Effective Date: 4/27/2016 Rev. 0 Page | 1 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

NIOSH RESPONSE: REVIEW OF REMAINING SITE PROFILE ISSUES FOR MOUND LABORATORY 

Issue 

Number

SC&A 

Section

Matrix Issue 

Number

Issue NIOSH/DCAS response

1 5.1 Matrix Issue #5

(PU-240, 241)

A remaining action was identified for this SEC matrix item 

when the Work Group closed it out: for NIOSH to confirm 

a bounding intake for plutonium-241 (Pu-241) for use in 

the dose reconstruction program. (ABRWH 2008a, Work 

Group (WG) transcripts pp. 147–158; ABRWH 2008b, WG 

transcripts, pp. 227–228). During the June 5, 2012, Work 

Group discussion, NIOSH (Jim Neton) agreed that this 

remained an open item for consideration in the thenupcoming Internal Dose TBD revision (ABRWH 2012, 

WG transcripts, p. 194). SC&A was unable to locate 

consideration of this issue within the revised TBD and 

suggests further clarification by NIOSH of its disposition.

NIOSH has updated Table 5-11 of the Mound 

internal TBD to provide bounding mixtures of Pu. 

The WGPu mixture with the highest proportion of 

Pu-241 was identified as the Hanford site mixture 

thus, for the current revision of the internal TBD, the 

Hanford mixture is used to bound Mound Pu intakes.

2 5.2 Matrix Issue #6

(Tritides)

During the Work Group discussion of this SEC issue, 

NIOSH acknowledged that some consideration was needed 

by dose reconstructors of “intermediate solubility class” 

tritium compounds (ABRWH 2009, WG transcripts, pp. 

239–256; NIOSH 2009a). During the June 5, 2012, Work 

Group discussion, NIOSH (Jim Neton) agreed to address 

the inclusion of guidance on intermediate solubility class 

compounds (such as titanium tritide) in a more formal 

response for the Work Group (ABRWH 2012, WG 

transcripts, p. 198). SC&A was unable to locate any formal 

NIOSH response on this issue or any specific treatment 

within the revised TBD or in the supporting document, 

ORAUT-RPRT-0057, Revision 00, A Method for 

Estimating Stable Metal Tritide Exposures to Tritium 

Ancillary Workers Based on Swipe Data in Rooms SW-8, 

SW13, SW-150 and R-108 at the Mound Laboratory 1968 

to 1989 (Jessen et al. 2013). SC&A suggests further 

clarification of NIOSH’s position on this item.

Assuming employment and exposure for all years 

(1969 – 1999), IMBA runs for solubility types F, M, 

and S calculated organ doses in the 1E-5 to 1E-8 rem 

range. This dose is significantly less than 1 millirem. 

The highest doses are for the thoracic lymph nodes 

(LN(TH)) - this was determined by assuming Type S 

intakes and resulted in 0.088 millirem for all 

potential years of exposure (or 0.000003 rem per 

year). NIOSH has determined that this small 

increment of dose does not increase probability of 

causation for even the most affected workers (those 

with respiratory-tract cancers assumed to be exposed 

over the entire 30-year period). Standard procedure 

for dose reconstruction is to use the most claimant 

favorable solubility type – NIOSH has not included a 

repetition of the standard procedure in the TBD.
Effective Date: 4/27/2016 Rev. 0 Page | 2 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

3 5.3 Matrix Issue #9 

(High fired Pu238)

High-fired Pu-238 Concur with recommended closure of this site profile 

item.

4 5.4.1 Matrix Issues 

#11, 12, and 13 

Uncertainties 

and Low 

Recovery for 

Polonium 

Bioassay 

Procedures

Uncertainty and low recovery of polonium: 

Systematic errors occurred in analytical procedures in the 

early years due primarily to ineffective plating techniques 

and low recoveries. Low recoveries were due largely to 

colloidal plating of metabolized 238,239Pu and 210Po 

from raw urine onto sample containers. Polonium-210 

recovery in the early years before sample acidification 

could have resulted in an order of magnitude correction for 

210Po urinalysis results.

