SEC-00090

provided 2.6 watts of power to the Trans
initially used in SNAP applications becai
reentry. A change in philosophy resulted
and maintained integrity during reentry.

Reactor fuels research using Pu-239 led

microspheres of unique plutonium comp
These same processes were adapted duri
microspheres for heat sources with essen]

From the early 19606 to the late 1970s,

RTG systems in the SM and PP buildings.

Building 50.

5.2.3. Tritium Production

Following some earlier research with sm
weapon applications began during the mi
recovery processes, and control of tritiuny
system had many applications. The tech
stack effluents. Tritium processing took

$24 Substitute Materials, Radium-2

Po:210 has a half- lite of 138 days, so'the
had to be replaced and returned for reco’

longer half-lives were sought to replace

life of 21 years. A résidue containing ra
1949 for the purpose:of recovering the AI
Ac-227 from material containing the U-2
Ra-226 targets to produce the Ac-227. Ii
operations began at Monsanto in Dayton|
Ac-227 from irradiated Ra-226. The lev
Mound. However, after rapid growth of|
ended by July 1953,-as alpha emitter-ber;
generated from small D-T accelerators.

5.2.5 Thorium-232 Extraction

In the mid-1950s, Mound was directed t
Brazilian monazite sludge and other thor}
target material for irradiation to produce
process pilot plant (the “Monex” proces}
spring of 1955. Construction began on tl
project had barely begun when it was en
1955 and the construction was cancelled
at least 1,650 tons of thorium-bearing mi
Company of Middlesex, New Jersey. M

12-19-07 Mound Plant

t navigation satellite in 1963. Metallic plutonium was
se the devices were designed to disintegrate and burn during
in the use of plutonium ‘dioxide which was less vulnerable

lo the development of chemically and physically stable
nds and alloys using an inductively-coupled plasma torch.
g the mid-1960s for Pu-238 to produce high- integrity

jally no transportable or removable activity.

found continued to produce both heat sources and complete .
Related worki with Pu-238 occurred in the R building and

all quantities of tritium, production of tritium for nuclear
id-1950s. Related activities included tritium enrichment,
-contaminated wastes. The tritium recycling and enrichment
hology was further applied to reduce/recover tritium from
lace in many of the buildings at Mound.

26, Actinium-227 and Thorium-228
shelf-life of fabricated components was limited TI he, items
ery and/or rework. Alternate alpha emitters wi somewhat
0-210. One promising candidate was Ac-227, with a half-
ium, known as K-65 residue, was received on site in October
(C-227 from this material (ORAU, 2003e, p.33). Recovery of
35 series was not as effective as the neutron irradiation of
itial Ra-226 recovery, purification, and production

Similarly, work progressed on extraction and production of
el of effort for this program was considerably expanded at
the program during 1951 and 1952, the program essentially
\lium initiators: were abandoned in favor of neutrons

: 1

perform the R&D necessary to extract thorium from
jum-bearing materials. This thorium refinery was to provide
|U-233 and the thorium breeder reactor. A Th-232 refinery

) was assembled in Room 1B of the SW Building in the

e thorium refinery to the west of the SW building. The

led. The construction directive was issued on March 11,

lon May 9, 1955. However, preparations included receipt of
terial during December 1954 from the National Lead

st was in thé form of Brazilian monazite sludge, which

22 of 95



SEC-00090

12-19-07 Mound Plant

75 Summary | of Feasibility Findings for r Petition SEC-00090

This report evaluates the feasibility for completing dose reconstructions for employees at the Mound

Plant from February'], 1949 through Au
records, process descriptions and source

gust 17, 2007. NIOSH found that the available monitoring
term data available are sufficient to complete dose

reconstructions for the proposed class ofjemployees, with the exceptions listed below.

Table 7-3 summarizes the results of the
source during the time period February

i

easibility findings at the Mount Plant for each exposure
, 1949 through August 17, 2007. -

Februar}

H Table 7-3: Summary of Feasibility Findings for SEC-00090 al

1, 1949 through August 17, 2007

Source of Exposure
i

Reconstruction Feasible Reconstruction Not Feasible

Internal *

Actinium-227__ Wi xX

!
Mar 1, 1959 — Aug 17, 2007) X (Oct 1,1949 — Feb 28, 1959)

Americium-241 +

Curium-244 i

Plutonium-238 !

Plutonium-239 _!

