Summary of Changes Made to Pinellas Plant Site Profile in 2011 

This is a working document 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 report has been reviewed to identify and redact any information that is 

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

All of the technical basis documents (TBDs) making up the Pinellas Plant Site Profile 

were revised in 2011. The main reason for revising those TBDs was to resolve issues 

with the Pinellas Plant Site Profile that were documented in SCA-TR-TASK1-0015. 

However, a significant number of additional changes were made to those TBDs to 

incorporate new information about the site and its practices and to address issues that 

were identified by NIOSH and/or ORAUT. The following is a summary of the changes 

that were made to each of the TBDs in the site profile. 

General Changes Affecting All or Several TBDs: 

1) Since these TBDs were originally written, it has been discovered that a number of key 

references that were being used were actually documents on General Electric X-Ray 

Division Site (a.k.a. the GEXM site). The GEXM site was the pilot plant for the 

Pinellas Plant and the two sites had a lot in common as described in the revised Site 

Description TBD. The references to the GEXM documents have been either 

eliminated, replaced with Pinellas Plant document references, or, in a few instances, 

had additional text added to a TBD to justify their use for the Pinellas Plant. 

Introduction TBD: 

1) Issue 1 Resolution: The table titled “Summary of data capture searches for the 

Pinellas Plant” was updated to address Issue 1 in SC&A’s issues matrix. 

Additions/updates were also made to this table to include some more recent data 

capture efforts. 

2) This brief TBD was also completely rewritten to update and correct some of the 

information in it to accurately reflect information in the other recently revised TBDs. 

The summary information being presented for each of the other TBDs in the site 

profile are now in their own subsections, which makes the information for a specific 

TBD easier to find. 

Site Description TBD: 

1) Issue 6 Resolution: Section 2.3.4 titled “Decontamination and Decommissioning Era 

(October 1994–1997)” was added to this TBD to address Issue 6 in SC&A’s issues 

matrix. 
This is a working document 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 report has been reviewed to identify and redact any information that is 

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

 

 

 

 

 

 

2) Secondary Issue 2 Resolution: A significant amount of additional information was 

added to this TBD to better describe the operations involving Ni-63, C-14, depleted 

uranium, and metal tritides to address Secondary Issue 2 in SC&A’s issues matrix. 

The bulk of this information was added to Section 2.4.1 which is titled “Radioactive 

Materials”, but some information was added throughout this TBD. In addition, a 

significant amount of information regarding metal tritides was added to the 

Occupational Internal Dose TBD to address this issue. 

3) A number of other significant changes were made to the Site Description TBD to 

better organize the information being presented, incorporate a significant new amount 

of process and facility information, and eliminate some redundant information. 

Occupational Medical Dose TBD: 

1) Issue 10 Resolution: The Equipment and Techniques Section of this TBD was 

revised to address Issue 10 in SC&A’s issues matrix. The table listing the types of 

medical X-ray equipment that were used (now Table 3-1) was updated based on new 

information that was found. All of the pre-1972 X-ray doses are still based on the 

information in the Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Medical X-Ray Procedures (OTIB-0006). However, a 

number of the PFG X-ray dose values were changed due to a revision of OTIB-0006. 

Because the types of medical X-ray equipment that were used for the periods of 

1972–1987 and 1988–1997 are now different, the X-ray dose values for those periods 

have been revised. 

2) Issues 9 and 11 Resolutions: The Examination Frequencies Section of this TBD was 

revised to address Issues 9 and 11 in SC&A’s issues matrix. This section now 

indicates that the lumbar spine and abdomen/KUB (kidneys, ureters, bladder) X-rays 

are considered to be occupational screening X-rays when they were performed in 

conjunction with a chest X-ray. The section also contains a stipulation to not assess 

the X-ray doses for any X-rays when the energy employee’s records clearly indicate 

that the X-rays were performed for individual diagnostic reasons or for work-related 

injuries. In addition, the section now indicates to assign occupational medical doses 

based on the X-ray records when provided, which they typically are, and to assign the 

occupational medical doses based on the recommendations in OTIB-0006 when no 

records are provided. 

3) Secondary Issue 1 Resolution: The Uncertainty Section of this TBD was revised to 

address Secondary Issue 1 in SC&A’s issues matrix. A list of the various uncertainty 

values for each source of uncertainty is now provided in this section, along with the 
 

 

 

 

 

total propagated uncertainty that was estimated for the Pinellas Plant X-ray 

procedures. 

4) An error in the applicable period for PFG X-rays was corrected to reflect the 

recommendations in OCAS-PER-004. The applicable period is now 1957–1959 

versus 1957–1960. 

5) Because only anterior-posterior (AP) exposures are performed for abdomen/KUB 

X-rays, the abdomen/KUB X-ray dose values for lateral (LAT) exposures were 

eliminated from the TBD. 

6) Tables containing skin dose values for various skin locations on the body were added 

to Attachment A of this TBD. 

7) A number of other significant changes were made to the Occupational Medical Dose 

TBD to better organize the information being presented, eliminate some information 

that served no purpose, and to make some of the terminology being used throughout 

the TBD consistent with other NIOSH/ORAUT documents. 

Occupational Environmental Dose TBD: 

1) Secondary Issue 3 Resolution: The onsite tritium air monitoring results are now 

provided in 4.3.5 of the TBD and a comparison of the air concentrations based on 

atmospheric dispersion calculations and actual air monitoring results is now provided 

in Section A-6 to address Secondary Issue 3 in SC&A’s issues matrix. 