Section 5.5.1.1, Bioassay Methods, of the current 

Mound TBD describes this issue in “Chemical 

Recovery Correction” over several paragraphs. The 

TBD directs dose reconstructors to use the claimant 

favorable methods in Section 5.8.1. The correction is 

described in the paragraph below:

Urinalysis data for 210Po collected before 1964 

should be normalized assuming 85% extraction 

efficiency, then corrected for a 10% chemical 

recovery. Polonium-210 data that was reported 

after 1963 should be normalized assuming 85% 

extraction efficiency and then corrected for a 63% 

chemical recovery based on the analysis by 

Fellman et al. (1989). 

The required corrections are summarized in 

Equations 5-4 and 5-5, used by the dose 

reconstructor to reconcile the polonium urinalysis 

data. 

Note that these are the locations in the current 

document, but this dose reconstruction practice has 

been in place since the initial issue of the internal 

TBD for Mound in 2004.

5 5.4.2 Matrix Issues 

#11, 12, and 13 

Other 

Radionuclide 

Data (SC&A 

Data 

Comparison)

Other Radionuclide Data 

This issue was raised originally in SC&A’s white paper, 

Mound Internal Dosimetry Data Completeness (SC&A 

2009a), in Section 3.6. In its May 2012 response (NIOSH 

2012), NIOSH noted that it had “responded in detail to 

these concerns in its November, 2009 report, NIOSH 

Evaluation of Data Adequacy and Completeness Issus at 

NIOSH concurs with the recommendation to 

close this matrix item.
Effective Date: 4/27/2016 Rev. 0 Page | 3 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

the Mound Laboratory (NIOSH 2009b), and again in its 

August 2011 report, NIOSH Evaluation of Data Adequacy 

and Completeness Issues at the Mound Laboratory 

(NIOSH 2011). During the June 5, 2012, Work Group 

meeting (ABRWH 2012, WG transcripts, p. 205), SC&A 

acknowledged NIOSH’s responsiveness to two of the subissues regarding “~95% of data found for selected 

individuals was collected in 1990 and later...Pre-1990 

results included uranium, thorium, and curium” and 

“Majority of pre-1990 results not available in MESH” and 

recommends that the Work Group close these sub-issues. 

For the other issues—recognizing that data comparison is 

rendered difficult due to units and radionuclides not always 

matching and that volume corrections were not possible in 

many cases—SC&A views these as enhancements, for 

clarity sake, that NIOSH can consider for future TBD 

revisions. Overall, SC&A recommends closure of this site 

profile item.

6 5.4.3. Matrix Issues 

#11, 12, and 13 

Secondary/Oth

er Radionuclide 

Data (MJW 

Evaluation)

SC&A agrees with NIOSH’s 2011 conclusion (NIOSH 

2011) that the scale of workers affected is relatively small, 

given the research context of this laboratory work, but 

continues to contend that NIOSH needs to reconcile these 

original MJW quality findings for “other” radionuclides 

with how it is approaching dose reconstruction for them in 

the Occupational Internal Dose TBD. Although the number 

of workers was small relative to tritium and plutonium 

production operations, research was a prime mission of 

Mound and needs to be addressed accordingly in terms of 

the adequacy of bioassay data being used in reconstructing 

doses for those workers. If they are not to be ignored in the 

dose reconstruction program for Mound, how are such 

doses being assigned?

Potential internal doses from these exposures are 

assigned on the basis of records supplied by DOE. 

The Mound internal TBD contains guidance, in 

section 5.9, for assigning doses from thorium (§ 

5.9.2), 231Pa (§ 5.9.3), uranium (§ 5.9.4), for the 

reactor fuels project, based on U, Pu, and Th (§ 

5.9.5), the reactor waste project (§ 5.9.6), americium 

and curium (§ 5.9.7), and from the rare isotopes 

project, based on U and Pu progenitors in the process 

(§ 5.9.8).

We report the bioassay methodology for those 

radionuclides for which we typically find bioassay 

data in claimant records. Dose reconstructors are 

required to reconstruct, or overestimate, doses for all 

internal dose monitoring results, and though the 

guidance in the TBD is intended to cover all likely 
Effective Date: 4/27/2016 Rev. 0 Page | 4 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

situations, it is possible that additional data not 

corresponding to one of the methods in section 5.9 of 

the TBD will be discovered. In this case, the DR 

must reconstruct the dose in the most effective way 

possible outside guidance in the TBD, typically with 

the assistance of the Principal Internal Dosimetrist.