Plutonium-240 © ¥

Polonium-210

Protactiniuim- 241’

Radium-223

Radium-224 i

x
x
x
x
x
x
x
x
x

Radium-226

Radon-220

‘Mar 1, 1959 — Aug 17, 2007) X (Oct 1,1949 — Feb 28, 1959)”
x :

Radon-222

x

Thorium-228

Thorium-230

Mar 1, 1959 — Aug 17, 2007) X (Oct 1,1949 — Feb 28, 1959)”
i

Thorium-232,

Uranium-233 |

Uranium-234 i,

Uranium-235

Uranium-238

> [>< [oe |oe [oe fx

External

- Gamma

- Beta

- Neutron fi

x |e oe

- Occupational Medical x-ray

x

' “Internal” includes an evaluation of urinaly
2 K-65 sludge (the source of Ac-227, Ra-226
these radionuclides are not relevant from the
The related area of work was decontaminated

place from that time forward.
t

is (in vitro), airborne dust, and lung (in vivo) data
and Th-228 concerns) did not arrive-on site until October 1949; therefore,
eginning of the evaluation period (February 1, 1949) until October, 1949.

and decommissioried on February 28, 1959; sufficient monitoring was in

|
As of December 6, 2007, a total of 491 claims have been submitted to NIOSH for individuals who
worked at Mound and are covered by the proposed class definition evaluated in this report. Dose
reconstructions have been completed for 348 of those individuals (71%).

86 of 95



“Special Exposure Cohort Petition 7 U.S, Department of Health and Human Services!

under the Energy Employees Occupat’ona Centers for Disease Control and Prevent‘on
Itness Compensation Act National Institute for Occupational Safety and Health

. ae OMB Number: 0920-0639 Expires: 05/31/2007
Special, Exposure Cohort Petition — Form B Page 4 of 7

__|Mound Laboratory Miamisburg, Ohio

E.2 Locations at the Facility relevant to this petition:
— Buildings HH, PP ( Building 38), R, SM, SW, T, and WOWDA

E.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

included in this class:
—AII scientific, technical, maintenance, production work forces as'well as h—
—administrattve and support staff in these same work areas [—

£.4 Employment Dates relevant to this petition:

Start End
Start Enid __

—.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: O Yes Q No

If yes, provide the date(s) of the incident(s) and. a complete description (attach additional pages
as necessary): :

The definition of incident is prcblematic. There is no intention to claim an exposure
incident comparabie to an uncontrolled fission reaction or criticality incident, only a
claim of inadequately monitored and inadequately protected radiation exposed workers.
This SEC petition is based on the fact that large quantities of several radionuclides
‘|were processed without éngineering controls or protection-as would be expected by
today's standards thus representing a real or rationally expected potential for
significent risk from occupational exposure to radiation. In addition sadiation
monitoring was not uniform, in thet not all workers were routinely monitored. Selection
of workers for monitoring was not necessarily cased on worst case scenarios, in.other
words the exposure data available for subsets of the population may not represent the
highest exposures experienced. This facility wes involved in large part in. extraction of
Polonium 210 for manufacture of stomic weapons Pu-3e neutron initiators but wes also
involved in research and develcrment activities involving a variety of other
radionuclides including: Ra-226, Ac-227, .Th-228. Tn~232, Th-230, Pa-231, and U-233 as
well as extraction and purification of Ra-226, Ac-227, Th-230 and Pa-231.
The SC&A consultation report on the NIOSH Site Profile does not inspire Confidence in
{the claimant's that accurate, defensible dose recons=ructions are possible.

These comments are él? referzble to Lc he unmonitored exposure
situation at this facility represents a day by day reality and not a discrete “incident”
per se.

Name or Social Security Number of First Petitioner:



we REP TY RMR EE RE SE

Page 2 ~ The Secretary

(42 C.F.R. pt. 83, Tab B). Since these procedures were promulgated, Congress has amended
EEOICPA to mandate that HHS report to Congress on both decisions to add and decisions to
deny a designation within 30 days of HHS receiving a recommendation by the Advisory Board
on Radiation and Worker Health (Board) to add the class to the SEC. Failure to report to
Congress within this 30-day deadline would result in the automatic addition of the class to the
SEC.

Under the HHS procedures for designating additional members of the SEC, the National Institute
for Occupational Safety and Health (NIOSH) received an SEC petition representing certain
workers at the Mound Plant near Dayton, Ohio (Tab C). NIOSH evaluated the petition and
presented the findings (Tab D) at the Board meeting in Las Vegas, Nevada, on January 8, 2008.
The NIOSH evaluation recommended adding the following proposed class to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and DOE
contractors or subcontractors who worked in any areas at the Mound Plant site from
October 1, 1949, through February 28, 1959, for a number of work days aggregating at
least 250 work days or in combination with work days within the parameters established
for one or more other classes of employees in the Special Exposure Cohort.

The Mound site conducted diverse activities in research and chemical engineering. The
radionuclides radium-226, actinium-227, and thorium-228 were used in research on the
production of Ac-227 for use as a substitute for polonium in neutron initiators. Decontamination
and decommissioning of the building where the work was done was completed in February 1959.
NIOSH has access to a limited number of bioassay results for these radionuclides; however,
interpretation of the results is uncertain. NIOSH cannot bound the internal dose for these
radionuclides from October 1, 1949, through February 28, 1959, and does not know which
workers were exposed. During that time period, NIOSH has determined that internal doses for
the proposed class cannot be determined with sufficient accuracy for the following reasons:

1. NIOSH has access to a limited number of bioassay results for these radionuclides;
however, interpretation of the results is uncertain.

2. While it is likely that the bioassay results possessed by NIOSH relate to the workers
directly involved in the separation operation, it is not known what fraction of those
workers was sampled for the bioassays.

