrap analysis method may be inappropriate in a dose reconstruction 

context; it does not appear to be claimant favorable. Assuming the data are 

suitable for use in dose reconstruction, the use of lognormal distribution appears 

to be more appropriate. 
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2.2 SUMMARY OF ADDITIONAL FINDINGS FROM THIS WHITE PAPER 

REPORT 

Finding #1: Questionable basis for NIOSH presumptions regarding the integrity of Fernald 

radiation safety programs prior to 1986 

The DOE RU reports and related historical references indicate that prior to 1986, the radiation 

safety program at Fernald was probably not adequate to control potential exposures from 

contaminants in RU. In all likelihood, the 1986 changes were implemented by the new M&O 

contractor in response to problems encountered during RU processing in the preceding years. 

This raises concerns regarding NIOSH’s reliance on the integrity of such programs as assurance 

that their defaults were not exceeded during the proposed SEC period. This is not only of 

concern during the early years of RU processing but also during the 6 years that had elapsed 

from the time the most contaminated RU material was received in 1980 until the new program 

elements were implemented. 

Finding #2: Questionable basis for NIOSH default plutonium concentration 

A formal specification for maximum transuranic and fission product contaminants in uranium 

recycle material had probably not existed either within or between sites. In fact, the only formal 

limit adopted by the Atomic Energy Commission (AEC) for RU was adopted in 1971 to 

accommodate commercial fuel shipments to the gaseous diffusion plant (GDP). The fact that 

there are several orders of magnitude of variability in the 4,000 analytical results reported for 

Pu-239 in DOE 2000b raises concerns as to NIOSH’s reliance on the Hanford ‘working 

specification’ of 10 ppb as the basis for their default plutonium concentration. SC&A believes 

that a re-analysis of the data to determine if there are classes of workers that are not sufficiently 

bounded by the current methodology would be highly beneficial. 

Finding #3: NIOSH provides no clear basis for the choices of 3,500 and 9,000 ppb U for 

Np-237 and Tc-99 defaults 

NIOSH indicates that data from Table 5 of their RU white paper were used to develop the default 

activity ratios for use in the absence of specific bioassay data for workers involved in any of 

these process subgroups. However, it is not clear to SC&A how the values of 3,500 and 

9,000 ppb U for Np-237 and Tc-99 (and the ratios of 35 and 90 for Np/Pu and Tc/Pu) were 

derived from these sub-group means. 

Finding #4: DOE 2000b is questionable as the basis for the NIOSH defaults; Source data 

should be reviewed in the context of an SEC Petition 

The DOE 2000b report for RU data is neither comprehensive nor reliably representative and 

rigorous in its scrutiny of data validity. Clearly the subgroups listed in Tables ES-5A, 5C and 

5D are not sufficiently detailed to reflect the wide range of RU sources that would result from 

analysis of the permutations of processing facility, process operations, time of operation and 

fuel/target type. It is incumbent on NIOSH to review the source data for its adequacy in 

bounding worker doses in an SEC context. 
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Finding #5: Gaps and limitations in the dust data render them questionable as a basis for 

establishing default levels of contaminants in RU for the SEC period 

SC&A believes that the 1985 dust collector data alone are not adequate as a basis for establishing 

default levels of RU contaminants. However, we believe that they have some utility in 

determining whether the NIOSH defaults are bounding for all classes of workers at Fernald 

during the proposed SEC period and potentially for estimating intakes for some classes of 

workers in the 1980s. 

Finding #6: Dust data do not support NIOSH defaults for some classes of workers in some 

facilities 

The Plant 1 and Plant 5 dust data, while limited in space and time, tend to support the 

concentration and persistence of RU contaminants in those facilities, and suggest that some 

classes of workers were potentially exposed to levels of RU contaminants in excess of the 

NIOSH defaults. 

Finding #7: Boundary air concentrations of Pu do not support NIOSH defaults and are 

consistent with elevated levels observed in dust collector data 

Elevated plutonium ratios in site boundary air measurements appear to correlate with the onset of 

processing of the highly contaminated Paducah tower ash shipments and are consistent with the 

elevated levels in Plants 1 and 5. Note also that one would expect boundary air concentration 

ratios to be lower than Plant 1 and 5 source effluents due to dilution with uncontaminated 

uranium from other stacks. 

Finding #8: The 1989 air sampling data for Plants 4 and 8 do not support the NIOSH default 

levels as bounding. Potentially significant worker doses could have resulted from off-normal 

events. 

The statements in Bassett et al. 1989 indicate that the limited set of 24-hour air collections do not 

reflect incidents with high exposure potential such as the spills, hydrofluorination bank failures 

in Plant 4 or furnace temperature excursions in Plant 8, as identified in DOE 2000b 

(Table D.1-15). While measured air concentrations were low, the mass fractions of Pu and Np 

were high, exceeding the defaults in several instances. During high dust loading events, these 

levels could result in significant exposures to workers. 

Finding #9: The Hanford UNH data from the early 1970s suggest that the working 

specification for Pu was exceeded on a frequent basis with some batches much higher than the 

NIOSH default. 

While it is recognized that this material could have been down-blended at later steps in 

production, it remains unclear whether batches of UO3 in excess of the NIOSH default were 

shipped to Fernald and if so, whether Fernald personnel were aware of it and took precautionary 

measures.
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3.0 BACKGROUND – TRANSURANICS AND FISSION PRODUCTS IN 

RECYCLED URANIUM 

3.1 HISTORICAL OVERVIEW 

RU was uranium that had been recovered from irradiated production reactor fuel and plutonium 

production target fuels. RU was separated in the chemical processing plants at the Hanford, 

Savannah River (SRS), West Valley and Idaho Chemical Processing Plant sites (NIOSH 2008). 

The recovered uranium was sent to other sites for enrichment and to make nuclear fuel for 

reactors and other components (DOE 2003). The reprocessing operation results in two primary 

streams. The stream that was of most interest to the DOE and predecessor organizations was the 

recovery of plutonium for the nuclear weapons program. The secondary stream comprised the 

remaining uranium and was known to contain TRU and fission product impurities. It is this 

secondary stream that is of concern for worker exposures at Fernald during the proposed SEC 

period. 

In August 1999, workers at the Paducah Gaseous Diffusion Plant (PGDP) raised concerns and 

initiated a lawsuit over health and safety issues related to possible exposure to contaminants, 

especially plutonium, in recycled uranium processed at the plant. In response to the workers’ 

concerns, DOE initiated an investigation of the production and use of recycled uranium. In the 

fall of 2000, as a result of this investigation, the principal DOE sites that produced and utilized 

recycled uranium published reports accounting for the production, characteristics, and use of 

recycled uranium at these sites (DOE 2000a, DOE 2000b). The investigation was quite complex 

and considered the operations of the Department and its predecessor agencies over a 47-year 

period, from March 1952 to March 1999. The analysis required the review of thousands of 

Departmental records, dozens of processes, and the participation of many people including site 

and subject experts. 

During preparation and at publication, inconsistencies were noted between shipper and receiver 

data presented in these reports that were caused by accounting differences and the various 

operational definitions of recycled uranium used by the sites to account for the material of 

interest. 

A follow-up investigation was initiated by the Department in the spring of 2002 to review the 

original reports and to reconcile and validate the recycled uranium material values. That new 

report, DOE 2003, presents revised information concerning production, characteristics, and 

shipment of recycled uranium from the chemical processing facilities to the sites initially 

receiving the material for enrichment and component manufacturing. DOE (2003) has generally 

lower values for the amount of RU that was received by Fernald and includes only the receipts 

from the primary generating sites, i.e., the fuel processing plants (NIOSH 2008). 

It appears that Fernald received various chemical forms of recycled uranium from several sites, 

which did not have formal agency-wide, and in several instances, site-specific limits set for 

radionuclide contaminants. They included the following: 
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 Uranium trioxide (UO3) from Hanford and the Savannah River Site (SRS) 

 Fuel fabrication scrap from Hanford 

 U03 ash from the Paducah GDP 

 Oxide salt from the Portsmouth GDP 

 Oxide, ash and uranyl nitrate hexahydrate (UNH) ash from the GDPs 

 UNH from SRS and West Valley 

 UNH from commercial fuel fabrication/recovery plants 

Fernald received RU from Hanford, SRS, and West Valley that was contaminated with low 

levels of transuranic and fission product radionuclides. According to DOE 2003, more that 80% 

of the RU receipts at Fernald originated at Hanford. DOE 2000b indicates that the first shipment 

of RU from Hanford occurred in 1953. DOE 2003 (Table A-9) indicates that approximately 

45 metric tons (MT) of RU were received at Fernald from 1958–1960. Receipts peaked in the 

mid- 1960s and again in the mid-1980s. From 1953 until operations ceased in 1989, RU receipts 

totaled approximately 18,000 MTU (DOE 2003). 

The complex-wide mass accounting in DOE 2003 shows that the use of recycled uranium 

introduced about 500 grams of plutonium into the DOE processing complex. The estimate for 

the amount of neptunium is about 38 kilograms (kg) and for technetium, less than 900 kg. 

Because the PGDP received approximately 71% of the RU shipped from the production sites, it 

also received the majority of the contaminants, including about 354 grams of plutonium, 28 kg of 

the neptunium, and 628 kg of the technetium. Fernald received approximately 15% of the 

material shipped from the production sites and a similar fraction of the contaminants, including 

about 74 grams of plutonium, 5,700 grams of neptunium, and 135 kg of technetium. It is also 

estimated that Fernald received about 71 kg of U-236 with several shipments of enriched 

uranium. The levels of contaminants were typically recorded in parts per billion on a uranium 

mass basis. According to the 1985 Task Force Report on Recycled Uranium (DOE 1985): 

Of all the plutonium estimated to have been received by the FMPC over the past 

24 years (since plant startup), 50 percent of the plutonium was thought to have 

been contained in one shipment of Paducah Feed Plant ash in 1980. About 

32 percent is believed to have been received from the Hanford site. The balance 

of the plutonium came from NFS-West Valley, the SRP [SRS], and other 

miscellaneous sources. (DOE 1985, p. xi) 

SC&A 2009 identified several findings in NIOSH 2008 regarding unresolved inconsistencies and 

gaps in amounts and sources of RU received at Fernald. Findings 3 through 5 are replicated as 

follows: 

Finding 3: The exact amount of RU processed in any given year is not directly 

connected to dose reconstruction procedures or results. However, the 

assignment of trace contaminant concentrations in the absence of a resolution 

of major materials accounting discrepancies may remain questionable, 

especially for those time periods for which no trace contaminant data are 

available. 
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Finding 4: A corollary of the above findings is that the suitability of the use of 

the materials balance analysis done by the DOE for developing bounding dose 

estimates (or dose estimates more accurate than that) for the purposes of the 

Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA) has not been adequately established.

Finding 5: NIOSH has not taken into account the RU originating in the 

Hanford U Plant during the period of uranium recovery from high-level waste. 

This RU may have characteristics in regard to trace radionuclides, including 

fission products that are very different from the ratios that NIOSH proposes to 

use. The validity of the ratios in the NIOSH paper for RU originating in the U 

Plant (directly or via some other DOE facility) has not been established 

[emphasis added]. .... 

It is evident that SC&A’s principal concern is not the total amounts of RU received, but rather an 

apparent incomplete accounting of the contaminant levels in those receipts that were used to 

derive defaults for assignment in dose reconstruction. That is, our concern is whether the 

NIOSH default analyses bound the distribution of concentrations of the contaminants in RU that 

were handled and processed at Fernald. 

3.2 FERNALD SITE PROCESS DESCRIPTIONS AND WORKPLACE EXPOSURE 

CONDITIONS 

Knowledge of the processes that occurred in the various Fernald plants is essential to 

understanding the reasons for elevated levels of RU contaminants in some air sampling data and 

in identification of classes of workers that may have been at risk for enhanced exposure to those 

contaminants. Thus, an overview of Fernald production processes is introduced here. The 

historical production processes at Fernald were conducted in ten production plants, each having a 

specific mission that supplied the succeeding plant with an intermediate product for further 

processing until the eventual uranium form was produced. Detailed descriptions of the processes 

that took place in the various plants and the associated operations with high dust loading 

potential are contained in Appendix D of DOE 2000b (pp. D.1-62-D.1-71). Brief descriptions of 

the plants that had a major role in RU handling and processing and the associated dust loading 

potential for specific operations are as follows: 

Plant 1 – Sampling Plant: Plant 1 became operational in December 1953, and soon thereafter, 

was designated the official AEC sampling station for determining uranium and isotopic assays of 

uranium ores and concentrates. Plant 1 functioned primarily to receive, weigh, sample, and store 

feed materials from offsite sources and process residues generated from onsite production 

operations. Most materials were received in 55-gallon steel drums. The process consisted of 

drying, milling, sampling, and analyzing, as necessary, for process control and accountability of 

nuclear materials. Plant 1 was considered an operations support facility and not a mainline 

production plant. Other operations included milling of enriched and depleted uranium byproduct 

slag from Plant 5, burning waste oil, drum reconditioning; baling scrap metal drums, and 

screening, milling, and packaging enriched uranium dioxide for offsite shipment. Table D.1-15 

of DOE 2000b, identifies general milling, Titan milling, drum dumping and dust collection as 
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processes with high airborne RU dust exposure potential in Plant 1. Magnesium fluoride 

(MgF2), U3O8, and residues were the principal materials of concern. 

Plant 2, 3 - Refinery: The Ore Refinery Plant (2/3) became operational in December 1953. 

Early in 1962, Plant 2/3 was shut down and placed in standby and all uranium refining 

operations were consolidated at the Weldon Spring Site. Limited operations were resumed 

within one year and continued intermittently until 1972, when the concentrate conversion 

campaign was started. 

The production process began with the conversion of impure uranium feed materials and 

recycled residues to pure uranium trioxide (UO3) in the Refinery. This was accomplished in a 

three-step operation that began with acid-leaching uranium from dry solid feed materials, 

followed by solvent extraction processing to produce a highly pure solution of UNH. The final 

step was the conversion of pure UNH solution to UO3 by thermal decomposition. 

The solvent extraction operation was an adaption of the PUREX Process developed at Hanford 

for recovering uranium and transuranic elements from spent fuel. In this process, tri-butyl 

phosphate (TBP) in kerosene selectively removes soluble uranium from aqueous acidic UNH 

solutions into the organic extract phase. After scrubbing the extract with small quantities of 

deionized water to remove entrained impurities, the extracted uranium is recovered by contact 

with large quantities of non-acidic water. Perforated-plate, pulse columns were used for these 

operations. 

After milling and screening, UO3 was loaded into portable metal hoppers or drums, either for 

transport to Plant 4, or shipment offsite. Support areas included Nitric Acid Recovery, Raffinate 

Treatment, and the Refinery Sump. Table D.1-15 of DOE 2000b, identifies digestion and 

denitration as processes with high airborne RU dust exposure potential in Plant 2/3. Prepared 

Feed, MgF2, U3O8, and UNH were the principal materials of concern. 

Plant 4 - Green Salt Plant: Plant 4 began operating in October 1953 for converting UO3 that 

was either produced in Plant 2/3 or received from offsite to uranium tetrafluoride (UF4), 

commonly called green salt, by a two-step operation. In the first step, UO3 was reduced by 

hydrogen to form uranium dioxide (UO2), which was then converted to green salt using 

anhydrous hydrofluoric acid in the second step. The production of large quantities of enriched 

UF4 started in 1963, with UO3 recycled from Hanford ("A508" material). At various times, the 

plant processed combinations of green salt for dehydration, normal UO3 from Weldon Spring 

and Port Hope, UO3 recycled from Hanford and Savannah River, and "300" and "500" enriched 

UO3 from a scrap processing campaign at Weldon Spring. Complete clean outs of process 

reactor banks were required between the specific campaigns of these different source materials to 

maintain nuclear criticality control, accountability of uranium values, and segregation of isotopic 

enrichments. Table D.1-15 of DOE 2000b, identifies Hydrofluorination Banks 7–9, packaging 

stations and dust collection as areas/processes with high airborne RU dust exposure potential in 

Plant 4. Uranium dioxide (UO2), UO3, UF4, and U3O8 were the principal materials of concern.

Plant 5 – Metals Production Plant: Plant 5 was comprised of the Reduction Area where UF4

was converted into uranium derby metal and the Casting Area where derbies and other forms of 
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high-grade metal scraps were cast into ingots. Each area had its own distinct support 

components, including a slag liner and milling operation for supporting metal reduction and a 

Graphite Machining Shop to support casting operations. Major components of the reduction 

process included 11 jolters, 5 filling machines, 44 reduction furnaces, and 2 derby breakout 

stations. 

The Casting Area was where derbies and recycle scrap metal in the form of ingot top crops, 

briquettes, crushed elements, and other bulk forms of high-grade metal scraps were cast into 

ingots. Casting Area equipment included 28 vacuum induction furnaces for melting derbies and 

other high-grade uranium metal scraps into ingots. Auxiliary equipment included crucible and 

mold coating equipment crucible burnout and ingot separation stations; and saws for cropping 

the top of cast ingots. 

Crucibles were prepared for reuse by inverting them in a controlled facility for burning any 

residual uranium adhering to the interior. Molds were removed from cast ingots after cool down 

and cleaned for reuse. During the controlled solidification of castings, oxides and carbon 

impurities floated on the surface of molten uranium and rose to the top of the ingot. Such 

impurities were removed from cast ingots by cropping a few inches from the top section using 

mechanical saws; the sawed section was identified as a top crop. 

Nearly all operations in the metals production process involved high dust loading potential. 

These included blending charges, filling reduction bombs, furnacing, and derby breakout. Other 

dusty operations were mold and crucible burnout, and crushing, separating, and binning uranium 

and MgF2. Major off-normal occurrences in Plant 5 involved blowout of metal reduction 

charges in Rockwell Furnaces and self-pour castings. DOE 2000b notes that in these offnormal situations, the installed ventilation systems were ineffective at controlling dust 

emissions. 

 

Plant 8 – Scrap Recovery Plant: Plant 8 began operations in November 1953 for upgrading 

process residues to a form suitable for uranium recovery in Plant 2/3. Process residues were 

numerous forms of low-assay uranium materials that were generated by all production 

operations. Examples include MgF2 slag, sump filter cakes, dust collector materials, incinerator 

ash, and off-specification UO3 and UF4. Low-grade metal scrap that was unacceptable for 

recycling via re-melting was furnaced to black oxide (U3O8). After screening, the fine material 

fraction became acceptable feed for Plant 2/3 operations and the coarse material fraction was 

further oxidized in a furnace. Table D.1-15 of DOE 2000b, identifies wet chemical processing, 

furnacing, screening and blending, and hand sorting as processes with high airborne RU dust 

exposure potential in Plant 8. Uranium, ammonium diuranate (ADU), U3O8 and residues were 

the principal materials of concern. 

Pilot Plant: The operation of the small-scale unit in the Pilot Plant began in 1958, and was 

operated primarily for producing enriched UF4 for conversion to metal. With the introduction of 

enriched uranium processing in Plant 2/3 beginning in 1965, the Pilot Plant UF6 to UF4 facility 

was also operated to produce "sweetener" for adjusting the isotopic assay of recycled materials to 

meet product specifications. Sweetener was the term for restoring the fraction of U-235 that had 

been converted to transuranic elements and fission products in reactor site operations. 
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concern.