As discussed at length during the working group 

sessions (e.g., transcript, January 6, 2010, starting at 

page 82, line 12), the King document is intended to 

list the potential presence of every possible 

radionuclide in every possible location, rather than to 

suggest, in each location, a presumptive intake.

 

7 5.4.4 Matrix Issues 

#11, 12, and 13 

Tritium 

Logbooks 

Missing for 

1976 and 1977

An SEC was added to account for missing tritium logbook 

data.

NIOSH concurs with the recommendation to 

close this matrix item.

8 5.4.5 Matrix Issues 

#11, 12, and 13

Tritium 

Bioassay Data 

Adequacy

Bounding method for STC addresses SC&A’s original 

concern.

NIOSH concurs with the recommendation to 

close this matrix item.

9 5.4.6 Matrix Issues 

#11, 12, and 13

Plutonium Data 

Comparison

Regarding PURECON: As recommended in Section 5.4.6 

above, the Work Group should request that NIOSH provide 

a summary of how it conducted a validation of Mound’s 

internal and external dose databases.

NIOSH did not itself do a validation and verification 

of Mound’s PURECON database. PURECON 

printouts are considered to be reference information 

and treated as one source of information to be used in 

individual dose reconstructions, evaluated along with 

scans of primary records and MESH records from 

employee files. 
Effective Date: 4/27/2016 Rev. 0 Page | 5 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

10 5.4.7 Matrix Issues 

#11, 12, and 13

Polonium Data 

Comparison

Regarding PORECON: As recommended in Section 5.4.6 

above, the Work Group should request that NIOSH provide 

a summary of how it conducted a validation of Mound’s 

internal and external dose databases.

NIOSH did not itself do a validation and verification 

of the Mound PORECON database. PORECON 

printouts are considered to be reference information 

and treated as one source of information to be used in 

individual dose reconstructions, evaluated along with 

scans of primary records and MESH records from 

employee files. 

11 5.4.8 Matrix Issues 

#11, 12, and 13

Fecal Bioassay 

Data

In its 2009 report, Mound Internal Dosimetry Data 

Completeness, SC&A (2009a) found that there are 

relatively few fecal results in the plutonium urinalysis 

bioassay results database (PURECON) (i.e., total of 29 

fecal samples for 12 individuals for the entire Mound 

worker population) and that there is poor overlap of data 

with corresponding logbooks for the same time periods. A 

majority of the data found in the logbooks were not found 

in the individual exposure files. As many of these samples 

were likely collected as a result of an incident or suspected 

plutonium exposure, the data can be critical to bestestimate dose reconstruction. 

When SC&A mentioned this data completeness concern 

during the June 5, 2012, Work Group meeting, NIOSH 

pointed out that it does not intend to make use of the fecal 

sampling records, rendering moot the incompleteness of 

these records (ABRWH 2012, WG transcripts, p. 214). 

SC&A recommends that the Work Group request 

confirmation from NIOSH that Mound fecal data have no 

use in dose reconstruction.

The Mound Internal Dose TBD contains provisions 

to use fecal data. However, as SC&A points out, 

Mound has fecal data only infrequently, and 

urinalysis data are plentiful in most worker records. 

The Mound dose reconstruction approach therefore 

relies primarily upon the urinalysis data. 

The Mound TBD requires dose reconstructors to 

evaluate fecal data using the IMBA program or other 

program resources in section 5.7.2, Fecal Sample 

Data:

Fecal samples were also infrequent during most of 

the history of the Mound site’s internal dose 

monitoring program. When fecal data are present 

in claim records, they should be reconciled with 

urinalysis data in estimating the internal dose. 

Guidance for this is given in ORAUT-OTIB-0060 

(ORAUT 2007a). MDAs for fecal data are listed in 

the table below. For dose reconstruction, 

resolution of fecal samples may be performed 

using the MDAs listed in Table 5-8 below. These 

MDAs were reported as part of a retrospective 
Effective Date: 4/27/2016 Rev. 0 Page | 6 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

project to establish MDAs for Mound bioassay 

procedures conducted in 1995 (Author unknown 

undated).