3. There is strong evidence that airborne contamination was produced by the separation
process. The limited number of individuals for whom radium-226, actinium-227, and
thorium-228 bioassay results are available suggests that the larger population was
unmonitored for potential intakes.

4. The reported airborne contamination concentrations are relatively high in some cases,
suggesting the potential for non-trivial intakes and consequent internal doses.

Extemnal dose monitoring was part of the personnel protective practice from the early days at
Mound, starting with the first operational process, polonium neutron source preparation. External


SEC-00090

12-19-07 Mound Plant

unmonitored worker,who had the potenti
unmonitored dose based on co-worker d
for the proposed class.

i
14.2.3 Plutonium through Ventilation

\
al for radiation exposure, NIOSH could estimate
ta. This does not prevent NIOSH from bounding the dose

[Ducts

h

t
SEC-00090: [Employee name removed],
result of an accident,where a failure to p
move through ventilation ducts and into
particularly hot area where he worked
No effort was ever made to determine oj
been exposed to ten times the radiation
despite his complaints, management nev
or to determine by other means the actuq

There were certainly incidents througho
of such incidents does not prevent NJOS|
accuracy. Film badge dosimeters in use
insensitive element. } Occupational-range
insensitive element had a much higher-r
Mound would fully éxpose the insensiti
measure neutron doses by accumulating
- the extent that the: damage tracks are’ diff
estimated by the health: ‘physics program
dose may be estimated by a proportional

14.2.4 Reports |
4.
SEC- 00090: As a quality engineer and a
reports relating to people being expose
failures. Through I do not have any spe
Department of Energy and, in theory, co}
constant occurrence!

i
Although ho specifies were given in this|
of Mound. It has beén demofistrated thaj
Doses from internally- deposited radiony}
are measured using fi film badges or TLDs.
SEC implications. Ih the case of an unm
NIOSH could estimate unmonitored dos:
the proposed class. i

now deceased, told me that he had a full body burden as a
roperly control radiological material allowed plutonium to

is office, contaminating him. He also told me of one
here the dosiméter badges were always completely exposed.
[sic] the badges were just barely fully exposed or if they had
lecessary to fully expose the film. He went on to relate that

r made any effort to adjust the dosimeter reading schedule

1] exposure.

i f

it the operational history of Mound. However, the occurrence
HH from conducting dose reconstructions of sufficient
at the Mound site contained both a sensitive and an
measurements were made on the sensitive element; and the
sponse range. It is unlikely that any occupational exposure at
le element. On the other hand, neutron film emulsions, which
damage tracks, can also be darkened by gamma radiation to
licult:to read. When this occurs, the dose’is very likely:to-be
personnel; for any such occurrence in the.record, the neutron
neutron dose based on the recorded plioton dose.

i

!
member of the Mound audit staff, I constantly handled
to radioactive materials because of system and management
ific details, all these reports were carefully submitted to the
rective actions were taken, but exposure incidents were a

example, incidents did occur throughout the operating history
the doses resulting from such incidents can be estimated.
clides are estimated from bioassay results; and external doses
While this is an important issue, such issues do not have
jonitored worker who had the potential for radiation exposure,
s. This does not prevent NIOSH from bounding the dose for

82 of 95



SEC-00090

12-19-07

Mound Plant

Table 5-5 summarizes the respective neutron energy categories used by EEOICPA in accordance with
the External Dose Reconstruction Implementation Guideline (OCAS-1G-001) applied to Mound site
workplaces by facility and operation. (ORAUT-TKBS-0016-6)

Table 5-5: Neutron Energy by Facility and Operation

Facility Operation Period IREP Energy Percentage
Category (MeV)
PP Building: .
Waste Handling area Th-232 storage and re-drumming 1955-1975 0.1-2.0 75
2.0 - 20 25
R Building:
R117 Storage Vault 1949-1990 0.1-2.0 50
2.0 - 20 50
SW Building:
Ssws Xe isotope separation 1957-1960 0.1-2.0 50
SW 11-14 & 16 (area | Decon of BiSO, 1951-1953 2.0 - 20 50
1B) Pa-231 purification 1956
SW_19 (Old Cave) Radium-actinium separation 1951-1953
SW 140 (New Cave), | Processing residue from 1970-1979
132, 136, 137 pitchblende production
SW 146-147 Metallurgy laboratory 1967-1985
SW 219 Neutron source production 1962-1965
T Building:
All but T 43, 44, 48, Po neutron source program 1949-1973 0.1-2.0 25
50-51, 57-59, 348-359 2.0 = 20 75

31 of 95



SEC-00090

12-19-07 |

Mound Plant

6.1.8 Substitute Materials, Radium-2

As part of the Substitute Materials Progr:
with neutron-generating efficiency comp’
replacement for Po-210 for initiator prodi
neutron-irradiated Ra-226.