Production activity was suspended in 1967, because sufficient sources of sweetener were 

available from enriched uranium received from offsite. Activity resumed in 1985, when the 

larger scale, upgraded facility was placed into service. Table D.1-15 of DOE 2000b, identifies 

numerous areas/processes with high airborne RU dust exposure potential in the Pilot Plant. 

Uranium dioxide (UO2), UO3, UF4, UF6, U3O8 and MgF2 were the principal materials of 
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4.0 NIOSH DEFAULT RU CONTAMINANT VALUES – BASIS AND 

APPLICABILITY 

According to NIOSH 2008, uranium urinalysis was performed routinely through the entire 

operational history of Fernald, from the early 1950s to 1986. There were minimal direct 

measurements of TRU contaminants during this period, and the doses determined from only 

uranium urine results obtained during this period do not account for a worker’s internal dose 

from Pu, Np, and Tc-99, or other contaminants in RU or RU byproducts handled and processed 

at the site. 

Because there are essentially no usable personnel monitoring data for RU contaminant 

radionuclides at Fernald, NIOSH proposed a “one size fits all” approach that uses uranium 

bioassay data together with fixed ratios of Pu, Np, and Tc-99 to estimate dose from these three 

trace contaminants, as shown in Table 10 of NIOSH 2008. Table 1, below, contains the 

information in Table 10 of NIOSH 2008. A conversion to units of μCi/kg U is added for 

convenience, as much of the historical data were reported in these units. 

Table 1. Percent of Total Uranium Activity Added to Air Monitoring Sample 

[From Table 10, NIOSH 2008 p. 15] 

RU 

Contaminant 

Mass Concentration 

Addition (ppb U) pCi/μgm U μCi/kg U

% DU 

act. 

%NU 

act. 

%EU act. 

(2%) 

Pu-239 100 6.3E-03 6.3 1.5 0.9 0.4

Np-237 3,500 2.5E-03 2.5 0.6 0.4 0.2

Tc-99 9,000 0.15 150 37 22 9

Th (232)a 10,000 1.1E-06 1.1E-03 2.7E-04 1.6E-04 7E-07

Ru-103/106 50 μCi/lb 0.11 110 27 16 0.7

Zr/Nb-95 15 μCi/lb 3.3E-02 33 8 5 2

Others (Sr-90) 2 μCi/lb 4.4E-03 4.4 10.9 0.6 0.3

*The long-lived fission products that were contaminants were beta emitters, including Tc-99, Sr/Y-90, Cs-137, 

Ru-103/106. For Ru and Tc, gross beta counts in a DU processing area could be as much as 30 to 40% of the total 

counts. However, since the permissible concentrations as compared to that for uranium are 2 to 4 orders of 

magnitude less restricting only the TRU isotopes are of major exposure concern. 

a

 Thorium-228 should be assumed to be at 70% equilibrium with Th-232. 

4.1 DOSIMETRIC IMPLICATIONS OF THE DEFAULT LEVELS 

To verify the dosimetric consequences of the NIOSH default levels, SC&A calculated ratios of 

50-year organ dose commitments from RU contaminants relative to uranium (natural uranium, 

specific activity = 0.683 pCi/μg) for combinations of solubility classes, using ICRP 68 (ICRP 

1994) dose coefficients. Constituent radionuclides were Pu-239, Np-237, Tc-99, Th-232, Sr-90 

and Cs-137. Zirconium/Nb-95 and Ru-103/106 were not analyzed due to their short half-lives. 

Cesium-137 was included because it was present in the dust collector data, though no default 

level has been established by NIOSH. In accordance with NIOSH conventions, ICRP 68 dose 

coefficients for uranium are based on U-234 to maximize dose. An example dose ratio 

calculation is provided for bone surfaces for Pu-239 Class M and U-234 Class S. 
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Pu:U = SA (Pu-239) (Bq/g) × 10-7 [mass fraction (g Pu/g U)] × DC (Pu-239) (Sv/Bq)

 SA (U nat) (Bq/g) × DC (U-234) (Sv/Bq) 

Where 

Pu:U = ratio of organ dose commitments from Pu-239 to U-234 (Sv Pu-239/Sv U-234) 

SA (Pu-239) = Specific activity of Pu-239 in units of Becquerels per gram (Bq/g) 

 = 2.3×109

 

Mass fraction = fraction of Pu:U on a uranium mass basis, corresponding to 100 parts per billion 

DC (Pu-239) = ICRP 68 dose coefficient for Pu-239 Class M in units of Sieverts per Bq (Sv/Bq) 

 = 1×10-3 for bone surfaces 

SA (U nat) = Specific activity for natural uranium = 0.693 pCi/μg = 2.53×104 Bq/g 

DC (U-234) = ICRP 68 dose coefficient for U-234 Class S 

 = 2.7×10-7 for bone surfaces 

Pu:U = 2.3×109

 (Bq/g Pu-239) × 10-7 × 10-3 (Sv/Bq Pu-239)

 2.53×104

 (Bq/g U) × 2.7×10-7 (Sv/Bq U-234) 

 = 33.71

Selected dose ratio combinations that exceed unity are provided in Table 2. Note that the highest 

default dose ratios for Tc-99, Th-232, and Sr-90 are 0.0439 [Tc(F):U(S), stomach], 0.009 

[Th(M):U(S), bone surfaces] and 0.0464 [Sr(F):U(S), red marrow], respectively. For Cs-137, 

dose ratios were assessed for the highest measured dust collector concentration, 0.76 ppb 

(66 μCi/kg U). The highest ratio observed was 0.076 (urinary bladder, pancreas, ovaries, 

uterus). 

Table 2. RU Dose Ratios Greater than Unity Given the NIOSH Default Ratios 

Organ Pu (S):U (S) Pu (M):U (S) Pu (M):U (M) Np (M):U (S) 

Bone surfaces 3.37 33.71 3.07 8.94 

Liver 5.17 51.66 4.67 -- 

Red Marrow 1.56 15.60 1.46 3.22 

Ovaries /Testes 1.26 13.60 1.26 3.60 

In summary, at the NIOSH default concentrations, organ doses from Pu and Np can be 

significantly higher than the corresponding uranium doses. This underscores the importance of 

defining truly bounding values if NIOSH is to continue the “one size fits all” approach to 

assigning organ doses from RU contaminants. 

4.2 HEALTH PHYSICS PRACTICES AT FERNALD – IMPLICATIONS FOR RU 

DOSES 

Clearly, potential exposures to transuranic and fission product contaminants are highly 

influenced by what radiological protective measures may have been taken while handling the 
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contaminated material. NIOSH’s justification for their default concentrations is based in large 

part on a presumption that historic radiation protection practices were adequate to have 

controlled exposures from RU to levels below their defaults, and that those practices were rigidly 

adhered to. The following discussion casts serious doubt on NIOSH’s presumption. 

According to a 1965 memo that was referenced in the 1985 Task Force Report on Recycled 

Uranium: 

...the processing of current recycle material does not require any health or safety 

considerations other than those made for normal virgin uranium. (DOE 1985, p. 

21) 

So it appears at least in the mid-1960s, no additional radiological controls were in place when 

processing recycled uranium. There does not appear to be much information specifically on 

recycled uranium handling practices between the aforementioned memo and the receipt of the 

Paducah tower ash which was processed in the early 1980s. NIOSH has stated in their most 

recent working group response (and also echoed in their original white paper): 

There were occasional sources of material that exceeded the [10 ppb] shipping 

specification. Shipment of such lots required the approval of the receiver. 

Although rare, Fernald was the recipient of some Plutonium-Out-Of-Specification 

(POOS) material, from Gaseous Diffusion Plants primarily. The material was 

handled very carefully with worker protection as a dominant concern... Worker 

protection was a special concern when POOS materials were being handled; 

special anti-contamination clothing and respiratory protection were used in 

recognition of the higher Pu content during handling and blending process [sic]. 

(NIOSH 2010, pp. 6 and 11) 

However, SC&A finds the assertion that contamination and worker exposures were carefully 

controlled during all periods of POOS processing to be questionable. 

DOE 1985 states: 

Once the material had been accepted, sampled, and analyzed at FMPC, five of the 

16 hoppers were repackaged into drums in the Green Salt Plant (Plant 4). Since 

this repackaging required open air transfer and some handwork with metal rods 

to break-up the solidified material, the workers were requested to wear half-mask 

airline respirators, and health physics attention was given to air sampling. 

[Emphasis added] (DOE 1985, p. 22) 

The FMPC determined that the protection factor (1000 to 1) afforded by the 

respirators (required for this operation) was sufficient to protect workers. No 

surveys of transferrable surface contamination were performed... [Emphasis 

added] (DOE 1985, p. 23)
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Task Force Observation ... Based on DOE and FMPC Health Physics 

review of this work (in February 1985) overall contamination control 

was judged to be marginal in that no surveys for transferrable surface 

contamination were performed at the time of processing to support this 

effort. (DOE 1985, p. 23)

Management awareness of the special monitoring and respiratory protection measures 

taken for this material was evident. Questions and concerns were raised by the 

operators and nearby millwrights regarding special respiratory protection 

requirements. Due to the dust being generated by the handwork required to repackage 

the material, the remaining hoppers were transferred to the Sampling Plant (Plant 1) 

where the balance of the material was repackaged. FMPC judged that the dusting could 

be better controlled in the Sampling Plant, although the Task Force was advised that 

worker protection methods were the same as in the Green Salt Plant... [Emphasis added] 

(DOE 1985, pp. 23–24)

Task Force Observation ... FMPC management stated that special 

precautions were taken to control exposures at the Sampling Plant; 

however, the Task Force was not able to document what precautions 

were taken or the personnel exposures experienced in the Sampling 

Plant. [Emphasis added] (DOE 1985, p. 24)

Further on in the document it states: 

(Respiratory Protective Equipment Requirements) states that air supplied hood or airline respirators are required for work at locations in which the National Lead Company 

of Ohio Concentration Guide (NCG) for airborne radioactivity could be exceeded by a 

considerable margin but the condition is not immediately dangerous to life or health 

DOE 1985, p. 35) 

Task Force Observation ... Worker protection could have been much 

better. For example, workers should have been better informed. The 

NLO-FMPC Manufacturing Standards/Procedures (November 17, 

1982, revised January 7, 1985) mention only briefly the need for airpurifying respirator with purple radionuclide cartridges when dust 

conditions exist. The standard also appears to place the burden of 

deciding whether or not a significant uptake of radionuclides has 

occurred (and thus the need for urine analysis) on the employee. 

Overall, additional environment, safety and health management 

attention and involvement are required. There is a need for better 

respiratory protection, housekeeping practices, and radiation 

protection and control practices at FMPC. The need for operator 

education, especially when working with materials in excess of 10 

ppb plutonium, exists as does the need for meaningful operator 

training. [Emphasis added] (DOE 1985, p. 37)
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In addition, DOE 2000b notes: 

The potential ramifications of transuranic and fission product constituents in 

recycle uranium had been recognized as early as 1986 and the FEMP site 

radiation protection practices were adjusted to account for the trace constituent 

levels within the framework of the DOE radiation protection standards in effect at 

that time. Prior to 1986, radiation practices addressed recycle uranium without 

considering the presence of recycle-generated radiological impurities. 

Therefore, it may be assumed that only monitoring data prior [to] 1986 need be 

considered in evaluating consequences of the constituents of concern in recycled 

uranium at the FEMP... Therefore any investigation of doses due to 

transuranics in recycle uranium would require a complete dose assessment, 

evaluating doses from uranium as well as transuranic constituents, utilizing 

internal monitoring results and information about the individual’s workplace 

assignments. [Emphasis added] (DOE 2000b, pp. 2-21 to 2-22) 

This statement that site radiation safety practices were adjusted in 1986 to account for 

contaminants in RU is supported by a 1986 standard operating procedure, which outlines how 

POOS material should be handled (Bogar 1986): 

 Continuous air samples at locations at the following locations: Plant 4 (dumping area, one 

section of reactor banks, drumming station, control panel/office area) and Plant 8 (north 

side of East Eimco Filter, Filter cake drumming station), Plant 51

 (magnesium fluoride 

dumping station, jolters (west bank), F-machines, break out area). These air samples 

should be changed daily and analyzed for gross alpha activity, uranium, or uranium plus Pu 

and Np as determined by Health Physics. 

 Every two weeks, a random operator who is processing POOS material is assigned a 

breathing zone (BZ) sampler for one shift, which is to be analyzed for gross alpha activity 

or uranium (as determined by Health Physics). 

 Urinalysis will be performed on POOS workers before, after and at six month intervals 

during the program [this is confirmed by the 1988 report, POOS History and Risk 

Assessment (Hinnefeld 1988)]. 

o Bi-weekly urine samples will be submitted for uranium analysis. Plutonium is 

assumed to be inhaled, in direct proportion to the uranium inhaled. 

o Urine sample results above 40 μg/L will require an additional 1-liter urine 

sample which will then be analyzed for Pu and Np. The 1-liter sample will be 

taken over the weekend, and the individual will be assigned work outside 

airborne radiation areas until the sample drops below 40 μg/L and the magnitude 

of the intake has been estimated. 

 1

 Note: the original SOP did not list Plant 5 but it appears to have been modified once it was proposed that 

Plant 5 be used to process some POOS material as shown on page 59 of Bogar (1986) 
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o Urine samples found to contain plutonium will trigger additional bioassay and any 

further actions deemed necessary to evaluate the employee’s exposure and 

identify its source. 

 All areas where uncontained out-of-specification material is handled will be designated as 

airline respirator RCZs (respirator control zones) and CCZs (clothing control zones) within 

a 10-foot radius of the uncontained material. 

 Work area swipes shall be taken prior to the project, daily during project operations, and 

after the project completion. 

 Biweekly reports should be submitted to include the quantities of material processed and 

remaining material, operational problems encountered, changes in worker protection, and 

number of workers involved, process/area/worker monitoring results, any violations of 

procedure. 

Presumably, the ‘bi-weekly reports’ contain all the sampling data which characterize the POOS 

operations. Only three of these reports (for Plant 8 in 1986) have been found in the SRDB. 

Urinalysis results are given in terms of μg U, but do not give contaminant values; radiological 

smear results are simply in dpm, and GA/BZ monitoring is in dpm/m3

. The only radiological 

contaminant data in the reports was a sampling of the ‘filtrate’ for plutonium. 

The assumption that plutonium intakes were proportional to uranium intakes is questionable, given 

the large variability in plutonium concentrations in feed and scrap materials on a uranium mass 

basis. That topic is investigated in detail in Section 4.3.1 of this report. Thus, it is possible that 

significant plutonium intakes could have occurred and not been measured if uranium bioassay 

results were less than 40 μg/L. 

Hinnefeld (1988, p. 3) provides additional insights regarding the POOS issue and the scope and 

outcome of the urine bioassay conducted for POOS workers: 

When the specification for acceptable levels of TRU elements was adopted in late 

1985, it was recognized that certain materials already at the FMPC did not meet 

the specification. In 1986 special procedures were developed for processing 

these materials, which were subsequently dubbed POOS, for plutonium-out-ofspecification. [Emphasis added.] 

The campaign to process the POOS UO3 to UF4 ran for only a few days before 

a spill of POOS material from a hopper shut down operations. Subsequent 

POOS operations have involved running out the POOS material that remained 

the reactor banks at the time the operation was shut down, and recovering 

material from various pieces of process equipment. [Emphasis

in 

 added.] 

One aspect of the procedure for running POOS materials was the collection of 

urine samples to be analyzed at an outside laboratory for plutonium. A POOS 

urine sample was to be collected before an employee started working with POOS 

materials, at six-month intervals during POOS operations, and at completion of 

POOS operations. In the April 1988 time frame samples were collected from 
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individuals who had worked in POOS areas since July of 1987. In one batch of 

11 samples that were sent in a single shipment to an outside analytical 

laboratory, [redacted] samples were reported to contain plutonium. These 

results were received at FMPC in early August, the involved employees were 

informed of the results, and additional bioassay samples were collected. 

[Emphasis added.] 

With only one positive bioassay result from an individual, it is not possible to 

make a technically sound assessment of the radiation exposure resulting from an 

intake of radioactive material. However, by making a few assumptions, rough 

estimates of the resulting exposure can be completed. If the assumptions are 

conservative, the rough estimate can tentatively be considered an upper limit on 

the actual exposure. This was done for the[redacted] positive Pu urinalysis 

results that were received in August. The committed effective dose equivalent for 

the person have [sic] the highest result was estimated to be 3.8 rem. It should be 

emphasized that this is a very preliminary number based on a single bioassay 

result. (Hinnefeld 1988, p. 5)

SC&A understands that the 3.8 rem effective dose for the highest bioassay sample is a highly 

uncertain best-guess estimate based on claimant-favorable assumptions. Note however, that 

based on ICRP 68 dose coefficients, an effective dose of 3.8 rem is equivalent to a bone 

surface dose of 119 rem and a liver dose of 25 rem. 

Bassett et al. (1989) makes the following statements regarding the plutonium bioassay of POOS 

workers: 

Since April 1986, WMCO has collected 675 plutonium bioassay samples from 441 

FMPC workers. Those samples were collected primarily from workers who were 

expected to be and, in some cases, were actually involved in POOS processing 

and clean-up campaigns in Plants 4 and 8. Of the 441 workers sampled to date, 

only [redacted] individuals have shown detectable quantities of plutonium in 

the urine, with none indicating significant levels of plutonium exposure. 

[Emphasis added.] (Bassett et al. 1989, p. 5) 

The [redacted] individuals who had positive plutonium bioassay results 

originally reported were [redacted] where in-vivo counts were conducted for the 

presence of plutonium. Fecal analyses were also performed for these individuals 

by a commercial laboratory [redacted]. All results were negative for plutonium 

as was expected from the levels found in the urine and the time which had 

transpired between the initial positive urine bioassays and the in-vivo counts. 

In summary, it is apparent that the bioassay sampling program for POOS workers was not 

comprehensive, but was limited in scope to a subset of workers in Plants 4 and 8 starting at the 

earliest in 1986. It is not clear whether the sampled workers handled POOS materials prior to 

that date or in plants or if the original positive results indicate actual exposures (Bassett et al. 

1989, p. 6). 
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Bassett et al. 1989 also notes: 

Prior to February 1989, no isotopic analysis for plutonium, neptunium, or 

thorium isotopes had been performed for smears or air sampling filters.2

Thus, it is not surprising that additional contaminant data related to POOS operations was not 

found in the 1986 bi-weekly reports. 

The problems associated with health and safety practices such as excessive dust and disregard for 

safety procedures were documented in 1980 during a week-long appraisal of the FMPC health 

protection program conducted by the Oak Ridge Office (ORO). The results of this health and 

safety review are summarized in Leist 1980. The review identified several instances of workers 

in dusty areas not utilizing proper ventilation or respirators. Specifically, the appraisal stated the 

following conclusions: 

 “... there were basic defects in our health and safety concepts. Further, that they had 

noted willful disregard of NLO regulations for health and safety and would conclude that 

management is not committed to this end.” 

 “NLO should retrain on the use of respirators...NLO has no respirator recycling check 

procedures to insure they are being cleaned properly.” 

 “NLO has no routine area radiation monitoring plan and we should institute one... 

NLO’s air monitoring program is minimal and should be expanded to avoid exposures.” 