2) Because the original detailed calculations were no longer available for resolving 

Secondary Issue 3, the dispersion calculations and environmental intake calculations 

were completely redone. As a result of that, Attachment A was completely revised, 

along with the applicable sections in the main body of the TBD. For the years of 

1957–1980, the new environmental intakes were comparable to the previous 

environmental intakes. However, starting in 1981 (i.e., after the height of the main 

stack was reduced) the new environmental intakes were generally higher than the 

previous environmental intakes. 

3) Section 4.4.2 of this TBD now recommends that the more claimant-favorable 

unmonitored external dose assignment from the Occupational External Dose TBD be 

used in lieu of the estimated on-site ambient doses to estimate the doses for 

unmonitored workers at the site. 

4) Bounding potential onsite environmental internal doses were assessed for Section 

4.4.1 of this TBD and were determined to be negligible (i.e., < 0.001 rem) for all 

This is a working document 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 report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
This is a working document 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 report has been reviewed to identify and redact any information that is 

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

 

 

 

 

 

internal organs. As a result, it was determined that the environmental internal doses 

will never need to be included in the IREP input sheet. 

5) Because there is no indication that plutonium was ever released to the environment, 

the environmental air monitoring results for plutonium were removed from this TBD. 

Environmental air monitoring for plutonium was only performed at the Pinellas Plant 

as a precautionary step due to the presence of the encapsulated plutonium sources at 

the site. Because none of the encapsulated plutonium sources ever leaked at the site, 

it is unlikely that plutonium was ever released to the environment. 

6) A number of other significant changes were made to the Occupational Environmental 

Dose TBD to better organize the information being presented, incorporate new 

information, and correct some inaccurate information. 

Occupational Internal Dose TBD: 

1) Issue 2 Resolution: An approach for assessing potential exposures to insoluble forms 

of tritium (e.g. metal tritides, organically bound tritium, etc...) at the Pinellas Plant 

was developed and is now provided in Section 5.7.1.2 to address Issue 2 in SC&A’s 

issues matrix. 

2) Issue 3 Resolution: The MDC and uncertainty information that was previously in 

this TBD has been replaced to address Secondary Issue 3 in SC&A’s issues matrix. 

Section 5.4.1.2 provides instructions and justification for using the MDC information 

in the TBD for the LANL site. The uncertainties associated with the plutonium 

bioassay results are usually reported with those results. Section 5.4.2.2 of this TBD 

shows how those uncertainty values were calculated. 

3) Issue 7 Resolution: Section 5.7.2 was added to this TBD to address unmonitored 

exposures to tritium, and Sections 5.2.4 and 5.2.5 now address potential unmonitored 

exposures to Ni-63 and C-14. 

4) Secondary Issue 5 Resolution: The Pinellas Plant’s basis for rejecting “positive” 

plutonium bioassay results has been replaced with a new approach for determining 

whether or not a Pinellas Plant plutonium bioassay result is positive. The new 

approach is in Section 5.7.3 of this TBD. 

5) Secondary Issue 6 Resolution: The plutonium solubility statements in question were 

eliminated to address Secondary Issue 6 in SC&A’s issues matrix. By eliminating 

those statements, the Technical Information Bulletin: Internal Dose Reconstruction 

(OTIB-0060) will require the dose reconstructors to use the most claimant-favorable 

lung absorption type when assessing potential plutonium intakes for Pinellas Plant 

workers. 
 

 

 

 

 

 

 

 

6) The table listing the MDCs and reporting levels for tritium urinalysis was revised 

based on new information that was found. In general, the MDCs prior to 1975 were 

increased. 

7) A number of other significant changes were made to the Occupational Internal Dose 

TBD to better organize the information being presented, incorporate new information, 

and correct some inaccurate information. 

Occupational External Dose TBD: 

1) Issue 4 Resolution: Information was added to Section 6.1.5 to address Issue 4 in 

SC&A’s issues matrix. 

2) Issue 5 Resolution: Changes were made to the Dosimetry Technology and Missed 

Dose Sections to address Issue 5 in SC&A’s issues matrix. 

3) Secondary Issue 7 Resolution: An Unmonitored Dose Section and Attachment B 

were added to this TBD to address Secondary Issue 7 in SC&A’s issues matrix. 

Attachment B provides the basis for the unmonitored dose assignment, which 

includes a comparison of the unmonitored dose assignment to the maximum 

likelihood doses for unmonitored workers. 

4) Secondary Issue 8 Resolution: The Missed Dose Section was revised to address 

Secondary Issue 8 in SC&A’s issues matrix. 

5) The approach that was previously used to calculate Pinellas Plant neutron doses was 

replaced with an approach that is consistent with the approaches used for other sites. 

For the neutron generator areas, the new approach will yield higher neutron doses for 

the years of 1957–1969 and lower neutron doses for the years of 1969–1997. 

6) For the RTG areas, the measured photon doses for the years of 1979–1981 are now 

higher because of a new dosimeter correction factor of 1.43 that gets applied for 

signal fading. The missed photon doses for the years of 1979-1987 will be higher 

because of that dosimeter correction factor and a higher LOD value. 

7) The RTG areas now have a more claimant-favorable neutron energy distribution of 

50% 0.1-2 MeV and 50% 2-20 MeV neutrons. In addition, the dosimeter limit of 

detection (LOD) values that were applicable to the RTG area dosimeters were revised 

based on new information. 

8) The external electron doses from an accidental exposure to Kr-85 were increased by a 

factor of 3.5 for the years of 1963–1985. 

This is a working document 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 report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
9) A number of other significant changes were made to the Occupational Internal Dose 

TBD to better organize the information being presented, incorporate new information, 

and correct some inaccurate information. 

This is a working document 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 report has been reviewed to identify and redact any information that is 

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