Between June and October 1954, almost
resulted in 47.5 Ci of Ra-226, 14.9 Ci of
the year. ‘

Urine analysis techniques were develope:
the SW Building. According to the Hist
work for analyzing urine samples contain
few urine samples were analyzed in 1951
Several cases of personnel exposure werg
these 1952 samples do not appear to be in
urine samples were being analyzed by a s

Differential decay analyses indicated that
thorium were present in the samples; they
respective activities. To accomplish this,
-urine samples and the radium fraction wat
227.via Fr-223 (1%) and Th-227 (99%).
have short half-lives So they grow in relat
activities calculatéd using these curves.
simultaneous equations were then used tq
quantity of Ac-227 and Th-228 could the}

According to the History of Mound Bioas,
having participated in the program. How}
Assessment Project shows approximatel:
analysis. The last routine sample was pro
Area was completed.. A few more sampl¢

6.1.9 Uranium Records

"Several isotopes of uranium have been us

largest uranium program appears to have
during 1958 and 1959. This was most lik

this program began in July 1958 and endg

time period.

From 1962 to 1972, another program pro

(Meyer, 1992). About 10 grams (6.2E-02

was shipped as the oxide. There was no i
work. .

26, sana and Thorium-228 Records

m, a search was undertaken for other alpha-emitting isotopes
arable to Po-210. Ac-227 was selected as a possible
uiction. This program involved the separation of Ac-227 from

48 g of radium had been processed and canned. This work
Ac-227, and 24.6 Ci of Th-228 being purified by the end of

d to support the processing of neutron-irradiated Ra-226 in
ry of Mound Bioassay Programs (Meyer, 1992), preliminary
ing Ra-226, Ac-221, and Th-228 was completed in 1952. A
and 1952 as part of the research work for the program.
detected by routine urinalysis in December 1952. Results of
any logbooks, nor could data sheets be found. At the time,

imple procedure for radium only.

in-addition to the radium, varying amounts of actinium and
efore, a new procedure was developed to determine.their
horium.and radium were chemically separated from the. +
is counted for total activity. Ra-223 is a decay product of Ac-
IRa-224 is a decay product of Th-228. Ra-223 and Ra-224 ,
ively rapidly. Decay and in-growth curves were plotted and
amples were counted periodically for several weeks and
determine the activity. of Ra-226, Ra-223, and Ra-224. The.
h be inferred from the results.

say Programs (Meyer, 1992), sixteen people are listed as
ever, a compilation of data during the Pre-1989 Dose

120 people as having submitted urine samples for radium
cessed in February 1959 when decontamination of the Cave
s were analyzed between 1963 and 1967.

ed at various times throughout the history of Mound. The
involved about ten people in limited research on U-233

ly a part of the reactor fuels program. Urine sampling for

id July 1959. Over 130 bioassay results are available for this

luced U-234 by chemically separating it from aged Pu-238
Ci) were produced annually; the U-234 that was produced
dication of a specific bioassay program associated with this

42 of 95



Special Exposure Cohort Petition U.S. Department of Health and Human Services|
under the Energy Employees Occupational - Centers for Disease Control and Prevention
Iliness Compensation Act National institute for Occupational Sefety and Heath
. ” ‘ OMB Nunibér: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 5 0f7
Basis for Proposing that Records and Information are Inadequate for Individual Dose —-
Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
the oa information related to the selection. You are not required to complete more than one entry.

Fa fe have attached either documents or statements provided by affidavit that Indicate that
lation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area

monttoring.
(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) Indicate that potential radiation exposures were not monitored.

wad Gu au) vetst Cu ul i aunierest .

Pf, We have attached either documents or statements provided by affidavit that indicate that
idiation monitoring records for members af the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been last, altered illegally, or destroyed.

Fag The "GO" Dany Gisd Lance 0) ET Wks ROTA WaAL OntencO SueTuRge gO
AWG hretacty OF Te Ono “Tone Daas eke hs ND Vie

saa

—
Part F is continued on the foltowing page.

_— AFFANIT(S) Armand) Thy [2004

Name or Social Security Number of First Petitioner:

Pelion RENveD 07 hi [20.7



SEC-00090 12-19-07 Mound Plant

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Rev. 00; Oak
Ridge Associated Universities; April 26, 2007; SRDB Ref ID: 31421

ORAUT-PROC-0006, External Dose Reconstruction, Attachment A; Rev. 0, Oak Ridge Associated
Universities; June, 27, 2003; SRDB Ref JD: 20211

ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Rev. 01;
Oak Ridge Associated Universities; June 28, 2006; SRDB Ref ID: 29986

ORAUT-PROC-0061, Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 01; Oak Ridge
Associated Universities; July 21, 2006; SRDB Ref ID: 29987

ORAUT-TKBS-0003, Technical Basis Document for the Savannah River Site, Rev. 01, Oak Ridge
Associated Universities; August 21, 2003; SRDB Ref ID: 20178

ORAUT-TKBS-0016-1, Technical Basis Document for the Mound Site — Introduction, Rev. 00; Oak
Ridge Associated Universities; September 9, 2004; SRDB Ref ID: 19784

ORAUT-TKBS-0016-2, Technical Basis Document for the Mound Site — Site Description, Rev. 00
PC-1; Oak Ridge Associated Universities; July 7, 2006; SRDB Ref ID: 30057