 “The appraisers found a basic lack of concern for spills clean-up and longer term 

exposure in the plants and a lack of reflection of Management’s concern in this area with 

the line people. The appraisers also feel that our safety programs are not being 

implemented.” [Leist 1980] 

It cannot be assumed a priori that conditions were better in the earlier period without direct 

evidence. Later in the 1980s, the air monitoring program was characterized as follows: 

When WMCO began administration of the DOE contract for operation of the 

Feed Materials Production Center in January of 1986, the FMPC air sampling 

program was very limited. WMCO has aggressively upgraded the air sampling 

program by providing written procedures, introducing continuous sampling, 

posting all ‘Airborne Radioactivity Areas’ at 10 percent of the established limit, 

setting up Beta and Alpha CAMs to provide real time monitoring, requiring 

respiratory protection in all ‘Airborne Radioactivity Areas’ and providing 

continuous radon/thoron working level monitoring. [Emphasis added.] (Rogers 

1989) 

 2

 This report notes that the samples taken in 1989 showed that uranium was the driving health concern. 
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Finding #1: Questionable basis for NIOSH presumptions regarding the integrity of Fernald 

radiation safety programs prior to 1986 

The passages cited above indicate that prior to 1986 the radiation safety program at Fernald 

was probably not adequate to control potential exposures from contaminants in RU. In all 

likelihood, the 1986 changes were implemented by the new M&O contractor in response to 

problems encountered during RU processing in the preceding years. This raises concerns 

regarding NIOSH’s reliance on the integrity of such programs as assurance that their defaults 

were not unknowingly exceeded during the entire SEC period. This is not only of concern 

during the early years of RU processing but also during the 6 years that had elapsed from the 

time the most contaminated RU material was received in 1980 until the new program elements 

were implemented. 

4.3 BASIS FOR NIOSH DEFAULTS 

In accordance with the Board’s directive to detail SC&A’s basis for the conclusion that the 

subgroup means in Table 5 of NIOSH 2008 do not provide a firm basis for bounding defaults for 

TRU and fission products, SC&A researched the available literature in the Site Research 

Database (SRDB) pertaining to limiting values for RU contaminants. This section examines the 

findings of that review. 

4.3.1 Basis for the 10 ppb Guideline for Plutonium 

The principal basis for NIOSH’s default value of 100 ppb plutonium on a uranium mass basis is 

the presumption that an AEC guideline of 10 ppb U was established early in the RU processing 

period and was strictly adhered to (except for a few known shipments that were specially 

handled). In establishing their default, NIOSH simply applies a factor of 10 multiplier to this 

guideline to account for claimant favorability. NIOSH states in their most recent response to 

SC&A’s findings: 

From the very beginning of shipping RU materials between AEC Sites, 

specifications were established that limited the Pu content to 10 ppb U, with other 

specifications to limit the concentration of fission products...The product 

specification of 10 ppb Pu was the requirement for shipping material to other 

sites within the complex, including Fernald. “Review of Generation and Flow of 

Recycled Uranium at Hanford, DOE/RL-2000-43 [DOE 2000a] identifies the 

product specification in Section 2, and reviews the basis for the product 

specifications and lists examples of the effort to assure that the product met the 

specifications. (NIOSH 2010, p. 6 and p. 14) 

However, DOE 1985 indicates the following: 

There are inconsistencies regarding the maximum allowable transuranic and 

fission product content in recycle material processed by the FMPC... the FMPC 

advised that ‘internal NLO [the operating contractor of the FMPC] memos 

established 3,000 disintegrations per minute (dpm) plutonium and neptunium per 
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gram of uranium (roughly 20 parts per billion [ppb]) as a target for maximum 

TRU (transuranic) content in materials handled at the FMPC. This has not been 

a standard or acceptance criterion. (DOE 1985, p.12) 

The Task Force Report makes the following observation regarding specifications for 

TRU in RU established by the AEC in 1971: 

During 1971, the Atomic Energy Commission (now DOE) published 

specifications for the commercial delivery of uranium oxides, UNH crystals and 

UNH solutions to AEC facilities for conversion to uranium hexafluoride (UF6). 

An applicable page from these specifications is shown in Table 3. A limit of 

15,000 dpm/g U alpha activity [for all transuranic elements] was established. 

(DOE 1985, p. xi) 

 

Note that 15,000 dpm/g U corresponds to approximately 108 ppb Pu-239 or 9,580 ppb 

Np-237 (almost 3 times the NIOSH default value, assuming 100% Np-237). Currently, 

NIOSH assumes both 100 ppb for Pu and 3,500 ppb for Np-237. In summation, that is 

about 19,300 dpm/g U for the two TRU components. 

In their summary conclusions, the Task Force made the following general remark 

regarding specifications for TRU and fission products in RU: 

A formal, technically sound, understood and accepted specification for 

maximum transuranic and fission product contaminants in uranium recycle 

material has probably never existed either within or between sites. Although 

most sites had their own "working" specification, there simply was no 

understanding and agreement on specifications for recycle material shipped to or 

from the DOE sites studied by the Task Force that had been agreed to, signed, 

and used for decision-making. [Emphasis added] (DOE 1985, p. xi) 

The Task Force goes on to recommend the following in its concluding remarks: 

Mutually agreeable and technically sound transuranic and fission product 

element specifications should be established between shipper and receiver for all 

recycle material shipped to and from all DOE sites handling recycle material ... 

To implement this recommendation, DOE established a multi-contractor 

specifications Task Group to develop these specifications under the auspices of 

the Uranium Recycle Task Force. (DOE 1985, p. xv) 

This would seem to indicate that a complex-wide guideline on transuranic contamination was not 

established as late as 1985. Specifically regarding Hanford shipments, the Task Force report 

notes the following: 

While the Hanford UO3 product specifications are used as a working document 

by both the FMPC and Hanford, no written agreement exists between the two 

sites that formalize these specifications. (DOE 1985, p. 15) 
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It is clear, then, that the guidelines established at Hanford at 10 ppb U were not a formal 

agreement, but rather ‘working specifications.’ In fact, the task force report indicates that a 

definite guideline of 10 ppb for plutonium contamination did not occur until an April 14, 

1985, letter to FMPC management from DOE which imposed the 10 ppb guideline. (DOE 

1985, p. 15) 

Regarding the accounting of TRU and fission products in RU received at Fernald, the Task Force 

reports: 

The FMPC has not been required by DOE to maintain accountability records of 

transuranic and fission product elements in the quantities generally received by 

the FMPC. As such, the Task Force could not determine, with confidence, the 

quantity of contaminants that may have been received and processed at the 

FMPC. Only best estimates were available for the review. (DOE 1985, p. xi) 

DOE 2000b attempted to compile available data on TRU present in material at Fernald and other 

sites, and apply them to different process streams. This report notes: 

The database [as compiled for the DOE 2000b report] includes 4,000 analytical 

results reporting Pu-239, one of the principal constituents of interest. The range 

of results spans 8 to 9 orders of magnitude for this analyte, illustrating the diverse 

cross-section of the Fernald processes and material sources represented by the 

data. (DOE 2000b, p. 4-4) 

Finding #2: Questionable basis for NIOSH default plutonium concentration 

A formal specification for maximum transuranic and fission product contaminants in 

uranium recycle material had probably not existed either within or between sites. In fact, the 

only formal limit adopted by the AEC for recycled uranium was adopted in 1971 to 

accommodate commercial fuel shipments to the gaseous diffusion plant. The fact that there 

are several orders of magnitude of variability in 4,000 analytical results reported for Pu-239 in 

DOE 2000b raises concerns as to NIOSH’s reliance on the Hanford ‘working specification’ of 

10 ppb as the basis for their default plutonium concentration. SC&A believes that a reanalysis of the data to determine if there are classes of workers that are not sufficiently 

bounded by the current methodology would be highly beneficial. 

As a corollary to Finding #2, NIOSH has not yet established that the 4,000 data points analyzed 

in DOE 2000b represent a complete dataset in both space and time for the purpose of 

establishing a bounding Pu ratio (Findings 2 through 5 of SC&A 2009). Furthermore, it is not 

evident that the original database (with apparently 4,000 analytical data points for Pu-239 alone) 

is available for inspection by either SC&A or NIOSH. In any case, it would take a major 

document retrieval and data compilation effort to check at what time period the values for trace 

contaminants in NIOSH 2008 might be claimant favorable. 
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4.3.2 Basis for NIOSH Np-237, Tc-99, and Fission Product Defaults (other than Tc-99) 

In 1967, the Hanford UO3 product specification established an upper limit of 15 μCi/lb U for 

Zr/Nb-95, 50 μCi/lb for the combination of Ru-103/RuRh-106, and 2 μCi/lb for all other 

isotopes excluding Tc-99. Ten-lot average values were also established, with the values for 

Zr/Nb-95, Ru-103, and Ru/Rh-106 and others limited to 10, 25, and 0.5, respectively (DOE 

2000a, p. 9). It is interesting that as of 1976, Fernald did not have specified levels for fission 

products in RU. In 1985, the Hanford values listed above were in place (DOE 1985, pp. 13–15). 

This further supports the conclusion in DOE 1985 that a technically sound, understood, and 

accepted specification for maximum transuranic and fission product contaminants in uranium 

recycle material has probably never existed either within or between sites. 

Neptunium and technetium methods were not included in the original Hanford Works 

documents, nor are there single accepted methods for the measurements available at the time that 

the RU reports were compiled (2000). For that reason, technologies developed at the on-site 

laboratories were applied after extensive testing and application to the UNH matrix. Reliable 

neptunium measurements were not made on UO3 until 1969, and technetium analyses were not 

performed until 1985. Chemical standards with the isotope were included during the analyses to 

verify method performance (DOE 2000a, p .10). 

Whereas NIOSH relied on the Hanford production specification of 10 ppb U as the foundation 

for their default of 100 ppb for plutonium, they have relied on an analysis of recycle contaminant 

flows in (DOE 2000b) almost exclusively as the basis for Np-237 and Tc-99 defaults (3,500 and 

9,000 ppb U, respectively) and to validate their defaults for Pu. A brief description of how the 

data were assembled and analyzed in DOE 2000b is instructive for the purposes of assessing the 

veracity of that reliance. 

Each of the sites included in DOE 2000b (i.e., Fernald, Reactive Metals Incorporated, West 

Valley, Weldon Springs) reviewed existing and historical analytical data records to locate RU 

contaminant content results for materials shipped to, received by, and/or processed by their 

operation. The data collected for Fernald was the most extensive of any of the Ohio Field Office 

sites, incorporating over 3,000 individual data points from 20 sources. This represents most of 

the 4,000 total data points that were assembled from all of the sites. 

To assess the types and quantities of contaminants in the RU received and shipped by Fernald, a 

thorough search for available and useful laboratory data was performed by DOE. This effort 

consisted of the following elements: 

 Process knowledge experts from the production operations period of Fernald searched the 

records archive for original analytical data report forms with transuranic and technetium 

results reported. These experts examined boxes of archived files from process 

engineering and development organizations, production control organizations, and 

materials control and accountability organizations. 

 Project team members collected transuranic and technetium data from current electronic 

inventory and analytical records. 
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 Analytical results from a period of intense scrutiny of production for transuranics content 

in the mid-1980s were recovered from archives. 

 Project team members collected data from other DOE sites pertaining to Fernald 

shipments and receipts, including analyses from Oak Ridge, SRS, Idaho, and Hanford 

data sources. 

After compiling the data, process knowledge was used to assign the data into subcategories of 

similar materials. Upon assigning the data into 1 of the 19 subcategories, a Microsoft Access® 

database report was designed, generated, and used to develop the statistical parameters used in 

Appendix F of DOE 2000b to estimate the mass quantities of the constituents of concern. The 

values reported in Table F.3-1 of DOE 2000b are referred to (by DOE) as “bootstrap means” of 

the 19 subgroup data distributions and are replicated in Table 5 of NIOSH 2000b. The bootstrap 

mean is similar to a standard arithmetic mean (AM), but the technique is designed to minimize 

the influence of “outliers” in a dataset. For convenience, Table 5 from NIOSH 2008 is 

reproduced below as Table 3. 

Table 3. Recycled Uranium Summary Values by Process Subgroups 

(From Table 5, NIOSH 2008, p. 7) 

Subgroup # Description Pu-239 

ppb U 

Np-237 

ppb U 

Tc-99 

ppb U 

1A Miscellaneous 16.035 1328.11 2399.22 

1B Miscellaneous – Minor Offsite 0.889 109.07 0.55 

2 UF6 Source UF4 (GDP Tails) 0.502 54.90 201.61 

3 UF6 source metal & scrap 0.007 2.54 9.12 

4 Normal U product, residues & scrap 0.091 67.09 26.55 

5 Enriched UF6 source products/Res. 1.259 81.39 2109.61 

6A UO3 Purex source (A508)(Unblended) 2.884 388.97 8552.23 

6B LEU products A508 UO3/UF4 (low cross) 2.321 332.94 8934.58 

6C LEU products A508 UO3/UF4 (high cross) 23.969 1045.29 2789.56 

6D A500 coded enriched residues 4.556 143.75 1085.45 

6E SR UNH 16.527 nm nm 

6F SR UO3 – not shipped to FEMP 2.805 nm nm 

7A A508 based derbies 9.305 311.97 1721.00 

7B A508 based ingots & Metal 1.165 263.48 447.81 

8 Enriched MgF2 96.618 1881.53 1651.23 

9 Incinerator ash& scrap residues-GDPs 47.616 3164.53 263.32 

10A Tower ash & decon. residues 412.177 10503.53 2618.36 

10B UO3 from tower ash 20.772 498.17 2405.28 

11 Waste residues 84.817 3999.32 4110.05 

*Though the results in the table are all reported in ppb U, this measure may appear less meaningful in 

subgroups in which there is very little uranium, such as subgroups 8 and 11, in which the MgF2 and 

chemical plant raffinates accumulated some isotopes, but were relatively low in uranium by design, but still 

a significant contributor to the gross alpha activity. Note that even with decreased U levels, the 

contamination can still be a ratio of U. 

** nm – not measured 
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As regards the use of the 19 process subgroups in Table 5, NIOSH 2008 states: 

Table 5 lists a summary of the RU contaminants by subgroups (2000b). Data 

from this table was [sic] used to develop the default activity ratios for use in the 

absence of specific bioassay data for workers involved in any of these process 

subgroups. [Emphasis added] (NIOSH 2008, p. 7) 

Even a casual inspection of Table 3 reveals the enormous variability in constituent levels (3 to 4 

orders of magnitude) and in the ratios of Np-237 and Tc-99 to Pu among the 19 subgroups. This 

is to be expected, as the data reflect different batches of RU that represent different stages of 

processing through the DOE complex. 

Finding #3: NIOSH provides no clear basis for the choices of 3,500 and 9,000 ppb U for 

Np-237 and Tc-99 defaults 

NIOSH indicates that data from Table 5 of their RU white paper were used to develop the 

default activity ratios for use in the absence of specific bioassay data for workers involved in 

any of these process subgroups. However, it is not clear to SC&A how the values of 3,500 and 

9,000 ppb U for Np-237 and Tc-99 (and the ratios of 35 and 90 for Np/Pu and Tc/Pu) were 

derived from these sub-group means. 

Since the release of NIOSH 2008, SC&A and NIOSH have had several interactions during which 

the applicability of the subgroup process means as a basis for developing and validating 

bounding default RU contaminant levels was debated. Because SC&A believes that NIOSH has 

not adequately addressed our concerns, our position on the issue, as articulated in SC&A 2009, 

remains unchanged. Our concerns are restated in the following paragraphs. 

SC&A questions the partitioning of Pu into the product and waste streams that was applied in 

DOE 2000b. Appendix D of DOE 2000b provides a description, mainly qualitative, of how the 

partition of the plutonium was done among the various production and raffinate streams at 

Fernald. There do not appear to be quantitative historical data; rather, a study done in 1977 is the 

basis for some of the partitioning estimates provided in the report. That description was 

provided in SC&A 2009 and is reproduced here: 

Several of the historical technical documents examined for this project predicted 

that approximately 80 percent of the Np and Pu would report to the aqueous 

raffinate from the extraction process. However, Plant Test (PTA) number 302 

authorized and conducted in 1977 determined that 87.2 percent of the initial Pu 

and 41.6 percent of the initial Np remained in the product UO3 stream of the 

process. These results were based on an overall material balance performed 

during and by PTA-302. The lesser decontamination provided by the process 

nonetheless results in Pu and Np reporting to both product and by-product stream 

(raffinate). The raffinate, which is low in uranium content by design, would be 

expected to present higher Pu and Np values than original feed materials to the 

process, when reported on a uranium assay basis (Pu/Np relative to U content). 
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Extraction raffinate was neutralized and subsequently pumped to FEMP waste 

pits as a slurry. [DOE 2000b, p. D.1-73]

As noted in SC&A 2009, this approach was the basis of estimating a materials balance, but there 

is no analysis in the NIOSH White Paper of variability and uncertainty that would indicate that 

the values resulting from the analysis in DOE 2000b provide bounding estimates. 

Finding #10 from SC&A 2009 summarizes our concerns regarding the application of surrogate 

data in assigning subgroup process means to actual site processes for which data are unavailable 

or deemed not appropriate. 

Finding 10: NIOSH has not analyzed the underlying raw data or the many 

assumptions in the DOE Ohio field office analysis of the RU data for its 

applicability to dose reconstruction (rather than to a materials balance exercise). 

The use of assumptions about the similarity of materials streams in regard to 

trace contaminant values—that is, of surrogate data—without an actual 

examination of the underlying processes at the facilities from which the RU 

originated and the period in which they originated, is questionable in a dose 

reconstruction context, as well as in an SEC context. (SC&A 2009, p. 20) 

Regarding Finding #10, NIOSH states in their most recent response to SC&A’s findings: 

The analyses of the data streams in the Ohio Report were considered 

comprehensive and adequate, and did not warrant further analysis in the White 

Paper. Since the constituent concentrations in the Paducah Tower Ash were the 

highest that were handled at Fernald, (and the cause for very special operating 

and worker protection considerations), assuming that the Oak Ridge streams 

were at this level appears to be claimant favorable, especially in light of the total 

Pu from OR was less than that from Paducah, as shown in Appendix A of the RU 

White Paper. (NIOSH 2010, p. 18) 

SC&A believes that this response does not adequately address our concerns. First, the analysis 

in DOE 2000b is not comprehensive, though SC&A recognizes that it likely represents the best 

that could be done in the short time that was available (9 months). Second, significant 

uncertainties exist regarding the applicability of surrogate data assignments both in space and 

time that cannot be ignored, especially in the context of an SEC petition. Note that the value of 

412 ppb for plutonium in Sub Group 10A (Tower ash and decontamination residues received 

from Portsmouth and Paducah GDPs) is an average value from a very broad distribution that 

ranged from 0.6 to 3,504 ppb U [DOE 2000b, p. 1144 (F.1-5)] and does not necessarily represent 

a bounding value for that process or others to which it is ascribed. Note also that SC&A’s 

concern as outlined in Finding 10 is not limited to the cited example. 
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The following passages from DOE 2000b regarding the assignment of sub-group statistics to site 

processes underscore our concerns regarding their use of surrogate data: 

Section F.4: Application of Results to Material Streams 

Application of the available FEMP analytical data to the identified recycled 

uranium mass flows has been accomplished in this report by a combination of 

direct application (data directly represents materials in question) and 

extrapolation (data is selected from available sub-groups to approximate the 

material in question) using process knowledge as a guide. [DOE 2000b, p. F-5 

(1099 of PDF)]

...a relatively small number of analytical values are utilized to represent 

approximately 40 years of Fernald shipments, receipts, and production and are 

also utilized to represent other DOE site recycled uranium... [DOE 2000b, 

pp. F-5 to F-6 (1099-1100 of PDF)]

Application of the data (discussed further in Appendix F) is not limited to the use 

of the 19 sub-groups, since an individual data point within the database actually 

represents a material that exists/existed at the FEMP. Such is the case with the 

representation of West Valley UNH, for example. A single data point in the 

database actually represents a batch of the UNH processed to an intermediate 

material at the FEMP and has been presumed to better represent the West 

Valley UNH than any of the sub-groups developed. [Emphasis added] (DOE 

2000b, p. 575 of PDF) 

This last statement indicates that a single datum from Fernald regarding UNH processing was 

applied to West Valley solely on the basis of process knowledge determinations. The 

uncertainty associated with this and other process knowledge assignments is not quantified 

in the DOE 2000b report.