12 5.4.9 Matrix Issues 

#11, 12, and 13

Tritium (HTO) 

Data 

Comparison

Regarding Tritium (HTO): As for the findings in Sections 

5.4.6 and 5.4.7 above, SC&A recommends that the Work 

Group request that NIOSH provide a summary of how it 

conducted a validation of Mound’s internal and external 

dose databases in this context.

NIOSH has not conducted a validation and 

verification to ensure the MESH database is 

complete with respect to tritium results. 

In fact, the MESH database offers only summary 

data prior to 1981, and zero results listed for each 

year may be spurious. That is, a zero dose is 

documented in MESH, when monitoring may not 

have been performed. For dose reconstruction, in 

general, primary records are used, along with the 

MESH printouts (provided by DOE), for calculating 

tritium doses. While some claims have no primary 

records for tritium urinalysis in the “DOE Response” 

file, logbook pages have been linked as “Personnel 

Exposure” files, for at least some cases. For other 

cases, to which the records are not linked, the dose 

reconstructor is instructed to consult the logbooks,

which are available in Mound electronic files. 

The technical basis addresses this contingency in 

Section 5.8.3, Tritium (second paragraph):

For 1957 onward, the listed and zero doses may be 

used, with equation 5-2, to assign a dose only when 

dose overestimates are appropriate. If they are not 

appropriate, it is necessary for the dose 

reconstructor to review tritium logbooks for the 

employee’s name for the years in question and to 

assign dose from tritium bioassay, or missed dose 

based on these records instead. 
Effective Date: 4/27/2016 Rev. 0 Page | 7 of 7

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. 

Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document 

represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

1. Carbaugh, E.H., D.E. Bihl, and J.A. MacLellan, “Methods and Models of the Hanford Internal Dosimetry Program,” PNNL-MA-860, January 1, 2003. 

13 5.4.10 Matrix Issues 

#11, 12, and 13

Thorium 

Bioassay Data

In its 2009 report, Mound Internal Dosimetry Data 

Adequacy, SC&A (2009c) concluded the following: 

In summary, the limited amount of data and the 

shortcomings associated with data interpretation remains 

for thorium beyond the established SEC period ending on 

February 29, 1959. Although urinalysis data exist for 

thorium prior to 1970, procedures on how these samples 

were analyzed and interpreted are not available. The data 

infers [sic] that at least a portion of the thorium analysis 

was analyzed by the radium extraction and differential 

counting method to measure the radium daughter of the 

thorium. If this is the case, then, as noted by MJW, there 

are a lot of questionable assumptions that need to be made 

is using an excreted daughter to estimate the intake of a 

parent...the lack of bioassay procedure information can 

make the derivation of the MDA or MDC, which forms the 

basis for NIOSH’s proposed method of assigning missed 

doses, difficult. 

An additional concern is the potential for Class YY 

insoluble thorium being handled at Mound. In 1996–

1997... The Work Group subsequently closed all but the 

question of Class YY solubility, an issue that NIOSH (Jim 

Neton) believed had been addressed in terms of dose 

reconstruction methodology at other DOE sites being 

reviewed; this was to be confirmed and a consistent 

approach for handling highly insoluble thorium applied to 

Mound (ABRWH 2012, WG transcripts, p. 216). SC&A 

recommends that the Work Group confirm that NIOSH has 

addressed this question at other DOE sites and whether 

such an approach has been made available for Mound dose 

reconstructors.

Regarding the “Class YY” concern: SC&A released, 

in September 2012, its SC&A REVIEW OF 

LAWRENCE BERKELY NATIONAL LABORATORY 

SITE PROFILE MATRIX ISSUE #3. This document 

makes the statement that 

SC&A agrees with the NIOSH response that 

solubility Type S, as provided by the Human 

Respiratory Model described in ICRP 66 (ICRP 

1994), adequately bounds the behavior of “highfired” uranium. The same applies to thorium 

compounds.

Though this document applies, strictly speaking, to 

Lawrence Berkeley Laboratory (LBNL), it is clear 

that the conclusion applies generally, rather than 

just to the compounds encountered at LBNL.