ORAUT-TKBS-0016-3, Technical Basis Document for the Mound Site - Occupational Medical Dose,
Rev. 01 PC-2; Oak Ridge Associated Universities; March 31, 2006; SRDB Ref ID: 30059

ORAUT-TKBS-0016-4, Technical Basis Document for the Mound Site - Occupational Environmental
Dose, Rev. 00; Oak Ridge Associated Universities; October 6, 2004; SRDB Ref ID: 19789

ORAUT-TKBS-0016-5, Technical Basis Document for the Mound Site - Occupational Internal
Dosimetry, Rev. 00; Oak Ridge Associated Universities; September 9, 2004; SRDB Ref ID: 19790

ORAUT-TKBS-0016-6, Technical Basis Document for the Mound Site - Occupational External
Dosimetry, Rev. 00; Oak Ridge Associated Universities; August 11, 2004; SRDB Ref ID: 19791

ORAUT-TRNG-0051, Dose Reconstruction Training, Rev. 03; Oak Ridge Associated Universities;
March 1, 2007; SRDB Ref ID: Not currently in SRDB

Ac-227, 1952, Report for Research on Substitute Materials, October 1, 1951 to December 31, 1951
(Actinium-227), Mound Laboratory; MLM- 650; February 4, 1952; SRDB Ref ID: 24671

Bismuth, 1952, Bismuth Recovery Process, Engineering Research Final Report; Mound Laboratory;
MLM-734, August 5, 1952; SRDB Ref 1D: Not currently in SRDB

BWXT, 2000, Radon Study Summary Report; 2000; Document search underway; SRDB Ref JD: Not
currently in SRDB

Decon, 1951, Decontamination of Process Waste Solutions Containing Fission Products by
Adsorption and Coprecipitation Methods (Information Report), Mound Laboratory; C. S. Lowe, et al.;
MLM-621; November 13, 1951; SRDB Ref ID: 24668

91 of 95



servic,
on * Us

ADVISORY BOARD ON RADIATION AND WORKER HEALTH

4
Ss 4676 Columbia Parkway, MS: C-46
3 Cincinnati, Ohio 45226
° (513) 533-6825

'e,

January 30, 2008

(CHAIRMAN:

Paul L. Ziemer, Ph.D.
Lafayette, Indiana . +
The Honorable Michael O. Leavitt

Secretary of Health and Human Services

MEMBERS: Department of Health and Human Services

Josie Beach 200 Independence Avenue, S.W.

Richiand, Washington Washington, DC 20201

Bradley P. Clawson

Rexburg, Idaho Dear Mr. Secretary:

Michael H. Gibson . wo

Franklin, Ohio The Advisory Board on Radiation and Worker Health (The Board) has
Mark A. Griffon evaluated SEC Petition-00092 concerning workers at the Lawrence

‘Salem, New Hampshire Livermore National Laboratory (LLNL) in Livermore and Tracey,
James E. Lockey, M.D. California under the statutory requirements established by EEOICPA and
Cincinnati, Ohio incorporated into 42 CFR Sec. 83.13 and 83.14. The Board respectfully
James MA, Melius, M.0., Ph.D. recommends Special Exposure Cohort (SEC) status be accorded to all
Albany, New York employees of the Department of Energy (DOE), its predecessor agencies,
Wanda L. Munn and DOE contractors or subcontractors who were monitored for radiation
Richland, Washington exposure while working at the Lawrence Livermore National Laboratory
John W. Poston, Sr., Ph.D. for a number of work days aggregating at least 250 work days from
College Station, Texas January 1, 1950 through December 31, 1973, or in combination with work
Robert W. Presley days within the parameters established for one or more other classes of
Clinton, Tennessee employees in the SEC. The Board notes that although NIOSH found that

they were unable to completely reconstruct radiation doses for these

Genovieve S. Ri Ph.D. .

yea Minnesota pap employees, NIOSH believes that they are able to reconstruct other

Philip Schoftetd components of the internal dose (except for mixed fission and activation
Bosque Farm, New Mexico products) and all external doses.

STAFF: This recommendation is based on the following factors:

EXEC! ECRETARY: e People working at the LLNL facility during this time period

Lewis V. Wade, Ph.D worked on research and production activities related to nuclear
Washington, DC weapons production.

COMMITTEE MANAGEMENT : e The NIOSH review of the available monitoring data as well as the
Zaida Burgos available source term and other information found that they lacked
Atlanta, Georgia adequate information necessary to conduct accurate individual

dose reconstructions for internal doses from exposures to mixed
fission and activation products during the time period in question.


SEC-00090 12-19-07 Mound Plant

Gross alpha analyses were conducted at Mound, and until 1980, activity was assigned to specific
isotopes of plutonium and other alpha emitters based on sequential gross alpha counting or chemical
separation followed by gross alpha counting. Alpha spectrometry capable of identifying specific
alpha-emitting isotopes was not introduced until 1980.