A recurring concern for SC&A is that NIOSH has not made an independent analysis of the 

data and analysis for its suitability for dose reconstruction under EEOICPA and its 

regulations. DOE 2000b acknowledges that there are no data for many of the RU receipts and 

assumes that the contaminant values are the same as those of other RU streams presumed to be 

similar. This may be understandable in an approximate materials balance report; however, given 

the wide variations in trace contaminant streams, the use of a derived average value without an 

analysis of the processes is questionable in a dose reconstruction context at best; using it as part 

of a bounding value estimate in an SEC context is also problematic. 

NIOSH has also failed to adequately account for bias and uncertainty introduced in extrapolating 

the sub-group data to earlier periods. While SC&A understands that a truly bounding value will 

by definition account for bias and uncertainty, NIOSH has not demonstrated that their defaults 

are bounding, especially for the early period (pre-1970) when no site-specific data are available 

for Fernald. It is noteworthy that DOE 2000b provides the following cautionary statement 

regarding back-extrapolation: 
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One known bias that was not generally factored into data segregation is the 

period of production. Because FEMP analytical data primarily represents the 

production period from the middle to late 1980s, the use of the data for prior 

periods must be evaluated using available process knowledge. Application of the 

data using extrapolation is possible, but the limits of the applicability must be 

understood. [Emphasis added] (DOE 2000b, Appendix F, p. 1095) 

Finding #11 from SC&A 2009 summarizes our concerns regarding the statistical analysis applied 

to the sub group data to arrive at the average values listed in Table 3 above. 

Finding 11: A preliminary review of the analysis in DOE 2000b indicates that 

the bootstrap analysis method may be inappropriate in a dose reconstruction 

context; it does not appear to be claimant favorable. Assuming the data are 

suitable for use in dose reconstruction, the use of lognormal distribution appears 

to be more appropriate. 

Regarding Finding #11, NIOSH states in their most recent response to SC&A’s findings (NIOSH 

2010, p. 18): 

The bootstrap approach selected to analyze the data was very appropriate 

considering the nature of the data. 

As indicated in DOE 2000b, “none of the constituent data sub-groups conform to 

a pure distribution.” The report further states, “In all cases, the datasets were 

determined to be best represented by the use of a simple arithmetic average of the 

data values.” The bootstrap analysis, which is a very appropriate method for 

statistical analysis of data that does not follow any standard distribution type, 

was used as the basis for this conclusion. This conclusion was the best judgment 

of the individuals that were most familiar with the data. Although a log-normal 

distribution was clearly evaluated, the conclusion was that log-normal did not 

best represent the datasets. 

A review of the plots for the sub-groups clearly indicates the difficult analysis 

problem that the Ohio Report team had with the data. None of the data fits a 

normal or standard statistical distribution pattern that lends itself to easy 

analysis, which is why the team elected to use the bootstrap analysis for their 

method. 

The spread of the data actually indicates another conclusion when the focus is on 

dose reconstruction. The data indicates that the samples in each sub-group did 

not come from a homogenous population, which is not an unexpected result 

considering the source of the samples varies over a range of facilities, a range of 

processes, and over a significant period of time. Most of the data points are at 

the low end of the range for each sub-group, which is consistent with the fact that 

most (75%) of the material handled at Fernald was not enriched, and would have 

had fairly low levels of RU contaminants. 
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This most recent response by NIOSH amounts to a restatement of their original position. Note 

that the last sentence of the last paragraph above could be interpreted as a description of lognormally distributed data. 

The 19 process subgroups and attributes of the assigned datasets are described in detail in pages 

C-12 to C-17 of DOE 2000b. It is noteworthy that for each subgroup, the data distributions are 

indicated to be representative of the range of expected values. For example, as regards Sub 

Group 8, ‘Enriched MgF2,’ DOE 2000b states: 

While the range of this data set is very broad, the FEMP process knowledge team 

believes the values in this data set are consistent with the anticipated levels of the 

constituents of concern in MgF2 from the metal reduction process. (DOE 2000b, 

p. C.1-4 [p. 578 of PDF) 

These acknowledgments by the Ohio Field Office team that the subgroup data are to be 

considered representative of expected values appear to contradict NIOSH’s assertion above. 

That is, in a dose reconstruction or SEC context, the full distribution of sub-process data should 

be considered, not just a central estimate (e.g., arithmetic or “bootstrap” average). 

SC&A understands that NIOSH has not actually compiled or analyzed the data underlying DOE 

2000b, nor reviewed its conclusion that the usual statistical analysis using lognormal 

distributions is inappropriate. Since DOE 2000b contains the data as compiled by DOE (but not 

the raw data), SC&A did a preliminary analysis as to whether the lognormal analysis is 

inappropriate and, if not, whether the bootstrap analysis is claimant favorable. That preliminary 

analysis is included in SC&A 2009 as Attachment 1. The following paragraphs from SC&A 

2009 bear repeating: 

A comparison of the results of simple averaging, bootstrap means, and lognormal 

means is provided in Table 1 of Attachment F.1 in DOE 2000b (pp. F.1-1 to F.1-

5). SC&A’s preliminary conclusion from these values is that the reduced 

influence of the extreme values, which is the underlying rationale for the 

bootstrap method, is inappropriate in this case. These extreme values cannot be 

treated as outliers in the normal statistical sense of being suspect 

measurements, which should be assigned less weight on that account. The high 

measurements should be treated as actual values of contamination that may 

have been experienced by some workers and be assigned a full weighting in the 

analysis. Were the lognormal distribution to be used, the mean values would be 

considerably greater than those derived by DOE using the bootstrap analysis, 

which are the values used in the NIOSH White Paper. Firm conclusions in this 

regard can only be arrived at after an examination of the raw data. SC&A’s 

preliminary analysis is provided in Attachment A to this report. [Emphasis 

added] (SC&A 2009, p. 19) 

Moreover, the upper confidence limits of the means are far higher than the means 

themselves. NIOSH has not provided any discussion of, or rationale for, using the 

means rather than the upper confidence bound of the mean for dose 
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reconstruction for long-term employees and of 95th percentile values for shortterm employees. The bootstrap method, as applied by DOE, does not provide 

estimates of the 95th percentile values nor their confidence bounds. 

Alternatively, the lognormal estimates derived by DOE provide the necessary 

information to estimate the 95th percentile exposures. [Emphasis added] 

(SC&A 2009, p. 19) 

Attachment 1 of SC&A 2009 states: 

...the lognormal and bootstrap estimates differ markedly in 4 of the 19 subgroups: Sub-groups 1A, 8, 9, and 10A. 

In these four sub-groups, the lognormal mean estimate exceeds the bootstrap 

mean estimate by factors ranging from 2 to 5 times higher. This set of sub-groups 

also includes four of the five highest sub-groups, when the sub-groups are ranked 

by the estimated lognormal mean. Note that the bootstrap estimates agree with 

the arithmetic mean in all subgroups; hence, the lognormal mean exceeds the 

arithmetic mean by roughly the same factor as for the bootstrap mean in the four 

highlighted subgroups. 

In general, the lognormal plots for plutonium shown in Appendix F fit the data 

much better than the normal plots. In particular, inspection of the lognormal 

plots indicates that the lognormal model appears to fit relatively well for the four 

subgroups noted above. Moreover, the lognormal model appears to 

underestimate the extreme upper tail of the distributions in all four cases. 

[Emphasis added] 

Based on this cursory examination, it appears that the bootstrap method performs 

as expected—it is designed to reduce the influence of extreme outliers, thus 

providing a stable estimate of the mean. In this case, however, the reduction of 

influence of outliers is not claimant favorable. The lognormal estimates of the 

mean include the influence of these high-end values, which should not be 

treated as "outliers.” [Emphasis added] 

SC&A has expanded the analysis of the data provided in Table 1 of Attachment F.1 in DOE 

2000b to include Np-237 and Tc-99. That analysis is included as Attachment 1 to this white 

paper. In summary, this expanded analysis confirms the conclusions drawn from Attachment 1 

to SC&A 2009 regarding the appropriateness of the log-normal model for the subgroup data, as 

applied to all three RU constituents. 

4.3.3 Additional Commentary on DOE 2000b 

Given the heavy reliance on DOE 2000b by NIOSH as the basis for bounding doses from RU, 

SC&A believes that it is crucial to understand the context in which that report was conceived and 

developed. Such an understanding will highlight the limitations of that report as a basis 

document in the SEC context. To that end, SC&A has drawn on the experiences of James (Jim) 
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Werner, an SC&A Associate who was formerly employed by the DOE Office of Environmental 

Management (EM) and was involved in managing the preparation of that document. 

Associate’s Credentials 

The 1997 Linking Legacies report by DOE (DOE 1997), which was prepared through Mr. 

Werner’s office under his direction, documented the flow of RU through the AEC, Energy 

Research Development Administration, and DOE complex. Linking Legacies was the source of 

the basic materials flow diagrams used in the various Recycled Uranium and Uranium Mass 

Balance Project reports.3

 To our knowledge, Linking Legacies was the first publicly available 

U.S. Government document to acknowledge the shipments of recycled uranium from Hanford 

and Savannah River site to Paducah, Portsmouth and the Oak Ridge GDPs, Fernald and other 

sites. Mr. Werner deliberately sought to clearly document the RU shipments in Linking Legacies

because he had become aware of this practice of shipping RU to the GDPs from the reprocessing 

sites when he worked in the 1980s as a contractor to DOE performing field surveys of 

environmental problems at DOE sites, including Portsmouth, Paducah and the Oak Ridge K-25 

GDPs. Mr. Werner became aware of the RU issue upon his first contractor assignment working 

as an environmental engineer in August 1986. 

In May 1999, Mr. Werner was the DOE official to whom the relators4 in the Qui Tam lawsuit, 

led by the Natural Resources Defense Council (where he was employed from 1989 to 1993) 

initially delivered documentation of the DOE contractor’s alleged failure to report certain worker 

exposures and environmental releases. This lawsuit5 alleging that the contractor submitted 

inaccurate and incomplete reports to the federal government triggered the cascade of events 

leading up to the “DOE 2000b” report and enactment of the EEOICPA. 

In addition to the overview analysis in “Linking Legacies” of specific nuclear weapons processes 

and their byproducts, EM supported others studies to seek to better understand the extent of 

contamination and waste disposal at particular sites, such as Hanford (Sederburg and Reddick, 

1994). These analyses documented the frequently changing flow sheets for the reprocessing 

operations. The two major reprocessing sites regularly re-engineered the reprocessing operations 

to seek to optimize the efficiency of the chemical extraction process (i.e., separate out more 

desirable fissile plutonium for target material and more uranium from the spent driver fuel, 

which was the source of the recycle uranium). Over the years, numerous experiments were 

conducted by engineers and scientists at both Hanford and Savannah River sites, and later scaled 

up to the whole large-scale reprocessing canyon operations. These experiments and operational 

process changes involved changes in acids (e.g., nitric acid to hydrofluoric acid), solvents (e.g., 

kerosene to tributyl phosphate), as well as changes in the equipment (e.g., chop and leach tanks, 

slab tanks, agitators, counterflow pulse extraction columns (ANL 1971, GE 1951, Gerber 1993), 

temperatures, pressures, cycle times, and use of catalysts. All of this “tweaking” resulted in 

 3

 See Figures 3-3A, B, C, and D, in the Hanford Uranium Mass Balance Project report (DOE 2000a) in 

Section 3, Pages 4–7. 4

 A “relator” in a False Claims Act lawsuit is comparable to a plaintiff in other civil matters. 

5

 United States ex rel. Natural Resources Defense Council, et al., v. Lockheed Martin Corporation, et al., 

Civil Action No. 5:99CV00170-M (W.D. Ky.). The lawsuit was filed in June 1999, and the U.S. Justice Department 

joined the lawsuit in 2003. 
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substantial improvements in the efficiency of extraction of plutonium or uranium. Hence, earlier 

operations (e.g., 1940s–1960s), or operations for which plutonium removal was not optimized 

(e.g., neptunium removal experiments), likely contained significantly higher concentrations of 

plutonium and other TRU and fission products than later RU batches (e.g., 1970s and 1980s) 

when processes had been refined further. 

Mr. Werner had previously analyzed the issue of DOE’s historic dichotomy in accounting for 

plutonium material, based on whether it was a stockpile asset or regarded as a contaminant in 

waste. He helped coordinate a groundbreaking DOE report in 1996 that declassified plutonium 

stockpiles (DOE 1996). Specifically, he was the primary author of Appendix B in that report 

(“Plutonium Waste”), which detailed how plutonium that was disposed of as waste was not 

accounted for with the same rigor accorded to plutonium still considered part of the production 

system using the Nuclear Materials Management and Safeguards System. Similar to DOE 

2000b, this initial report on plutonium was not the last word on the issue, and site specific details 

remained to be analyzed further with greater quantitative rigor (Alvarez 2010 and Wald 2010). 

Also, this 1996 analysis documented that concentration data for Pu in “waste” (including RU 

byproducts streams) were less reliable than concentration data for Pu in nuclear weapons 

stockpile material. 

In reviewing draft materials for the report that became DOE 2000b, Mr. Werner expressed 

concern about the historic lack of rigor in accounting for plutonium contamination in RU and the 

need to examine more carefully any source data regarding plutonium contamination 

concentrations in RU. The general response to these concerns at the time was, essentially, “we 

will get to that issue later because we don’t have time right now and we just need to get this out 

the door.” This explanation was generally accepted in the context of the significant pressures at 

the time to enact the worker compensations legislation and respond to congressional and media 

scrutiny with the idea that specific details could be filled in later. 

This following narrative supplied by Mr. Werner is intended to explain the circumstances of how 

DOE 2000b was compiled and what analysis would have been necessary to make it more 

comprehensive and representative. 

Overall, NIOSH relies extensively on DOE 2000b for specific details of contaminant 

concentrations in recycled uranium (RU) at various sites, especially the Fernald (ORAUT 2004a) 

and Weldon Spring Sites (ORAUT 2005). Because the report is central to many of the estimates 

of RU, it is useful to summarize briefly the circumstances under which it was prepared to better 

understand the limitations on using it to reach a conclusion on exposures and dose estimate for 

particular sites. 

The “DOE 2000b” document was prepared in about 9 months during a period of significant 

pressure from ongoing political and media publicity about the recycle uranium (RU) issue and 

the resulting plutonium exposures. Several factors created a high pressure situation under which 

DOE 2000b was prepared in 1999–2000: 

 False Claims Act Qui Tam lawsuit for which a major DOE contractor (Lockheed Martin 

Corporation) was defendant 
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 News media publicity about excessive and previously undisclosed worker exposures, 

including from contaminants in recycle uranium 

 Congressional hearings on previously undisclosed worker exposures and environmental 

releases (e.g., at Paducah), including from contaminants in recycle uranium 

 Reorganization of the DOE Field office 

 End of Clinton Administration Second term and End of Congressional term (deadline for 

enactment of worker compensation legislation) 

The cascade of events ultimately resulting in the release of DOE 2000b and the enactment of the 

EEOICPA were initiated by the filing of a “Qui Tam” lawsuit under the False Claims Act in 

1999 and related Congressional hearings. One of the primary allegations in this lawsuit was the 

failure of DOE’s contractors to provide accurate reports about the contamination levels in RU 

and how the contaminant levels changed over time.6

 This lawsuit attracted media and 

Congressional attention. 

The DOE 2000b report was part of an extraordinary effort by a large team of DOE staff and 

contractors who were directed by senior management to obtain any information relevant to 

recycled uranium and make it public. The management direction from the DOE Secretary and 

Assistant Secretary was clear and unambiguous: make public any available information on the 

use of recycled uranium and its possible consequences to workers, public health and the 

environment. Nonetheless, this massive undertaking, involving dozens of sites and hundreds of 

staff was performed under enormous pressure with revelations in prominent newspapers about 

worker exposures—especially at the PGDP in Kentucky, and a worker compensation bill (which 

eventually became the EEOICPA) being debated on Capitol Hill. From start to finish, including 

research, writing, editing, technical, management and legal clearance reviews, the report was 

compiled in about nine months. Given how much detailed and useful, albeit incomplete, 

information is provided and integrated in a well-organized manner, it might be easy to forget that 

this large tome was compiled in such a brief period, under such enormous pressure. To regard it 

as the definitive and final word on the subject of RU would be to overstate its 

comprehensiveness and understate the challenges during its genesis. In fact, it was widely 

recognized at the time that this was an initial effort and there were many issues left unexamined 

for lack of time. In various places, the report recognizes it own incompleteness.7

The compilation of the data for DOE 2000b was done under extraordinary circumstances. The 

results provide a remarkable level of insight and information for such a large complex analysis 

performed under very short time constraints (less than nine months from August 1999 to April 

2000, when the draft was circulated) with significant political and news media pressures. 

Nonetheless, despite the extraordinary accomplishment of preparing DOE 2000b under 

such challenging circumstances, it cannot serve as a reliable source of information for 

precise or accurate data on TRU and fission product contaminant concentrations in 

recycled uranium that is reliably representative of the RU shipments to Fernald, Weldon 

 6

 United States ex rel. Natural Resources Defense Council, et al., v. Lockheed Martin Corporation, et al., 

Civil Action No. 5:99CV00170-M (W.D. Ky.). The lawsuit was filed in June 1999, and the U.S. Justice Department 

joined the lawsuit in 2003. 7

 See e.g., DOE 2000b, page 884, Appendix E, “...additional information is still being found.” 
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Spring and other sites. It may or may not be possible to compile more complete and 

representative data, but the analysts who compiled DOE 2000b knew at the time that to 

obtain and analyze the full range of data needed to ensure a reasonably complete and 

representative characterization of the contaminant concentrations would require more 

time than was available in late 1999 – early 2000. 

The primary report, “Recycled Uranium Mass Balance Project (RUMBP)” (See 

http://www.dnr.mo.gov/env/hwp/ws-special/ws-shipments.pdf), was initiated by the then-Energy 

Secretary in the midst of the effort to enact the worker compensation legislation (Energy 

Employee Occupational Illness Compensation Program Act (P.L. 106-398)). It was deemed 

more important at the time to do a timely and adequate job, than to do a complete and detailed 

review that might come too late to help inform the legislative process or respond to the urgent 

questions then focused on the Paducah Plant. Also, DOE believed that they could not afford to 

wait more than a year to complete a more comprehensive analysis, which could have left behind 

thousands of workers at several sites where RU was processed. This pragmatism made sense 

then, but it does not mean that the issue should not have been revisited. 