Individual radium bioassay samples were counted three times in a low-background proportional
counter over a period of weeks. The individual radium isotope activities were then estimated by
solving a system of simultaneous equations. This procedure requires equilibrium assumptions to
properly infer activity associated with individual decay chain radionuclides. For example, sequential
gross alpha counting was conducted on bioassay urine samples following radium extraction by co-
precipitation to quantify Ra-223, Ra-224, and Ra-226 activity. Evaluation of alpha activity with
decay time allowed the activities of individual radium isotopes to be estimated.

6.1.1 Tritium Bioassay

Tritium urinalysis for workers started in 1957. In 1958, an analytical method using a vibrating Reed
Electrometer was officially adopted from a Savannah River Plant procedure and continued to be used
into the early 1960s. Liquid scintillation counting began in 1961. Tritium results were always
reported in units of activity per liter of urine.

Available tritium data are contained within the MESH database. Data from 1957 through 1981 (over
30,000 records) are in the form of annual dose summaries for workers. The remaining employee
records (~ 250,000) span from 1981 through January 2006 and include bioassay results.

6.1.2 Polonium-210 Bioassay

All Mound employees working in polonium operations in T, HH, WD, H, B, and R Buildings were
required to submit weekly spot urine samples (Meyer 1992). Samples were usually collected on
Monday and Wednesday, or on Monday, Wednesday, and Friday. Po-210 bioassay data were
documented on several different types of records at Mound (Meyer, 1992; Spitz, 1989). Weekly
reports of urinalysis data were kept for workers; they were grouped by location with entries in cpm
per specified volume and with 24-hr samples identified. Weekly results were transcribed onto
Polonium Cards for individual workers with entries in cpm/50-ml unless otherwise stated. Twenty-
four Hour Reports were also kept and used to convert individual 50-ml spot samples collected on a
single day to a volume-weighted average 24-hr excretion in cpm. Finally, Special and Unscheduled
Sample Forms were kept when any additional urine samples were required to document possible
worker exposures, or to confirm previous results, with all entries in cpm and duplicate sampling
indicated.

Bioassay data for Po-210 have been placed in the PORECON database by MJW by evaluating
individual dosimetry files from original logbooks and data cards during their work on the Pre-1989
Dose Assessment Project (MJW, 2002, Phase I; MJW, 2002, Phase II). This database contains
207,750 individual sample results spanning from 1944 to 1973. Bioassay results are reported as Bq/d,
cpm, and dpm in this database.

37 of 95


| Special Exposure Cohort Petition

under the Energy Employees Occupational
'IlIness Compensation Act

| Special Exposure Cohort Petition — Form B)

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/34/2007
Appendix =~ Continuation Page

The folllowing is rough transcript offa history from | sister of? |
- was hired’ on at Mounds around|the same dayas her sister in 9-25 1956- until 1986, 30
ears. Mary developed CML and died around Christmas| 2006. They all worked in several
buildings. A cousin also worked! there and got breast cancer. said they wore robes, |
special shoes, caps over hair, various s of gloves, rubber, plastic and cotton, occasionally a
ask for mixing MOCA. They always|wore a picture identification badge but did not always
wear radiation badges, Sometimes you|would wear a radiation badge almost all day but usually
lonly short parts of the day. She would have to shower repeatedly. She worked with Beryllium on|
several occasions including various latoratories and in the early years production of parts.
They would travel from building to building as they bid for different jobs.
A bldg was administration, B was biology, C was cafeteria, D was decontamination a hot bldg.
lots of water that they tried to wash the facility with and contaminated the regional aquifer, had
-!to remove tons of dirt. R building was fadioactive and hot. A young man got so exposed to
-jradiation in the T building that he died|in the medical facility. The T building was far
underground. After three years in the T| building, sometime in the 1970's), she had to be taken |
out because of persistent contamination. of her hair. She had to wear rubber gloves at home and
couldn't touch or'sleep with her husband for about two of three weeks until the radiation cleared
from her right arm. The production areps appeared spotless, very little dust. The areas in which
metallurgy was done were the dirtiest areas but these were mostly staffed by men.
[The chemical storage areas were some lof the most dangerous areas.

~Made heads for the triggers or cfonats rs of A bombs, soldered two little silver: spots and took a

‘frrieroscopic gold wire, on the detonators, and test fired these.

)She worked with beryllium off and on but did not personal ly sand, grind or polish such parts,
-She worked quite a bit with an explosive white powder which they would weigh out with
‘|staintess steel spoons. ‘
_jSome supervisors didn't tell workers what they worked with

| Workers had blue books and classified|ted books that told workers what they did

“There were times when —_-y was not Wearing a badge but her supervisor was

‘JAlso the men didn't seem to be as careful as the women were, they were braver.

|

as

Name or Social Security Number of First Petitioner: | L
. —



SEC-00090

12-19-07 Mound Plant

NIOSH has established that unmonitored

intakes of radi¢nuclides associated with radium-thorium-

actinium processing,,and purification research and production, may have resulted in unmonitored

doses to research and process workers, ai
reason, a class of workers is being propo}
site operations, NIOSH has access to suff
radiation dose for every type of cancer fo
incurred under plausible circumstances b}
doses to member of the class more precis