At the time DOE was compiling its landmark RU report (DOE 2000b), many knew that the 

analysis would be limited of necessity because of the very strict time limitations and lack of 

confidence in historic health physics and chemical analysis data, particularly from the pre-1980s 

period. There was intense pressure to complete the analysis so that it could be available to 

support the worker compensation legislation then being considered by Congress. One of the big 

questions DOE faced from both supporters and opponents of the legislation is, “what is the scope 

and expected cost of the worker compensation program being contemplated?” The analysis in 

DOE 2000b was expected to help put a rough boundary on that scope question and provide 

qualitative documentation that exposures occurred with sufficient quantification to 

substantiate the exposures, but not necessarily sufficient to serve comprehensively 

representative characterization of the exposures. Simply put, it was not intended to be the 

last word on the scope of RU uranium shipments, processing and exposures. Many expected 

it to be followed by a more detail examination of specific issues that arose in producing DOE 

2000b. These follow-on analyses could take years, rather than months to complete. The 

expectation was that DOE 2000b would be sufficient to document thoroughly the qualitative fact 

that RU shipments and processing occurred and that it could have led to elevated, albeit 

unquantified, exposures to contaminants in the RU. DOE 2000b was the best that could be done 

at that time, with limited time available, and was sufficient to document the basis for the need for 

a worker compensation program, which became EEOICPA. The exact level of those exposures, 

however, was beyond the scope DOE 2000b. Regrettably, those follow-on analyses many of 

us thought in 2000 would be undertaken in 2001–2004 to support EEOICPA appear not to 

have occurred.

There are several areas that merited more detailed examination beyond DOE 2000b to help 

quantify contaminants in RU, which could help assess worker exposures. 

First, DOE should have undertaken a more detailed analysis of the various sources of RU, from 

various specific locations at various times [each chemical separation and high level waste facility 

including particular reprocessing facilities within Hanford (e.g., T, B, U, UO3, and PUREX), 
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Savannah River Site (e.g., F- and H-canyons), and West Valley]. The TRU and fission product 

contamination in RU differed depending on the source of the RU. The RU varied with (1) the 

locations of the generation source, (2) the process operations occurring at that time at each 

location during the time when the RU was produced, and (3) the feed material being processed. 

Second, at each reprocessing facility, almost continuous process improvements resulted in 

changing product streams, which occurred regularly to improve the efficiency and extraction 

rate. Each of these process changes altered the characteristics of the effluent stream of RU. One 

example was the shift from kerosene as the organic extractant to tributyl phosphate. There were 

numerous other chemical formulation changes that resulted in greater Pu extraction efficiency 

over the years, or selective extraction of different constituents. 

Third, for each process at each facility, DOE could have analyzed the impact of feed materials 

changes and resulting output types. The fuel and target assemblies were changed at each facility, 

usually to help improve the production and purity of Pu-239 and tritium. At the Savannah River 

Plant, the M Area, and the Hanford 300 Area employed thousands of people working on fuel 

fabrication for the production reactors and regularly modified fuel and target structures and 

geometries to optimize target irradiation and Pu production. At the Savannah River site, the 

advances in reactors fuel/target design and fabrications, reactor operations and reprocessing 

operations resulted in highly purified Pu-239 known as “Super grade” plutonium. These process 

changes generally increased the amount of Pu recovered from the 1950s to the 1970s and would 

have affected the amount of Pu left behind in U solutions. Accordingly, given more time, the 

types of contaminants in various RU streams could have been examined in more detail. As 

SC&A noted in its March 2009 review of the NIOSH White Paper, the NIOSH analysis entirely 

omitted the Hanford U Plant, which produced some of the recycle uranium by processing 

uranium-laden high-level waste from the underground waste tanks at Hanford. The Hanford 

RU report indicated that the Pu concentrations in the high-level waste were 2–4 ppm (i.e., 

2,000–4,000 ppb), but the specification for sending PU to the UO3 plant 80 ppb (DOE 

2000a, p. 12). There was no time during the production of DOE 2000b to dig up the actual

plant process analysis logs and lab records to determine whether this specification was m

or ignored. No data at all was provided for RU from the West Valley site where records 

were missing and presumed buried in a waste 

et 

site.

The Mass Balance report for recycled uranium in DOE 2000b also suggests that Pu 

concentrations were higher than earlier estimates: “Employees working with plutonium-bearing 

materials (greater than 1 ppm [not ppb] in U) were examined once every six weeks” (DOE 

2000c, p. 2-32). 

Some of the technical basis documents (TBDs) appear to refer to plutonium concentrations based 

on DOE 1985. That Task Force report, however, was intended to establish limits for Pu in RU. 

The fact that this Task Force felt compelled to advocate for new limits, suggests that the earlier 

limits referred to (e.g., Bihl 2003) were not being followed consistently or needed to be changed. 

The 1985 Task Force report also acknowledged that different limits were being used at different 

sites. 
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While there is some evidence supporting Pu concentration in the 10–100 ppb range, it is not 

based on a comprehensive or representative analysis of RU sources. This is a critical question 

that deserves to be resolved rigorously to meet the threshold required under EEOICPA and give 

petitioners a greater level of confidence in the resolution. Clarifying some of the apparent 

inconsistencies noted above and providing greater detail on data sources would help reduce the 

lingering uncertainty about Pu concentrations. Also, the specific sources and varying 

characteristics of RU should be identified as much as possible. 

The commentary provided by Mr. Werner demonstrates that, contrary to NIOSH’s assertion, 

DOE 2000b is neither a comprehensive nor reliably representative compilation of RU operations 

and shipments that can be relied upon as the basis for bounding estimates of RU contaminant 

concentrations. This underscores SC&A’s recommendation that NIOSH analyze the source data 

for DOE 2000b and available site-specific measurements to ensure that worker exposures from 

RU contaminants at Fernald are bounded. 

Finding #4: DOE 2000b is questionable as the basis for the NIOSH defaults; source data 

should be reviewed in the context of dose reconstruction and an SEC 

The DOE 2000b report for RU data is neither comprehensive nor reliably representative and 

rigorous in its scrutiny of data validity. Clearly the subgroups listed in Tables ES-5A, 5C and 

5D are not sufficiently detailed to reflect the wide range of RU sources that would result from 

analysis of the permutations of processing facility, process operations, time of operation and 

fuel/target type. It is incumbent on NIOSH to review the source data for its adequacy in 

bounding worker doses in an SEC context. 
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5.0 SITE-SPECIFIC DATA – AIR CONCENTRATIONS AND FEED 

MATERIAL MEASUREMENTS 

Prior to the November 9, 2010, Fernald Work Group meeting, SC&A performed a preliminary 

review of data from a series of dust collector samples taken at various locations at Fernald in 

1985. These data are presented in the NIOSH white paper in Appendix B and discussed towards 

the end of Section 4.0 of that report. The source document for the data is a report prepared by 

the Fernald M&O contractor at the time, Westinghouse Materials Company of Ohio (WMCO), 

entitled, History of FMPC Radionuclide Discharges (Fernald 1987). SC&A’s preliminary 

review of these data indicates that the NIOSH default values may not be bounding for some 

classes of workers in some facilities during the proposed SEC period. Consequently, the Board 

requested that SC&A prepare a formal white paper review of these and other data that may be of 

use in determining whether the NIOSH defaults are bounding. Under that directive, SC&A 

conducted an exhaustive search of the SRDB to locate additional relevant data. As a result of 

that search, SC&A located several datasets, including three that were analyzed to supplement the 

1985 dust data. These were: 

 An additional set of contaminant ratios in scrubber solution (which is assumed in the 

report to be the same as the stack effluent) measurements (Fernald 1987) 

a. Subsumed into 1985 dust data discussion 

 Perimeter air sampling results for Fernald from 1983 (DOE 1985; Fernald 1987) 

 Air filter and smear samples collected in Plants 4 and 8 in 1989 (USTC 1989; Bassett 

et al. 1989) 

 Constituent levels in Hanford PUREX UNH from campaigns in 1970, 1971 

(Ward 1968; ARH 1969a, 1969b, 1969c, 1970a, 1970b, 1972a, and 1972b) 

 Analytical data on a shipment to Fernald that was suspected by Nuclear Fuel Services 

(NFS) at West Valley to contain elevated levels of neptunium (Noyes and Quigley 

1967) 

 Additional data from West Valley in a series of shipping documents with dates that 

range from December 30, 1967, through June 3, 1969, and generally contain data on 

plutonium (by alpha), thorium, and several fission products (ruthenium, strontium, and 

zirconium). 

The section begins with a review of the 1985 dust collector data; the supplementary datasets are 

then discussed and summarized. 

5.1 1985 DUST COLLECTOR AND SCRUBBER SOLUTION SAMPLES (FERNALD 

1987) 

Samples of bulk dust taken during 1985 were analyzed for 14 radionuclides in addition to 

uranium. Data were reported in units of μCi/kg U for Pu-239/240, Pu-238, Np-237, Th-234, 

Pa-234, Th-232, Th-230, Th-228, Ra-226, Cs-137, Ru-106, Tc-99 and Sr-90. A total of 36 

samples were taken; 6 from Plant 1, 8 from Plant 4, 14 from Plant 5, 3 from Plant 8, 1 from Plant 
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9, and 3 from the Pilot Plant. Additional information on the dust collector samples is provided in 

Attachment 2 and is presented as a truncated version of NIOSH 2008 Appendix B. Additional 

information is provided on the particle size distribution and uranium enrichment of the sample, 

as well as a qualitative statement on the exposure potential at the sampling locations (as 

presented in DOE 2000b).8

 Note that the dust collector data were a subset of the data used to 

populate the 19 subgroups in DOE 2000b. 

An additional set of measurements were found in the report “History of FMPC Radionuclide 

Discharges” (Fernald 1987). This additional data is a set of contaminant ratios in scrubber 

solution for three locations; the box furnace, rotary kiln, and No. 1 oxidation furnace. It is 

assumed in the report that the scrubber solution concentrations are the same as in airborne dust. 

It is not clear to what extent these measurements would be applicable to contaminant ratios the 

workers may have experienced during normal working conditions. 

SC&A’s review of the collector dust and scrubber data was limited to Pu-239/240, Np-237, 

Tc-99, and Sr-90. Radionuclides that are not considered pertinent to an evaluation of the NIOSH 

defaults for transuranic and fission products in RU were not reviewed. For example, SC&A’s 

preliminary review of the dust and scrubber data revealed that all samples showed levels of 

Th-232 and Th-228 far in excess of the NIOSH default of 1E-3 μCi/kg U. While the doses 

attributed to such levels of thorium far exceed the associated uranium doses (see Section 4.1 

“Dosimetric Implications”), most of the thorium contamination can be attributed to thorium 

metal production that took place at Fernald from the early 1950s through the 1980s and not RU 

processing. NIOSH has proposed other methods for assessing thorium dose that are outside the 

scope of this review. Likewise, Pa-234 and Ra-226, which are part of the U-238 decay chain, 

were not included in this review. All ruthenium values were less than the detection limits of the 

analysis used, reflecting the approximately 1 year half-life. Although no default was established 

for Cs-137, SC&A has noted elevated concentrations that appear to track with Sr-90 levels in 

some cases. 

5.1.1 Dust Sampling Process 

The purpose of originally collecting and analyzing the 1985 effluent samples is described in 

Fernald 1987 as follows: 

Information in this report was compiled in response to a DOE request for a 

history of radionuclide discharges during the 34 years of FMPC operations from 

1951 through 1984. DOE desired that best estimates be made when sampling 

data were not available to provide a complete history. (Fernald 1987, p. 8) 

Fernald 1987, however, provides only general information about the bulk dust samples and how 

they were collected and analyzed. It is important to note that the extensive set of atmospheric 

discharge data reported in Fernald 1987 were for samples collected at regular intervals 

 8

 While not all of the sampling locations presented in Fernald 1987 were discussed qualitatively in DOE 

2000b, there was enough information to match several of the sampling locations in each report. An additional 

column is found in Attachment 2, which discusses how some of the less obvious matches were made. 
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(nominally on a monthly basis) from the stacks, downstream from the bulk dust collectors. The 

collection period is not reported for the bulk dust samples. 

Fernald 1987 states: 

Most uranium production operations result in the generation of dust, fume or 

reaction gasses. These operations are conducted in ventilated enclosures and the 

air is passed through dust collectors or scrubbers. The filtered or scrubbed air is 

exhausted to the atmosphere. (Fernald 1987, p. 9)

Over ninety dust collectors have been used at the FMPC with fifty-three currently 

in use. Some original collectors have been replaced and others were removed 

from service as production operations changed. (Fernald 1987, p. 9)

Most FMPC dust collectors have handled several different enrichments and many 

have handled more than one uranium compound throughout an operating 

lifetime. ...in some production plants, overall operations have changed little over 

the years. For example, U03 has been the major refinery product and the Plant 4 

process still begins with U03 and ends with the UF4 product. The Plant 5 

reduction area dusts are UF4 and U308 (in MgF2). The principal uranium dust

produced in the Plant 5 remelt area, Plant 9 and Plant 6 is U308. Various 

compounds have been handled in Plant 1, Plant 8 and the Pilot Plant. (Fernald 

1987, p. 20) 

Particle size information was obtained on bulk dust collector material and on airstream particulates from collector inlet and outlet ducts. Samples were collected 

from June through September, 1985. (Fernald 1987, p. 22) 

During 1985, inlet and outlet duct samples were collected from 15 dust collectors 

and analyzed. Results are provided in Tables 16–30. Bulk samples were also 

collected from 21 other dust collectors and analyzed for particle size, percent 

uranium and isotopic uranium composition. Results are provided in Tables 31–

51. (Fernald 1987, p. 23) 

On several occasions, thorium metal and compounds were produced at the 

FMPC. These operations were served by dust collectors and scrubbers and 

occasional thorium discharges occurred. Table 88 lists all such releases. 

(Fernald 1987, p. 24) 

To provide a basis for estimating the emission of other radionuclides, samples 

of bulk dust taken during 1985 from 36 dust collectors were analyzed for 14 

additional radionuclides. These nuclides were thorium-232 and progeny, 

uranium progeny, transuranics and fission products. Results for the 36 bulk 

samples are given in Tables 52–87. [Emphasis added] (Fernald 1987, p. 23) 
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5.1.2 Gaps and Limitations in the Dust Collector and Scrubber Data 

While the dust collector data represent site-specific RU contaminant ratios that may help 

characterize the exposure potential for particular Fernald operations, it is important from the 

outset to recognize their limitations and the impacts of those limitations for establishing 

bounding ratios for the SEC period. First, the dataset is sparse, containing only 36 samples 

collected in 1985. Fernald 1987 states that there have been over 90 dust collectors used at FMPC 

during its history, with 53 currently being used by the site. Of the 53 operational dust collectors, 

samples from only 36 collectors (or roughly 68%) were used in compiling the report, though no 

rationale was provided as to why only this portion of collectors was analyzed over the others. 

The source report does describe three dust collectors that were not included in the 36 collector 

samples: 

Three Plant 1 dust collectors listed in Table 39

 serve support operations and were 

not equipped with stack samplers through 1984; G2-2, G2-6014 and G2-6015. 

Samplers were installed in 1985. These dust collectors served operations that 

involved dusts with low uranium concentrations. (Fernald 1987, pp. 20–21) 

The operations for these three dust collectors are described as follows: 

 

 G2-2 is at a station where magnesium fluoride (MgF2) slag is unloaded from drums or 

hoppers to be milled (report states the uranium content was 0.2% by weight) 

 G2-6014 is near a cleaning station for drums using an abrasive grit (before the drums 

arrive they are washed with a caustic solution and rinsed with water which removes most 

of the contamination) 

 G2-6015 was sometimes involved in the same cleaning operation as G2-6014 and 

sometimes was involved in shredding copper motor windings, which had only trace 

uranium 

While these operations may have had low uranium content, and thus are not overly important for 

uranium emission estimates, data regarding the level of transuranic and fission product 

contaminants that might have been present would be highly desirable for determining whether 

the NIOSH defaults are bounding. Data for collector G2-2 would have been particularly 

valuable, given the role of MgF2 slag in concentrating RU contaminants. This issue is developed 

further in subsequent paragraphs, in reference to potential exposures from contaminants in 

MgF2. 

e 

ios 

s 

 

No data are provided for the refinery (Plant 2/3), despite the crucial role of that facility in th

conversion of impure uranium feed materials and recycled residues to pure UO3. Refinery

operations with high exposure potential included feed material digestion, denitration, and 

packaging. Plant 8 data are limited to three dust samples and three samples of contaminant rat

in scrubber solution. However, the Fernald 1987 analysis of Plant 8 scrubber solution data i

9

 Table 3 in Fernald 1987 presents historical uranium discharges in Kg U for various dust collectors starting 

in 1953. 
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based on the assumption that constituent concentration ratios in solution are the same as in 

airborne dust. Thus, these data are highly uncertain. The lack of data for Plant 8 is significan

because large quantities of RU residues and scrap were pre-processed there and most Plant 8 

operations involved high dust exposure potential. These included, but were not limited to,

chemical proces

t 

 wet 

sing, furnacing, screening and blending, and hand sorting. (DOE 2000b, 

able D.1-15) 

 may 

nt real-time contaminant concentrations experienced by workers during RU 

rocessing. 

 

iod, NIOSH points to 

section of text in the source report presenting the 1985 data that states: 

 

 lower in 

concentrates. (Fernald 1987, p. 23) 

wever, does not provide or refer to data that would support this assertion. 

C&A 2009 states: 

s 

t this statement actually provides a suitable 

rationale for using the 1985 data. 

 their most recent response to SC&A’s findings, NIOSH states: 

els 

ails 

by Fernald, but was accepted with a high 

degree of awareness and caution. 

T

The fact that the dust samples represent an aggregated mix of materials processed during an 

undetermined collection period is especially problematic. The RU constituents in the samples 

from episodic processing would be expected to be diluted with uncontaminated uranium that was

collected on a more regular basis throughout the undetermined period. Thus, the dust data

under-represe

p

The dust data represent a snapshot in time during a period of increased awareness of RU issues.

Extrapolation of these concentrations to earlier times when data are not available and when no 

consistent purity specifications were in place involves considerable uncertainty, which would

obviously have to be addressed if the dust data are to be used retrospectively. In seeking to 

establish the relevance of the dust data to operations earlier in the SEC per

a 

It is likely that the transuranic and fission product concentrations were

prior years when FMPC feed materials included a high percentage of 

The source report, ho

S

Even though Fernald did process more uranium ore concentrates in earlier 

periods, its relevance for internal exposure potential of the workers who handled 

RU contaminated with trace fission products and transuranic radionuclides need

to be established. It is not clear tha

In

The material would have met the shipping specifications regardless of the source 

of the material. The implication that using the 1985 data to define process lev

in earlier years could result in defaults that were higher is not rational. The 

levels in the early years were the lowest of the operational history at Fernald for 

a number of reasons. First, reported data from Hanford clearly indicate that the 

levels specified by agreed procedure were not only met but were generally <5 ppb

U for Pu. Second, the AEC decision to recover the uranium from the GDPs t

and residues was initially resisted 
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As discussed in Section 4.2.1 of this report, the Hanford working specification of 10 ppb is not 

corroborated by historical documentation, and health physics practices during the time were 

questionable. Thus, our concern has not been resolved. 

Finding #5. Gaps and limitations in the dust data render them questionable as a basis for 

establishing default levels of contaminants in RU for the SEC period 

For the reasons cited above, SC&A believes that the 1985 dust collector data alone are not 

adequate as a basis for establishing default levels of RU contaminants. However, we believe 

that they have some utility in determining whether the NIOSH defaults are bounding for all 

classes of workers at Fernald during the proposed SEC period and potentially for estimating 

intakes for some classes of workers in the 1980s. 

5.1.3 Attributes of the Dust Collector and Scrubber Data 

Despite the limitations described above, the dust data provide insights into the contaminant 

levels that may have been experienced by workers in some of the facilities that processed and 

handled RU, and also help to identify those processes and jobs for which the NIOSH defaults 

may not be bounding. For reference, the NIOSH defaults in units of μCi/kg U are provided in 

column 4 of Table 1. 

Table 4 shows those samples that were near or exceeded the NIOSH default values for Pu-239, 

Np-237, Tc-99, and Sr-90 and also selected values for Cs-137. Column 2 of Table 1 lists the 

percent uranium by weight for the bulk dust samples. A discussion of hypothetical mechanisms 

for some elevated levels follows. 

The high Tc-99 values for Plant 4 are consistent with the Tc-99 volatilization process that 

occurred during hydrofluorination, as identified in DOE 2000b, Table D.1-15. 

The single Plant 8 box furnace scrubber measurement has the second highest Pu ratio and 

elevated levels of Np-237 and Cs-137. While the scrubber data are highly uncertain, the high 

levels in the furnace scrubber solution suggest a concentrating mechanism in the furnacing 

process similar to that observed at the GDPs. This underscores SC&A’s concerns regarding the 

limited data for Plant 8. 

By far the highest concentrations of TRU and thorium were found in the Titan Mill sample (G2-

64) in Building 1. According to the TBD (ORAUT 2004a, p. 15), the Titan Mill was a ringroller mill used to process enriched uranium slag and selected recycle materials for reuse in the 

production of uranium derby metal or for chemical processing to UO3 in the refinery. This 

equipment could reduce particulate size to 95% minus 325-mesh at a rate of up to 9.1 tons per 

day. 

The Titan Mill sample contained about 220 μCi Pu/kg U (factor of 35 above the NIOSH default) 

and 120 μCi Np-237/kg U (factor of 48 higher than default). Note that the Pu content of the dust 

sample was about 1⁄2 the maximum reported concentration of 7,757 ppb (489 μCi/kg U) in the 
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1980 Paducah tower ash receipts (hopper T-058) (NLO 1985, Table 1). Fission products are not 

elevated to a similar degree. 

Table 4. Dust Collector and Scrubber Samples with High Concentration Ratios 

Building/Sample % U by 

Weight Pu-239/240 Np-237 Tc-99 Sr-90 Cs-137 

Default (μCi/kg) 6.3 2.5 150 4.4 NA 

Plant 1 - - - - - 

Titan Mill (G2-64) 16.01 220 120 12 

Titan Mill Packaging 

(G2-76) 2.77 6.1 24 

Sampling area (G2-172) 23.84 - - 500 - - 

Plant 4

No. 1 packaging (G4-4) - - 520 - - 

No. 2 packaging (G4-2) - - 820 - - 

Plant 5 - - 

G2-67 2.32 5.2 1.5 - 78 12 

West Jolters (G5-247) 1.39 3.1 1.4 - 94 11 

No. 3 “F” 1.6 - - - 76 10 

West Breakout 

(G5-254) 2.2 - - - 79 18 

East Breakout (G5-256) 2.5 - - - 4.5 21 

Graphite Machine Shop 

(G5-262) 0.11 - 3.9 - 4.5 66 

Plant 8

Kiln & Calciner 

(G43-27) 10.9 4.7 - - - - 

Box Furnace Scrubber - 71 1.5 13 

In the original NIOSH white paper, the dust collector data were presented as an example of the 

claimant favorability of the default contaminant ratios to those that were actually measured in 

1985. In NIOSH’s attempt to use the dust data to support the contention that the defaults are 

bounding, they censored the Titan Mill sample and averaged the remaining 35 samples for the 

entire facility. The report notes: 

If the default recommendations are compared to the average concentration of 

these RU contaminants found in the dust collector samples, the default values are 

clearly higher than the observed concentrations in 1985. The comparison for Pu 

is 100 ppb versus 14.5 ppb; for Neptunium, it is 3400 ppb versus 560 ppb; for 

Technetium, it is 9,000 ppb versus 4310 ppb. (NIOSH 2008, p. 14) 

In their latest response to SC&A’s findings, NIOSH provided the following explanation for 

excluding the Titan Mill sample from their RU default validation check: 

The Titan Mill filter results are unusual, but are expected to be so. The Titan Mill 

was a process mill, as opposed to a sampling tool in Plant 1 (the Sampling Plant). 

The mill was used to prepare operational samples for further processing by 

breaking the material up, and reducing the particle size to facilitate dissolution. 

For example, the POOS materials would have required careful preparation to 
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assure complete mixing/blending, but would have left filter residues much higher 

than those in the work place after blending. In addition the blending operation 

was more carefully monitored and controlled due to the known higher hazard 

potentials and of relatively short duration. The materials thus processed by the 

Titan Mill do not necessarily represent an exposure source per se and would be 

covered by data in the individual processes. (NIOSH 2010, p. 15) 

SC&A recognizes that the processing of Paducah tower ash into UO3 was the principal source of 

Pu introduced into the Fernald complex after the most contaminated shipment was received in 

1980. According to NLO (1985), the Paducah tower ash was processed into UO3 from 1982 

until at least 1988 (the date of publication). Thus, the very high Pu levels in sample G2-64 in 

1985 likely derive from that tower ash processing that took place in the Titan Mill. However, 

SC&A finds the assertion that contamination and worker exposures were carefully controlled 

during all periods of POOS processing to be questionable, as discussed in detail in Section 4.2 of 

this report. As noted in that section, DOE 1985 states that some of the workers handling the 

tower ash material were ‘requested’ (not required) to wear half-mask respirators, but it is 

uncertain whether this action was actually carried out and how many potentially exposed 

workers were covered. Also, radiation safety procedures to help control exposures from POOS 

material were not actually instituted until 1986. 

SC&A also notes that 5/16th of the 1980 tower ash was repackaged in Plant 4. However, 5 years 

after the shipment and repackaging of the material in Plant 4, low-level transferrable Pu-239 

contamination was found. No surface contamination sampling was done during the actual 

repackaging activity. Remaining repackaging activities took place in Plant 1, with the same 

protective measures according to FMPC, though no documentation could be found by the Task 

Force to corroborate this, and no data were available to evaluate exposures (DOE 1985). 

NIOSH does not mention the reprocessing of MgF2 slag in the Titan Mill for subsequent reuse in 

reduction bomb liners in Plant 5 as a source of elevated exposure potential, though it was well 

known that this was a process by which Pu and other RU contaminants could persist and 

concentrate in Plants 1 and 5. The concentration of contaminant radionuclides is recognized in 

the TBD, which cited an expert evaluation done in 1989 (Bassett et al. 1989). In the case of 

magnesium fluoride feed, a note to Table 5-9 in the TBD states the following: 

Though the results in the table are all reported in ppb U, this measure is 

meaningless in subgroups in which there is very little uranium, such as subgroup 

8, in which the MgF2 did accumulate some isotopes, but was low in uranium by 

design. [ORAUT 2004b, p. 15] 

Despite the fact that the TBD states that trace contaminant values are “meaningless” when there 

is very little uranium present, the quantitative discussion in the TBD and in NIOSH 2008 of RU 

dose estimation is focused primarily on the trace contaminant values of uranium feed material 

and not raffinates or magnesium fluoride. 

A description of the reduction process in Plant 5 is instructive. In Plant 5, UF4 was converted 

into uranium “derby” metal by a thermite reduction process using magnesium metal granules. 
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By-product magnesium fluoride (MgF2) slag was generated in substantial quantities by the 

reduction process. About half of the slag generated was milled for reuse as refractory liner in 

metal reduction pots. Surplus slag either underwent chemical treatment for uranium recovery or 

was discarded to the waste pits, depending upon the isotopic enrichment (DOE 2000b). 

According to DOE 2000b [pp. D.1-73 to D.1-74 (812-813 of PDF)]: 

The reduction process heated UF4 powder mixed with magnesium metal turnings 

in a lined and sealed vessel to initiate a reaction to form uranium metal. The 

uranium metal initially formed in a molten phase and quickly solidified in the 

base of the vessel. The level of solubility of Pu and Np, and probably some 

uranium decay daughter products, in the molten uranium would determine the 

potential for separation of these constituents from the uranium. A study published 

in 1975 (NLCO-1130) [NLCO 1975] reported that 46 percent of the initially fed 

Pu and 63 percent of the initially fed Np reported to the MgF2. 

Because of evidence from the casting operation that a significant portion of the 

higher radioactivity uranium daughter products (Th & Pa) tended to become 

excluded from the uranium matrix, the potential for a similar mechanism 

separating the transuranics at the reduction operation may have been occurring. 

Based on these results, the MgF2 produced would be expected to have relatively 

higher levels of Pu and Np than the materials fed to the process. 

The operation to remove the uranium derby and MgF2 from the reduction vessels 

could have been an exposure point, if concentration occurred in the MgF2. The 

MgF2 milling operations and the operation for forming a MgF2 reduction vessel 

liner could have been as well. 

As regards this last statement, SC&A’s review of the TBD (SC&A 2006) makes the following 

observation, which has not been adequately addressed by NIOSH in the intervening 5-year 

period. 

Workers in some specific jobs may have been exposed to TRU concentrations at much higher 

levels relative to uranium than those handling feed material. For instance, workers manually 

cleaned out crucibles in which UF4 was reduced to metal, according to SC&A site expert 

interviews: 

Some of the high exposure jobs included manning the dumping stations, cleaning 

equipment (i.e., dust collectors, reduction pots, crucibles, furnaces, reaction 

vessels, etc.), inventorying the rabbit hutches, and decontaminating areas when 

needed. Graphite molds were cleaned with a broom handle and steel wool. After 

the removal of the MgF2 from the uranium, individuals would stick their heads 

down as far as they could to clean the slag out of the pot. During this operation 

there was no respiratory protection worn. [Emphasis added.] (SC&A 2006, 

Attachment 4)
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Uranium bioassay data would not be adequate to estimate trace contaminant doses in such cases 

without a very specific knowledge of the contaminant ratios for that particular operation. 

Finally, it is well documented that reduction bomb explosions took place on a regular basis and 

resulted in extremely high dust loading. Clearly, the concentrated contaminants in the bomb 

liners would have been suspended in the dust that resulted from these explosions and would have 

posed a source of exposure to all workers present in the building. 

The concentration process loop involving the Titan Mill and Plant 5 metals production appears to 

be supported by the dust data in Table 4. Neptunium-237 levels were elevated in 3 of the 14 

Plant 5 dust samples and Sr-90 was above the default by up to a factor of 20 in 50% of the 

samples. The highest Np-237 level (3.9 μCi/kg U) was in the graphite machine shop dust sample 

(G5-262). As documented above, graphite used in the crucibles and molds concentrated 

transuranics and fission products in much the same way as MgF2. 

This concentrated material would pose a source of elevated exposure that was not limited to the 

milling of POOS materials (e.g., Paducah tower ash) or processing it in the refinery. Moreover, 

it is highly doubtful that unique health and safety measures (e.g., respiratory protection) were 

employed to control exposures to all potentially affected workers from the time that the material 

was first introduced into production in 1982 through the end of the proposed SEC period in 

1989. 

Further evidence supporting this elevated exposure potential in Plants 1 and 5 is found in 

Table D.1-15 of DOE 2000b, where Plant 1 general milling and Titan milling and Plant 5 

reduction bomb preparation, furnacing and breakout are identified as operations with high 

potential for exposure to airborne radioactive dust. The dust exposure potential for different 

operations is included in Attachment 1. 

In summary, SC&A believes that processes that concentrated RU contaminants but that resulted 

in low uranium content cannot be ignored, particularly in an SEC context (SC&A 2006). 

Finding #6: Dust data do not support NIOSH defaults for some classes of workers in some 

facilities 

The Plant 1 and Plant 5 dust data, while limited in space and time, tend to support the 

concentration and persistence of RU contaminants in those facilities, and suggest that some 

classes of workers were potentially exposed to levels of RU contaminants in excess of the 

NIOSH defaults. 

5.1.4 Lognormal Fit to Dust Collector Data 

To better understand the distributions of contaminant levels in the RU plants represented by the 

dust data, SC&A performed a statistical evaluation of the data for Pu-239, Np-237, Tc-99, and 

Sr-90. A set of normal score plots in Figures A3-1 through A3-32 of Attachment 3 show that the 

lognormal distribution fits the dust ratios fairly well, despite the limited sample sizes. The Titan 

data are the clear outlier in Figures A3-1 and A3-2 for Pu-239 and Np-237, respectively. For 
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illustrative purposes, the lognormal distribution for the entire site is fitted with and without the 

Titan data, as is Building 1. 

Table 5 shows the arithmetic mean and standard deviation (SD) of the dust data for each building 

and the entire site. The parameters of the fitted lognormal distributions (mu and sigma) and the 

geometric mean (GM), geometric standard deviation (GSD), and mean of the fitted lognormal 

distribution are also shown in the table with the 84th and 95th percentiles. 

Table 5. Parameters of Lognormal Distributions Fitted to Filter Dust Ratios 

Entire Site (With Titan) 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 36 6.99 36.04 -1.46 2.47 0.23 11.79 4.89 2.71 13.50 

Np-237 36 3.71 19.67 -1.88 2.01 0.15 7.47 1.15 1.13 4.18 

Tc-99 36 72.79 171.07 1.95 2.56 7.02 12.90 184.63 89.27 471.01 

Sr-90 36 10.48 25.63 -1.41 3.26 0.24 26.09 49.92 6.27 52.27 

Entire Site (Without Titan) 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 35 0.90 1.50 -1.65 2.21 0.19 9.11 2.20 1.73 7.27 

Np-237 35 0.39 0.70 -2.07 1.69 0.13 5.41 0.53 0.68 2.03 

Tc-99 35 73.27 173.47 1.89 2.57 6.61 13.05 179.30 85.11 452.52 

Sr-90 35 10.71 25.95 -1.47 3.29 0.23 26.72 50.63 6.02 50.99 

Building 1 (With Titan) 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 6 38.05 81.40 0.41 2.62 1.50 13.77 46.89 20.42 112.45 

Np-237 6 20.24 44.61 -0.60 2.58 0.55 13.14 15.08 7.08 37.81 

Tc-99 6 112.83 174.69 3.41 1.91 30.22 6.73 185.82 201.12 694.69 

Sr-90 6 4.64 8.70 -1.12 3.00 0.33 20.08 29.27 6.43 45.22 

Building 1 (Without Titan) 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 5 1.66 2.29 -0.59 1.51 0.56 4.54 1.74 2.50 6.69 

Np-237 5 0.29 0.27 -1.68 0.99 0.19 2.70 0.30 0.50 0.95 

Tc-99 5 124.20 189.32 3.29 2.07 26.72 7.89 225.65 208.43 798.85 

Sr-90 5 5.10 9.46 -1.51 3.14 0.22 23.18 30.77 5.01 38.73 
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Table 5. Parameters of Lognormal Distributions Fitted to Filter Dust Ratios 

Building 4 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 8 0.19 0.22 -2.79 1.95 0.06 7.05 0.41 0.43 1.53 

Np-237 8 0.09 0.06 -2.97 1.39 0.05 4.03 0.14 0.21 0.51 

Tc-99 8 211.89 277.62 3.55 3.01 34.83 20.35 3262.94 697.20 4948.71 

Sr-90 8 0.05 0.06 -3.59 1.09 0.03 2.97 0.05 0.08 0.17 

Building 5 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 14 0.98 1.41 -1.26 1.91 0.28 6.74 1.75 1.89 6.53 

Np-237 14 0.67 1.01 -1.59 1.80 0.20 6.05 1.03 1.23 3.95 

Tc-99 14 6.57 9.57 0.66 1.69 1.94 5.43 8.12 10.43 31.37 

Sr-90 14 24.77 36.27 0.49 3.60 1.62 36.43 1041.65 58.02 601.32 

Building 8 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 3 1.83 2.04 -0.24 1.39 0.78 4.00 2.05 3.11 7.68 

Np-237 3 0.36 0.23 -1.39 0.96 0.25 2.61 0.39 0.65 1.20 

Tc-99 3 27.00 10.03 3.20 0.45 24.65 1.58 27.34 38.75 52.09 

Sr-90 3 0.11 0.11 -2.71 0.97 0.07 2.65 0.11 0.18 0.33 

Pilot Plant 

Nuclide N 

Arithmetic 

Mean 

Standard 

Deviation mu sigma GM GSD 

Lognormal 

Mean 

84th 

Percentile 

95th 

Percentile 

 (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) (μCi/kg U) 

Pu-239/240 3 0.21 0.29 -4.31 2.71 0.01 15.07 0.53 0.20 1.16 

Np-237 3 0.06 0.08 -3.89 1.57 0.02 4.79 0.07 0.10 0.27 

Tc-99 3 0.79 0.93 -1.12 1.34 0.32 3.82 0.80 1.23 2.94 

Sr-90 3 0.14 0.19 -4.18 2.33 0.02 10.24 0.23 0.15 0.70 

The summary statistics for the entire site and Plant 1 with and without the Titan Mill demonstrate 

the bias introduced for Pu and Np by NIOSH in selectively censoring that important data point. 

Technetium-99 and Sr-90 were not affected because those levels were from different collectors 

in Plant 1 (Table 4). 

For Plant 1, the lognormal means are consistent with the arithmetic means and the GSDs ranged 

from nearly 7 (Tc-99) to 20 (Sr-90). For all but Tc-99, the means exceeded the 84th percentile 

based on the GM and GSD. Given the caveats implied by Finding #5, the 95th percentile values 

may be more representative of Titan and general milling workers or personnel proximal to those 

operations during and after the Paducah tower ash was introduced in 1980. 
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For Plant 4, the lognormal mean for Tc-99 exceeds the arithmetic mean by a factor of 15; all the 

others are consistent with one another. GSDs ranged from 3 (Sr-90) to 20 (Tc-99). This reflects 

the high Tc-99 content in the vicinity of the hydrofluorination banks from volatilization of that 

radionuclide and the enhanced exposure potential for workers in those areas. 

For Plant 5, the lognormal mean for Sr-90 is 42 times higher than the arithmetic mean and 

reflects the enhanced concentration ratios in the vicinity of the jolters and breakout areas from 

the concentration in reduction bomb liners and graphite molds and crucibles. The GSD of 36 for 

Sr-90 reflects the enormous variability in concentration of that radionuclide within the plant. In 

the absence of more definitive data, the 95th percentiles may be more representative of workers 

handling reduction bomb slag and graphite molds and crucibles during and after the tower ash 

was introduced in 1980. 

The data for Plant 8 and the Pilot Plant appear to indicate low RU contaminant levels for the 

three areas sampled in each building. However, as noted above, the data for Plant 8 are sparse 

and the scrubber data are highly uncertain. 