7.3

The principal source of external radiation
Po production operations, which moved
narrowly-focused Po‘production work e:
components. Production of Pu-238 and F
mission was the.research, development, d
nuclear weapons that were assembled at
fabrication of neutron and alpha sources
Mound developed radioisotope thermoel
of missions to provide heat and power fo
was phased out in 1971 (ORAUT- TKBS

External dose monitoring formed a part
starting with the first ‘operational process.
monitoring continued throughout Mound
Dayton Laboratory (Units II]‘and 1V) wei
monitoring forms a part of most early do:

results reflect measurements with neutron

contrast with measurements at other sites
neutron doses in the spectrum generated
thermoluminescent dosimeters (TLDs).

Photon dose monitoring was conducted ff
dosimeters and, later; TLDs. Film and T!

photons in Mound work areas. Shallow d

detected on a portion of this dosimeter as

id workers incidentally exposed in these facilities. For this
ed for addition to the SEC. For the other periods of Mound

ficient information to either estimate the maximum internal

r which radiation dose are reconstructed that could have
any member of the class; or estimate the internal radiation
ely than a maximum dose estimate.

External Radiation Doses at Mound

doses for members of the proposed class is associated with
rom the Dayton Project to the Mound Site in 1949. The
panded to the development and production of weapons
'u-239 grew from the early Po work. The principal Mound
id manufacture| of non-nuclear explosive components for
ther sites. Research and development included the

for weapons and non-weapons use. Starting in the 1950s,
tric generators (RTGs) which have been used on a'variety
spacecraft. Po-210:production declined in the 1960s and
0016-2).

if personnel protective practice from the-early days at Mound,
polonium neutron source preparation. External dose |

s operational history. It is known that employees at the

‘€ unmonitored for neutron dose; however, neutron dose
monitoring records in Mound employee files. These
-track emulsion (NTA, for neutron track, type A) which, in
during that era, likely provided a proportional estimate of

y Po-Be sources. Later measurements were made with

om the onset of Mound operations using standard film
LD dosimeters provided reliable measurements of the
loses, from beta-emitters and low-energy gammas, were
well.

66 of 95



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2 of 95



SEC-00090 12-19-07 Mound Plant

WDA Building, or the WDA alpha wastewater treatment facility, was built in 1966 as an annex to
WD Building for the treatment of plutonium wastewater from the PP and SM Buildings. It was
designed as both a high-risk drumming station and a low-risk wastewater treatment facility.

Special Metallurgical Building, or the SM Building, was built in 1960 and became operational in
1961. It was designed to receive liquid plutonium nitrate mixture from the Savannah River Plant
that was used in a variety of programs, mainly heat source projects. In addition, SM building
housed recovery processing, waste treatment facilities, R&D, and analytical support activities.
(ORAUT-TKBS-0016-2) This building also included the Plutonium Processing (PP) area change
room, laboratories, maintenance shops, and building services. This building underwent
decontamination and decommissioning starting in 1977. (Ten-Year Plan, 1977)

Contamination Areas

Area 8, Thorium Contaminated Soils from Areas | and 9: This area is located northwest of
Building 31, on the SM/PP hill on the eastern side of the Mound site. The area is approximately
25,000 sq ft. Soil was buried in this area from decontamination activities from repackaging of
Th-232 sludges in 1965 and 1966. Pu-238 and thorium have been detected in this area.

Area 10, Debris from Dayton Units: This area is located west of Building 30, on the slope of the
SM/PP hill on the East Central portion of the Mound site. It was used for disposal of contaminated
concrete from the Dayton Units. One-hundred-sixty truckloads from Unit IV and 100 truckloads
from Unit III were deposited here. The area is approximately 15,000 sq ft. The primary
contaminant was Po-210. Soil was buried in this area in 1950.

Area 12, Thorium Contaminated Soil: This area is located west of Building 38, on the SM/PP hill
on the East Central portion of the Mound site. Th-232- and Pu-238-contaminated soil from SM
building and thorium-contaminated soil from Area | were placed in this area in 1965.

WTS Pipline: This pipeline line ran from SM building and Building 38 to the WD building. In
1969, the high-risk waste line ruptured below the WD building and resulted in Pu-238
contamination of an off-site portion of the abandoned Miami-Erie Canal bed. In 1991,
approximately 600 linear feet of contaminated pipe was unearthed and shipped off-site for burial.
The pipe had been the waste line that connected HH Building with the WD facility. (Mound,
1999).