5.2 PERIMETER AIR SAMPLING DATA (FERNALD 1987 AND DOE 1985) 

DOE 1985 (pp. 25–29) and Fernald 1987 describe boundary air sampling that was conducted at 

Fernald in the early 1980s that measured Pu and Np on a uranium mass basis. These data are 

compared to the dust collector data described above. Figure 4 of DOE 1985 identifies the 

location of seven boundary sampling sites. 

Fernald 1987 describes the perimeter air sampling methodology in detail.

Continuous air sampling is carried out at seven locations on the plant 

perimeter.... Air is drawn at one cubic meter per minute through an 8-inch x 

10-inch filter which is changed weekly. The filter and its dust load are dissolved 

in nitric acid and the resulting solution is analyzed for uranium and radioactivity. 

The remaining solution is held to provide an annual composite for the 

determination of other radionuclides such as thorium isotopes and transuranics. 

(Fernald 1987, p. 11)

Boundary air sampling results for uranium and the trace radionuclides are reported in the Fernald 

Environmental Monitoring Annual Reports. DOE 1985 Tables 5 and 6 provide information 

extracted from Fernald report number NLCO-2018 (NCLO 1984), which presents 1983 data. 

Tables 5 and 6 of DOE 1985 shows the air activity concentration for Np-237 and Pu-239 from a 

composite of 53 weekly samples, expressed in units of μCi/milliliter (mL) of air and air 

concentration of uranium in μg/m3

. It is noteworthy that while the constituent levels were small 

fractions of relevant DOE concentration guides, Pu-239 levels in air for 1983 were a factor of 

about 10 higher than 1982 levels. 

Table 6 provides the results from DOE 1985 and calculated values for Pu-239 and Np-237 in ppb 

U. 
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Table 6. Boundary Air Sampling Results – 1983 

Pu-239 Np-237 Uranium Pu-239 Np-237 

Sample ID μCi/ml μCi/ml μg/m3 ppb U ppb U 

BS1 4.10E-16 6.10E-17 0.031 213 2,789 

BS2 3.20E-16 3.00E-17 0.021 245 2,025 

BS3 5.30E-16 8.70E-17 0.036 237 3,426 

BS4 1.70E-16 2.30E-17 0.013 211 2,508 

BS5 1.40E-16 2.40E-17 0.014 161 2,430 

BS6 9.90E-17 4.40E-18 0.017 94 367 

BS7 2.30E-17 1.30E-17 0.007 53 2,633 

Five of the seven composite samples for Pu-239 in 1983 exceeded the NIOSH default by about a 

factor of two and were an order of magnitude higher than measured levels in the previous year. 

Finding #7: Boundary air concentrations of Pu do not support NIOSH defaults and are 

consistent with elevated levels observed in dust collector data 

Elevated plutonium ratios in site boundary air measurements appear to correlate with the 

onset of processing of the highly contaminated Paducah tower ash shipments and are 

consistent with the elevated levels in Plants 1 and 5. Note also that one would expect 

boundary air concentration ratios to be lower than Plants 1 and 5 source effluents due to 

dilution with uncontaminated uranium from other stacks. 

5.3 AIR SAMPLES AND SWIPES - PLANTS 4 AND 8 

SC&A located a set of analytical results for air filter and smear samples collected by WMCO in 

Plants 4 and 8 in 1989. The results were tabulated in a report from United States Testing 

Company, Inc., dated March 2, 1989 (USTC 1989) and discussed in Bassett et al. (1989). A total 

of 54 results were reported, including 4 air filter samples each from Plants 4 and 8. Air sample 

data sheets indicate that the air samples were all collected 5 ft above the floor. All except AF-5 

were 24-hour collections; AF-5 was an 8.5-hour collection. Twenty smear samples were 

reported for Plant 4 and 20 for Plant 8; none exceeded the defaults for Pu or Np. Page 105 of 

USTC (1989) provides a detailed survey map for Plant 4; maps for Plant 8 are on pages 110 and 

113. The Plant 8 survey was limited to the first floor. These maps allowed SC&A to compare 

the locations of these samples to those of the 1985 dust collector samples, as summarized below 

in Table 7. Note that the 4-year time difference between the two sample collections precludes all 

but a general comparison of the two datasets. 
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Table 7. Plant 4 – Sample Comparison 

Source Dust Coll. # 

or Sample # 

Production 

Location Location Pu-239/240 (μCi/kg U) 

Np-237 

(μCi/kg U) 

NIOSH 2008 

Appendix B G4-2 - No. 2 Pkg 0.054 0.1 

G4-4 - No. 1 Pkg 0.19 0.064 

G4-5 - Hoffman Backup 0.11 0.14 

G4-7 - H2 Off gas 0.63 0.15 

G4-12 - No. 3 Pkg 0.013 0.0035 

G4-13 - Bank 8 Pkg 0.048 0.17 

G4-14 - No. 1 Pkg 0.001 0.007 

G4-15 - Bank 7 Pkg 0.46 0.088 

USTC 1989 AF-1 U308 East Side of Fluid Bed 

Cocoa Reactor #7 9.727 0.469 

AF-2 U308 South side of fluid bed 

cocoa reactor #9 2.540 1.509 

AF-3 U308 

West Side of Fluid Bed 

Cocoa Reactor #9, 

North of #7 

4.495 0.411 

AF-4 U308 West Side of Fluid Bed 

Cocoa Reactor #9 16.261 0.000 

All of the Plant 4 air filter samples were enriched in Pu-239/240; AF-1 and AF-4 were 

significantly higher than the NIOSH default of 6.3 μCi/kg U. Neptunium levels were elevated 

for AF-2 though below the default of 2.5 μCi/kg U. An examination of the survey map in USTC 

(1989) reveals that the packaging stations referred to in Fernald (1987) were located from 15 to 

150 feet from the fluid bed cocoa reactors sampled in 1989. Thus, the marked differences in RU 

contaminant levels between the two sets of samples could simply reflect localized variability in 

concentration ratios within the plant. 

DOE 2000b (pp. D.1-73 to D.1-74) states the following regarding the hydrofluorination process: 

...the process is not believed to have permitted separation of constituents because 

regardless of chemical reaction, the powders were mechanically or pneumatically 

moved through the solid-gas reaction processes from start to finish. The 

exception to this presumption is the situational data that suggests that the Tc-99 

constituent tended to volatilize in high temperature processes, such as 

hydrofluorination, and would tend to collect on dust collector residues and media. 

Although this statement suggests that hydrofluorination was not expected to result in the 

separation of constituents, available data indicate that this was not true for Tc-99, as supported 

by the subgroup process data (Table 3), including the dust collector data (Table 4). Without 

more definitive data, the possibility of Pu and Np separation as an explanation for the elevated 

ratios cannot be ruled out. 
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Table 8. Plant 8 – Sample Comparison 

Source Dust Coll. # 

or Sample # 

Production 

Location Location Pu239/240 Np-237 

NIOSH 2008 

Appendix B G43-27 - Kiln & Calciner 4.7 0.64 

G43-29 - Rotex 0.64 0.36 

8035 - Oxy 1 Furnace 0.16 0.067 

USTC 1989 AF-5 UF4 Rotex 

South of Scale Rollers 

from Rotex Packing 

Station 

2.190 0.189 

AF-6 Raffinate Sump 

Cake 

East Side of Rotary Kiln 

Drumming Station 1.120 0.340 

AF-7 Oxidation Ash 

Drumming 

North End of Drumming 

Station, East Side of 

Oxidation Furnace 1 

2.308 0.206 

AF-8 UF4 - Rotex, 

Outside Zone III 

Rotex Drumming 

Station Area 0.910 0.146 

None of the Plant 8 air filter samples were higher than the NIOSH defaults for Pu-239/240 and 

Np-237. The following sample pairing estimates are based on examination of the survey map for 

Plant 8: 

Rotex - AF-5 and G43-29 

Kiln and Calciner – AF-6 and G43-27 

Oxy 1 Furnace - AF-7 and 8035 

The pairings may indicate a possible trend over time for Pu in the rotex and oxidation furnace 

areas. However, that difference could be from dilution with uncontaminated uranium in the 

aggregated dust collector samples. The higher Pu levels in dust sample G43-27 relative to the 

drumming station might be expected. However, it is difficult to draw meaningful conclusions 

given the large uncertainties in the samples. 

A discussion of this air sampling operation is provided in Bassett et al. (1989). That document 

indicates that the airborne maximum permissible concentration (MPC) of 168 alpha dpm/m3 (8 × 

10-11 μCi/mL) for POOS processing in Plant 4 was based on twice the highest plutonium and 

neptunium concentration found in any POOS material. 

Bassett et al. (1989, p. 7) states: 

Air sampling data for Plants 4 and 8 were reviewed and some samples were in 

excess of the MPC, particularly those taken during spills. However, none were 

observed to exceed the MPC by a factor of ten. 

Prior to February 1989, no isotopic analysis for plutonium, neptunium, or 

thorium isotopes had been performed for smears or air sampling filters. 
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In a summary discussion of these data, Bassett et al. (1989) indicate that the actual air 

concentrations of Pu and Np in these samples were low when expressed as a fraction of the 

derived air concentrations (DAC): 

In air samples, alpha activity associated with plutonium isotopes ranged from 

0.1% to 1% of its class Y DAC. Neptunium-237 concentrations ranged from less 

than 0.03% to 0.1% of its class Y DAC. ...uranium was the largest contributor to 

total alpha activity and had the highest fraction of the sample's DAC. Hence, air 

sampling indicates that uranium was controlling from a health and safety 

viewpoint. (Bassett et al. 1989, p. 4-5)

Finding #8: The 1989 air sampling data for Plants 4 and 8 do not support the NIOSH default 

levels as bounding. Potentially significant worker doses could have resulted from off-normal 

events. 

The statements in Bassett et al. 1989 indicate that the limited set of 24-hour air collections do 

not reflect incidents with high exposure potential such as the spills, hydrofluorination bank 

failures in Plant 4 or furnace temperature excursions in Plant 8, as identified in DOE 2000b 

(Table D.1-15). While measured air concentrations were low, the mass fractions of Pu and Np 

were high, exceeding the defaults in several instances. During high dust loading events, these 

levels could result in significant exposures to workers. 

5.4 PUREX UNH DATA FROM HANFORD 

Because of near total absence of RU data collected prior to the mid-1980s at Fernald and other 

DOE sites, SC&A analyzed samples taken from uranyl hexahydrate feed material for the 

Hanford uranium trioxide conversion facility (224 U) from April 1970 to February 1972 (Ward 

1968). UNH solution was sent to be denitrated using calciners at the 224 U plant, which 

produced UO3 powder. UO3 was then packaged and shipped to receiving sites such as Paducah 

and Fernald. While several steps removed from what Fernald workers would have experienced, 

the data provide distributions of actual measurements that show that the working specification of 

10 ppb was exceeded on a regular basis. Note also that these data are more extensive than the 

small number of samples analyzed at Fernald in the 1980s. Those data call into question how 

many “hot batches” were processed and whether Hanford and/or Fernald personnel were aware 

of them. 

The data sheets in Ward (1968) report Pu in ppb U and Np-237 in counts per minute per gallon 

of solution (cpm/gal). Because uranium content is also reported in pounds per gallon (lb U/gal), 

it is possible to estimate Np-237 content on a uranium mass basis, given the detector efficiency 

(dpm/cpm). SC&A was able to match 12 Np count samples with batch analytical results in 

grams Np/gal (average of from 2 to 6 batches). Five of the counts were above the minimum 

detectable level (MDL) and 4 yielded reasonable efficiency estimates 0.21 to 0.65, Avg = 0.36). 

However, we are not comfortable with that estimate, given the huge uncertainties in matching 

individual count data to batch average results. Given these concerns, SC&A assumed a detector 

efficiency of unity, which results in lower-bound estimates of Np content. 
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Based on 329 samples of UNH solution at Hanford, it was determined that plutonium 

concentrations ranged from 0.11 ppb to 1550 ppb, with a mean value of 15 ppb and an SD of 

98 ppb. Of these samples, about 15% (49) were in excess of the Hanford limit of 10 ppb, 7% 

(24) were greater than 20 ppb and 2% (7) were greater than 100 ppb. 

Figure 1 is a normal score plot for the plutonium data. Figure 1 indicates that the data seem to fit 

a log-normal fairly well up to the 95th percentile (about 2 z-scores). The 7 high values in the 

upper tail (> 100 ppb) are limited to just six batches (batches 3-1 to 3-4 on April 9 and 10, 1971; 

batches 2-20 and 2-21 on December 2 to 3, 1971; and batch 2-65 on January 6, 1972. The 

relatively frequent occurrence of plutonium out of specification (greater than 10 ppb) raises the 

question of how often highly contaminated batches were processed and/or shipped and whether 

Fernald personnel were aware of them. 

Figure 1. Normal Score Plot of Plutonium in Batches of Uranyl Nitrate Hexahydrate 

from Hanford (1970–1972) 

The Np-237 dataset contained 336 results, 84 of which were below the limit of detection (LOD) 

of 20,000 cpm/gal. Figure 2 is a normal score plot for the Np-237 data > LOD. 
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Figure 2. Normal Score Plot of Np-237 in Batches of Uranyl Nitrate Hexahydrate from 

Hanford (1970–1972) 

Figure 2 indicates that the data seem to fit a lognormal fairly well within ± 1 z-score, but about 

13% (32/252) are near the LOD and about 10% (38) are much higher than predicted by the 

lognormal. As was true for the Pu data, the highest values came from about 6 batches. Based on 

a hypothetical "lower bound" efficiency of 1, values >LOD range from about 7 to 2,040 ppb U, 

with an arithmetic mean of 53 with a SD of 155. For values within the lognormal range, the GM 

and GSD are 24 and 2.6. Given the high outliers, a GSD of about 5 might be more appropriate. 

Finding #9: The Hanford UNH data from the early 1970s suggest that the working 

specification for Pu was exceeded on a frequent basis, with some batches much higher than 

the NIOSH default. 

While it is recognized that this material could have been down-blended at later steps in 

production, it remains unclear whether batches of UO3 in excess of the NIOSH default were 

shipped to Fernald and if so, whether Fernald personnel were aware of it and took 

precautionary measures. 

5.5 OTHER DATA SOURCES REVIEWED BY SC&A 

There are two other sets of data that were reviewed in the preparation of this document. These 

include analytical data on a shipment to Fernald that was suspected by NFS at West Valley to 

contain elevated levels of neptunium (Noyes and Quigley 1967) and a set of shipping documents 

from West Valley for the period December 30, 1967, through June 3, 1969. 
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NFS had identified approximately 500 grams of missing neptunium and suspected it might be 

contained in five shipments sent to Fernald between December 23, 1966, and February 1, 1967. 

Based on sampling of these five shipments, it was found that only a fraction of the missing 

neptunium was contained in the shipments (~13%). Data on the five shipments are presented in 

Table 9; column 2 lists the Np concentration in parts per million (ppm) uranium. As shown in 

the Table, 4 of the 5 shipments were below the NIOSH assumed ratio of 3,500 ppb/U (though 

shipments 26 and 27 are close), and shipment number 28 was more than double the assumed 

NIOSH ratio. 

Table 9. Analytical Data on Five Shipments from West Valley to Fernald Suspected of 

Containing Elevated Neptunium Levels 

Shipment NO. ppm Np on U-basis Total grams Np in Shipment dpm Np per 100 dpm U 

24 0.624 2.63 0.05 

25 0.77 3.26 0.06 

26 3.14 14.18 0.25 

27 3.37 13.94 0.27 

28 7.69 31.82 0.62 

Data from West Valley that contain values for fission products were all listed as either not 

detected or less than a stated detection limit. Table 10 presents the summary data for the 

plutonium and thorium samples identified. 

Table 10. Summary Statistics for Plutonium and Thorium Contaminant Data in 

Shipments Between West Valley and Fernald 

Pu (ppb) Th (ppm) 

# of Samples 71 54 

Minimum 0.5 5.0 

Maximum 14.2 283.0 

Mean 5.2 41.3 

Median 4.8 17.0 

Std Dev. 3.2 65.6 

There are also a significant number of files with the naming convention “Analysis of NLO Lot 

[identifying #]” that as of this writing are not currently available to SC&A; the issue is currently 

being followed up on with the ORAUT information technology department. These files likely 

contain additional sampling data; however, it is not known at this time whether they contain 

transuranic- and fission product-specific analyses. 
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6.0 REFERENCES 

Alvarez, R., 2010. Plutonium Waste from the U.S. Nuclear Weapons Complex, Institute for 

Policy Studies report, July 7, 2010. 

ANL (Argonne National Laboratory) 1971. Chemical Separations Processes for Plutonium and 

Uranium, ANL-7799, July 1971. 

ARH (Atlantic Richfield Hanford) 1969a. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, June 1 thru July 31, 1969, ARH-1378, Atlantic Richfield Hanford Company, 

Richland, Washington. August 4, 1969. 

ARH (Atlantic Richfield Hanford) 1969b. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, August 1 through August 31, 1969, ARH-1370, Atlantic Richfield Hanford Company, 

Richland, Washington. September 2, 1969. 

ARH (Atlantic Richfield Hanford) 1969c. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, June 1 thru July 31, 1969. Atlantic Richfield Hanford Company, Richland, 

Washington. 

ARH (Atlantic Richfield Hanford) 1970a. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, February 1 thru February 28, 1970, ARH-1586, Atlantic Richfield Hanford 

Company, Richland, Washington. March 12, 1970. 

ARH (Atlantic Richfield Hanford) 1970b. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, April 1 thru May 2, 1970, ARH-1586, Atlantic Richfield Hanford Company, 

Richland, Washington. June 15, 1970. 

ARH (Atlantic Richfield Hanford) 1972a. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, March 15 thru April 10, 1972, ARH-2511, Atlantic Richfield Hanford Company, 

Richland, Washington. 

ARH (Atlantic Richfield Hanford) 1972b. Neptunium Analytical Data for C-1 Tank UNH 

Transfers, January 10 thru February 12, 1972, ARH-2387, Atlantic Richfield Hanford 

Company, Richland, Washington. February 18, 1972. 

Bassett, A.C., W.A. Goldsmith, J.M. Googin, J.G. Crawford, and K.F. Eckerman, 1989. Health and 

Safety Provisions for Recycle Uranium Processing at the FMPC, Fernald Environmental 

Management Project, Fernald, Ohio. March 7, 1989.

Bihl, D., 2003. Technical Basis Document for the Hanford Site – Occupational Internal Dose, 

NIOSH Dose Reconstruction Project. 

Bogar, L.C. 1986. Radiological Controls for Processing Out-Of-Specification Uranium,

Standard Operating Procedure (SOP) 22-C-101. Westinghouse Materials Company of Ohio – 

FMPC, ES&H Division, Plants 4 and 8. NIOSH-OCAS REF ID 33713. April 24, 1986. 
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written consent of the individual to whom the information pertains is strictly prohibited.

DOE (U.S. Department of Energy) 1985. The Report of the Joint Task Force on Uranium 

Recycle Materials Processing, DOE/OR-859, Oak Ridge Operations Office, September 1985. 

DOE (U.S. Department of Energy) 1996. Plutonium, the First Fifty Years; United States 

Plutonium Production, Acquisition, and Utilization from 1944 through 1994, DOE/DP-0137, 

February 6, 1996. 

DOE (U.S. Department of Energy) 1997. Linking Legacies: Connecting the Cold War Nuclear 

Weapons Production Processes to Their Environmental Consequences, DOE/EM-319, January 

1997. 

DOE (U.S. Department of Energy) 2000a. Review of Generation and Flow of Recycled Uranium 

at Hanford, DOE/RL-2000-43, Richland Operations Office, Richland, Washington, June 30,

2000. [SRDB Ref ID: 4971] 

DOE (U.S. Department of Energy) 2000b. Recycled Uranium Project Report, DOE 00-0001, 

Ohio Field Office, May 15, 2000. 

DOE (U.S. Department of Energy) 2000c. Recycled Uranium Mass Balance Report for the Oak 

Ridge Reservation, Oak Ridge Field Office, 2000. 

DOE (U.S. Department of Energy) 2003. Recycled Uranium-United States Production, 

Enrichment, and Utilization, DOE/SOO-0003, May 2003. 

Fernald 1987. History of FMPC Radionuclide Discharges, FMPC-2082, M.W. Boback, T.A., 

Dugan, D.A., Fleming, R.B., Grant, and R.W. Keys, May 1987. 

GE (General Electric Company) 1951. Hanford Works Monthly Report for July 1951, Atomic 

Energy Commission (HW-21802), August 24, 1951. 

Gerber, M. 1993. A Brief History of the PUREX and UO3 Facilities, WHC-MR-0437, 

Westinghouse Hanford Corporation. November 1993. 

ICRP (International Commission on Radiological Protection) 1994. Dose Coefficients for 

Intakes of Radionuclides by Workers. ICRP Publication 68. Ann. ICRP 24 (4), Pergamon Press, 

Oxford, England. 

Hinnefeld, S.L. 1988. “POOS History and Risk Assessment,” WMCO:OSH(ODI):88-359, 

Westinghouse Materials Company of Ohio. September 19, 1988. 

Leist, N.R. 1980. Minutes of Close-Out Meeting Health Physics – Industrial Hygiene Appraisal. 

National Lead Company of Ohio, October 10, 1980. SRDB Ref ID: 4193. 

NIOSH 2008. Dose Reconstruction Considerations for RU Contaminants at Fernald, White 

Paper, Bryce L Rich and Paul E. Ruhter, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. March 2008. 
Effective Date: 

February 4, 2011 

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NOTICE: This information is protected by Privacy Act 5 U.S.C. § 552a; disclosure to any third party without the 

written consent of the individual to whom the information pertains is strictly prohibited.

NIOSH 2010. Response to SC&A Findings related to the White Paper on Recycled Uranium at 

Fernald, National Institute for Occupation Safety and Health, Cincinnati, Ohio. October 2010. 

NLCO (National Lead Company of Ohio) 1975. Environmental Assessment of the Processing of 

Reactor Recycle Materials Containing Transuranium Elements, NLCO-1130, November 11, 

1975. 

NLCO (National Lead Company of Ohio) 1984. Feed Materials Production Center 

Environmental Monitoring Annual Report for 1983, NLCO-2018, DOE Contract No. AC05-

76OR01156. August 1, 1984. 

NLO (National Lead of Ohio, Inc.) 1985. Letter with attachments to J.A. Reafsnyder (DOE) 

from J.A. Spencely (NLO) entitled, Joint Task Force on Recycle Material Processing. April 29, 

1985. 

Noyes, J.H. and J.A. Quigley, 1967. “Investigation of Neptunium in UNH from NFS, INC.” 

NIOSH-OCAS Ref ID 43969. March 7, 1967. 

ORAUT 2004a. Technical Basis Document for the Fernald Environmental Management Project 

– Site Description, ORAUT-TKBS-0017-2, Vol. 2, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. May 20, 2004. 

ORAUT 2004b. Technical Basis Document for the Fernald Environmental Management Project 

– Occupational Internal Dose, ORAUT-TKBS-0017-5, Vol. 5, Oak Ridge Associated

Universities Team, Cincinnati, Ohio. May 28, 2004. 

ORAUT 2005. Weldon Spring Plant - Occupational Internal Dose, ORAUT-TKBS-0028-5, 

Vol. 5, Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 25, 2005. 

Rogers, R.M. 1989. Radiological Air Sampling Program and Air Sampling Philosophy. Feed 

Materials Production Center – Radiological Safety Section. February 10, 1989. SRDB Ref ID: 

4152. 

SC&A 2006. Review of the NIOSH Site Profile for the Fernald Environmental Management 

Project (Feed Materials Production Center), SCA-TR-TASK1-0010. SC&A, Inc., Vienna, 

Virginia. November 2006.

SC&A 2009. SC&A’s Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald: Commentary on the NIOSH White Paper, SC&A, Inc., 

Vienna, Virginia. March, 2009. 

Sederburg, J.P., and J.S. Reddick, 1994. TBP [Tri-butyl phosphate] and Diluent Mass Balances 

in the PUREX Plant at Hanford 1955-1991, WHC-MR-0483, UC-6000, Westinghouse Hanford 

Company, Richland, Washington. December 1994. 
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USTC (United States Testing Company, Inc.) 1989. Radiochemical Analysis Report, March 2, 

1989. 

Wald, M.L. 2010. Analysis Triples U.S. Plutonium Waste Figures, New York Times, July 10, 

2010. 

Ward, G.N., 1968. UNH Production and Analytical Data, ARH-Vol.1, Atlantic Richfield 

Hanford Company, Richland, Washington. October 21, 1968 (sampling data in the document 

covers the time-period October 1968 through March 29, 1972). 
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ATTACHMENT 1: EXPANDED ANALYSIS OF LOGNORMAL VERSUS 

BOOTSTRAP MEANS IN FERNALD RECYCLED URANIUM DATA 

As shown in Figures A1-1 through A1-3, the bootstrap mean is close to the normal mean and the 

lognormal mean for most sub-groups in the DOE table. The exceptions for plutonium are subgroups 1A, 8, 9 and 10A. In each case, the lognormal mean exceeds the bootstrap mean by more 

than 100%. The geometric standard deviations (GSDs) for sub-groups 1A, 8, 9, and 10A are 14, 

7.7, 15.9 and 10.7, respectively. 

The exceptions for neptunium are sub-groups 1A, 4, and 11. In sub-group 4, the normal mean 

exceeds the bootstrap mean by more than 200%. In sub-groups 1A and 11, the lognormal mean 

exceeds the bootstrap mean by more than 60%. The GSDs for sub-groups 1A, 4, and 11 are 9.7, 

4.2 and 10.4, respectively. 

The exceptions for technetium are sub-groups 5 and 8. In sub-group 5, the lognormal mean 

exceeds the bootstrap mean by more than 300%. In sub-group 8, the lognormal mean exceeds 

the bootstrap mean by more than 70%. The GSDs for sub-groups 5 and 8 are 20 and 5, 

respectively. 

With GSDs this large, only the lognormal distribution is appropriate as a claimant-favorable 

model for the exceptional cases. Yet, in every one of nine listed exceptions, DOE chose to use 

the bootstrap mean estimate instead of the higher estimate, which would be more claimant 

favorable. One can only presume that there was a large incentive for DOE personnel to keep 

these estimates as low as possible. 

We note that the DOE did not provide bootstrap estimates of the standard deviation (SD). They 

provide estimates of the SD of the data, and the SD of the logarithms of the data. The latter was 

used to estimate the GSD. 

In the case of technetium for sub-groups 2 and 7B, the lognormal mean is markedly lower than 

the bootstrap mean. In sub-group 2, DOE chose to use the normal mean, which is higher than 

both the lognormal and bootstrap means. In sub-group 7B, DOE chose the bootstrap mean. 
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0

1

2

3

4

5

6

1A 1B 2 3 4 5 6A 6B 6C 6D 6E 6F 7A 7B 8 9 10A10B 11 

Pu Normal Mean/Bootstrap Mean

Pu Lognormal Mean/Bootstrap Mean

Figure A1-1: Ratio of Normal Mean to Bootstrap Mean and Ratio Lognormal Mean to 

Bootstrap Mean for Plutonium 

0

1

2

3

4

1A 1B 2 3 4 5 6A 6B 6C 6D 6E 6F 7A 7B 8 9 10A10B 11 

Np Normal Mean/Bootstrap Mean

Np Lognormal Mean/Bootstrap Mean

Figure A1-2: Ratio of Normal Mean to Bootstrap Mean and Ratio Lognormal Mean to 

Bootstrap Mean for Neptunium 
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0

1

2

3

4

5

1A 1B 2 3 4 5 6A 6B 6C 6D 6E 6F 7A 7B 8 9 10A10B 11 

Tc Normal Mean/Bootstrap Mean

Tc Lognormal Mean/Bootstrap Mean

Figure A1-3: Ratio of Normal Mean to Bootstrap Mean and Ratio Lognormal Mean to 

Bootstrap Mean for Technetium 

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ATTACHMENT 2: ADDITIONAL INFORMATION CONCERNING DUST COLLECT

TAKEN IN 1985 AND PRESENTED IN APPENDIX B OF NIOSH WHITE PA

Dust 

Collector BLDG Location Pu239 ppb Np237 ppb Tc-99 ppb 

Activity 

Median 

Aerodynamic 

Diameter 

(Microns) 

STDEV 

of 

Particle 

Size 

% 

U235 

Qualitative 

Potential for 

Airborne 

Dust 

G2-64 1 Titan Mill 3548.39 173913 3294.1 8.2 2.6 0.71 High 

G2-1 1 UO3 Pkg St 1.61 73.9 64.7 16.8 2.3 0.95 Medium Assum

Fillin

G2-76 1 Titan Mill Pkg 98.39 1144.9 464.7 24 2.2 0.84 High Label

G2-172 1 Sample Area 25.81 478.3 29411.8 18 2.2 0.67 Low G2-235 1 Not Specified 2.90 110.1 3176.5 12.6 3.9 3.43 Unidentified 

G4-1 1 UO3 Dumping 4.84 318.8 3411.8 13 2.8 0.83 High AssumG4-2 4 No. 2 Pkg 0.87 144.9 48235.3 22.5 2.8 0.84 High All pa

are la

G4-4 4 No. 1 Pkg 3.06 92.8 30588.2 11 4.4 0.51 High All pa

are la

G4-5 4 Hoffman Backup 1.77 202.9 5705.9 11.5 2.2 0.8 Unidentified G4-7 4 H2 Off gas 10.16 217.4 6470.6 16 4.7 1.11 Unidentified 

G4-12 4 No. 3 Pkg 0.21 5.1 123.5 7.8 2.4 1.78 High All pa

are la

G4-13 4 Bank 8 Pkg 0.77 246.4 5470.6 7.9 3.3 0.9 High All pa

are la

G4-14 4 No. 1 Pkg 0.02 10.1 2.7 14.7 1.8 0.2 High All pa

are la

G4-15 4 Bank 7 Pkg 7.42 127.5 3117.6 6.1 1.7 0.84 High All pa

are la

G2-67 5 Plant 1? 83.87 2173.9 2000.0 28.4 1.4 0.81 Unidentified 

G5-247 5A West Jolters 50.00 2029.0 1058.8 29 1.5 0.78 High Assum

Colle

G5-248 5A East Jolters 6.45 362.3 135.3 19.8 1.4 0.21 High Assum

Colle

G5-249 5A No. 4 "F" 0.24 21.7 26.5 13.5 1.4 0.22 Unidentified 

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Dust 

Collector BLDG Location Pu239 ppb Np237 ppb Tc-99 ppb 

Activity 

Median 

Aerodynamic 

Diameter 

(Microns) 

STDEV 

of 

Particle 

Size 

% 

U235 

Qualitative 

Potential for 

Airborne 

Dust 

G5-250 5A No. 5 "F" 0.15 26.1 10.0 14 2 0.2 Unidentified G5-251 5A No. 1 "F" 14.52 869.6 511.8 9.4 1.1 0.43 Unidentified G5-253 5A No. 3 "F" 9.19 318.8 76.5 44 - 0.39 Unidentified G5-254 5B West Breakout 10.48 478.3 176.5 19.5 3.7 0.28 High G5-256 5A East Breakout 20.97 768.1 288.2 23 1.4 0.27 High G5-260 5B East Remelt 0.48 21.7 16.5 12.3 4.4 0.2 High AssumG5-261 5B East Burnout 0.53 21.7 16.5 2.5 1.8 0.21 High AssumG5-262 5B Graphite Mach. Shop 16.13 5652.2 20.0 44 - 0.25 Low Could 

Statio

G5A-100 5B West Sep. Booth 2.74 478.3 1000.0 18.8 4.1 0.31 High AssumG5A-101 5A East Breakout 5.16 347.8 76.5 18.5 1.2 0.22 High 

Bldg 55 - Not Specified 2.90 362.3 282.4 28.8 1.2 0.21 Unidentified 

G43-27 8 Kiln & Calciner 75.81 927.5 2117.6 9.8 2.8 0.93 High - Medium 

Both Calciwhile mediu

G43-29 8 Rotex 10.32 521.7 1882.4 6.7 2.2 0.91 High Assum

8035 8 Oxy 1 Furnace 2.58 97.1 764.7 7.9 2.5 0.42 High 

Oxidawere the 'BFurnaHigh 

G9N1-

1039 9 Not Specified 27.42 652.2 4000.0 12 4.1 0.93 Unidentified 

G-1 P.P. React 6/4 Packaging 0.04 7.0 5.6 10 1.9 0.78 Unidentified 

Reactconsiwhethsamp

G-2 P.P. React 6/4 Packaging 0.03 14.3 10.0 8.7 1.9 0.74 Unidentified 

Reactconsiwhethsamp
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Dust 

Collector BLDG Location Pu239 ppb Np237 ppb Tc-99 ppb 

Activity 

Median 

Aerodynamic 

Diameter 

(Microns) 

STDEV 

of 

Particle 

Size 

% 

U235 

Qualitative 

Potential for 

Airborne 

Dust 

735-13-

7050 P.P. Not Specified 10.00 260.9 123.5 44 - 0.62 Unidentified 

Average - - 14.51 559.6 4309.8 - - - - - 
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ATTACHMENT 3: NORMAL SCORE PLOTS FOR DUST DATA 

y = 2.467x - 1.455

-8

-6

-4

-2

0

2

4

6

8

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-1: Entire Site (With Titan), Pu-239/240 

y = 2.010x - 1.877

-8

-6

-4

-2

0

2

4

6

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-2: Entire Site (With Titan), Np-237 
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y = 2.557x + 1.949

-6

-4

-2

0

2

4

6

8

10

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-3: Entire Site (With Titan), Tc-99 

y = 3.261x - 1.408

-10

-8

-6

-4

-2

0

2

4

6

8

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-4: Entire Site (With Titan), Sr-90 
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y = 2.209x - 1.651

-8

-6

-4

-2

0

2

4

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-5: Entire Site (Without Titan), Pu-239/240 

y = 1.689x - 2.068

-7

-6

-5

-4

-3

-2

-1

0

1

2

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-6: Entire Site (Without Titan), Np-237 
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y = 2.569x + 1.889

-6

-4

-2

0

2

4

6

8

10

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-7: Entire Site (Without Titan), Tc-99 

y = 3.285x - 1.472

-10

-8

-6

-4

-2

0

2

4

6

8

-3 -2 -1 0 1 2 3

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-8: Entire Site (Without Titan), Sr-90 
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y = 2.623x + 0.408

-4

-3

-2

-1

0

1

2

3

4

5

6

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-9: Building 1 (With Titan), Pu-239/240 

y = 2.576x - 0.604

-5

-4

-3

-2

-1

0

1

2

3

4

5

6

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-10: Building 1 (With Titan), Np-237 
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y = 1.906x + 3.409

0

1

2

3

4

5

6

7

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-11: Building 1 (With Titan), Tc-99 

y = 3.000x - 1.122

-7

-6

-5

-4

-3

-2

-1

0

1

2

3

4

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-12: Building 1 (With Titan), Sr-90 
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y = 1.513x - 0.589

-3

-2.5

-2

-1.5

-1

-0.5

0

0.5

1

1.5

2

2.5

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-13: Building 1 (Without Titan), Pu-239/240 

y = 0.992x - 1.682

-3.5

-3

-2.5

-2

-1.5

-1

-0.5

0

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-14: Building 1 (Without Titan), Np-237 
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y = 2.066x + 3.285

0

1

2

3

4

5

6

7

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-15: Building 1 (Without Titan), Tc-99 

y = 3.143x - 1.513

-7

-6

-5

-4

-3

-2

-1

0

1

2

3

4

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-16: Building 1 (Without Titan), Sr-90 
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y = 1.954x - 2.789

-8

-7

-6

-5

-4

-3

-2

-1

0

1

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-17: Building 4, Pu-239/240 

y = 1.394x - 2.967

-6

-5

-4

-3

-2

-1

0

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-18: Building 4, Np-237 
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y = 3.013x + 3.551

-4

-2

0

2

4

6

8

10

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-19: Building 4, Tc-99 

y = 1.089x - 3.590

-6

-5

-4

-3

-2

-1

0

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-20: Building 4, Sr-90 
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y = 1.908x - 1.263

-6

-5

-4

-3

-2

-1

0

1

2

3

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-21: Building 5, Pu-239/240 

y = 1.800x - 1.586

-6

-5

-4

-3

-2

-1

0

1

2

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-22: Building 5, Np-237 
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y = 1.693x + 0.662

-3

-2

-1

0

1

2

3

4

5

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-23: Building 5, Tc-99 

y = 3.595x + 0.485

-8

-6

-4

-2

0

2

4

6

8

-2 -1 0 1 2

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-24: Building 5, Sr-90 
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y = 1.387x - 0.244

-2.5

-2

-1.5

-1

-0.5

0

0.5

1

1.5

2

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-25: Building 8, Pu-239/240 

y = 0.957x - 1.390

-3

-2.5

-2

-1.5

-1

-0.5

0

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-26: Building 8, Np-237 
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y = 0.455x + 3.205

2

2.2

2.4

2.6

2.8

3

3.2

3.4

3.6

3.8

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-27: Building 8, Tc-99 

y = 0.973x - 2.706

-4

-3.5

-3

-2.5

-2

-1.5

-1

-0.5

0

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-28: Building 8, Sr-90 
Effective Date: 

February 4, 2011 

Revision No. 

0 – Draft 

Document Description: A Second White Paper: 

Recycled Uranium at Fernald 

Page No. 

Page 88 of 89 

NOTICE: This information is protected by Privacy Act 5 U.S.C. § 552a; disclosure to any third party without the 

written consent of the individual to whom the information pertains is strictly prohibited.

y = 2.712x - 4.310

-8

-7

-6

-5

-4

-3

-2

-1

0

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-29: Pilot Plant, Pu-239/240 

y = 1.566x - 3.890

-6

-5

-4

-3

-2

-1

0

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-30: Pilot Plant, Np-237 
Effective Date: 

February 4, 2011 

Revision No. 

0 – Draft 

Document Description: A Second White Paper: 

Recycled Uranium at Fernald 

Page No. 

Page 89 of 89 

is information is protected by Privacy Act 5 U.S.C. § 552a

y = 1.340x - 1.124

-3

-2.5

-2

-1.5

-1

-0.5

0

0.5

1

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-31: Pilot Plant, Tc-99 

y = 2.327x - 4.180

-7

-6

-5

-4

-3

-2

-1

0

-1.5 -1 -0.5 0 0.5 1 1.5

Normal Score

(# of Standard Deviations)

log(uCi/kg U)

Figure A3-32: Pilot Plant, Sr-90 

NOTICE: Th ; disclosure to any third party without the 

written consent of the individual to whom the information pertains is strictly prohibited.