27 of 95



Special Exposure Cohort Petition Us. Department of Health and Human Services
under (he Energy Employees Ocoupational Centers for Disease Control and Pravention
Hines Compensation Act Naflonal Institute for Occupational Safety and Health
OMB Number: 0920-0838 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B . Appendix — Continuation Pay

ge OLE) p

| “[The fotllowing is rough transcript of a history from '
was hired on at Mounds around the same dayas her sister in 9-25 1956- until 1986, 30
years... ., developed CML and died around Christmas, 2006. They all w-rked in several
5 buildings. A cousin also worked there and got breast cance’, vaid they wore robes, §
{special shoes, caps over hair, various types of gloves, rubber, plastic and cotton, occasionally a |
mask for mixing MOCA. They atways wore a picture identification badge but did not always
wear radiation badges, Sometimes you would wear a radiation badge almost all day but usually
4 jonly short parts of the day. She would have to shower repeatedly. She worked with Beryllium on;
“several occasions including various laboratories and in the early years production of parts. i
“|They would travel from building to building as they bid for different jobs. j
“IA bldg was administration, B was biology, C was cafeteria, D was decontamination a hot bldg.
-jlots of water that they tried to wash the facility with and contaminated the regional aquifer, had
-lto remove tons of dirt. R building was radioactive and hot. A young man got so exposed to i
radiation in the T building that he died in the medical facility. The T building was far :
Junderground. After three years in the T building, sometime in the 1970's), she had to be taken ¢
i lout because of persistent contamination of her hair, She had to wear rubber gloves at home and i.
couldn't touch or sleep with .... husband for about two or three weeks until the radiation cleared
from her right arm. The production areas appeared spotless, very little dust. The areas in which |
metallurgy was done were the dirtiest ateas but these were mostly staffed by men.
| |The chemical storage areas were some of the most dangerous areas,
i ~Made heads for the triggers or detonators of A bombs, soldered two little silver spots and took a
~nicroscopic gold wire, on the detonators, and test fired these.
_She worked with beryllium off and on but did not personally sand, grind or polish such parts,
~She worked quite a bit with an explosive white powder which they would weigh out with
stainless steel spoons.
Some supervisors didn't tell workers what they worked with
‘Workers had blue books and classified red books that told workers what they did
There were times when —__ was not wearing a badge but her supervisor was
‘Also the men didn't seem to be as careful as the women were, they were braver. I

| ff
i

—-— 3



SEC-00090

12-19-07 Mound Plant

5.4.2 Beta

Although Po-210 itself does not emit bet
reactors to produce Po-210, contained tra
activated to produce radioactive contami:
separating the Po-210 was the primary si

emitters of concern from the polonium pi

a radiation, the Bi-209 slugs and their containers, irradiated in
ice quantities of several.non-radioactive elements that became
nants. Handling these slugs in preparation for chemically

irce of potential beta dose at Mound. Table 5-4 lists the beta
oduction process. (ORAUT-TKBS-0016-6) ;
a

| Table 5-4: Beta Emitters| Associated with Polonium Production at Mound
Radionuclide aximum Energy (MeV) Average Energy (MéV)

Sc-46 0.357 0.112
Zn-65_ 0.329 (Bt) 0.143

Hg-203 : 0.213 0.580 i

Ag-110m 0.531 0.165 a
Fe-59 1.565 0.615
Co-60 0.317 0.096

Bi-210 1.161 0.389 ‘

Beta-emitting radionuclides were presen
in polonium production. The beta-emitti
members of the naturally-occurring natu
Cs-137, and X¢é-131 (ORAUT-TKBS-0}

5.4.3. Neutron y
There were three neutron energy spectra
polonium-based sources (primarily Po-B}
and PuQ ) from the manufacture of radia
average emission energy neutron betwee!
average emission energy of approximate!
was a fission spectrum (maximum emiss
radionuclides (e.g., Cf-252) and critical 4
include a continuous’ spectrum of energia
interactions with different materials. Be
interactions with shiélding, facility const}
neutrons in the workplace are typically h
characteristic of the original source (Neu

in other Mound operations, but to a much lesser degree-than ,
ig radionuclides in addition to those in Table 5-4:inéluded
ally uranium, thorium, and actinium decay chains, St/¥.-90,'
16-2; ORAUT-TKBS-0016-6)

\
lat Mound. The principal sources of neutrons at Mound were
£ sources) and plutonium-based a,n sources (primarily PuFy .
‘isotope thermoelectric generators. A Pu-Be source has an
n 4 and 4.5 MeV; whereas plutonium-based sources ‘have an
ly 1.4 MeV. The third and less common neutron spectrum
on energy of about 2 MeV) from spontaneously-fissioning
ssemblies. Neutrons in the workplace would be expected to
is below the maximum emission energies due to their
cause moderation of neutron energy occurs through
uction materials, and process equipment and materials,
ighly-scattered, albeit with a neutron component
ron, 2001).°

30 of 95



SEC-00090 12-19-07 Mound Plant

7.3.1 Process-Related External Radiation Doses at Mound

The following subsections summarize the extent and limitations of information available for
reconstructing the process-rejated external doses of members of the proposed class.

7.3.1.1 Radiation Exposure Environment

The external dose received by Mound workers was a function of the physical location of the workers
on the site, the processes taking place, the types and quantities of material present, and the time spent
at each location. Most doses for Mound processing personnel resulted from a mixed. field of photons
and neutrons. Beta doses or doses from low-energy photons were present in some workplaces.
Breakdowns of the workplace radiation field characteristics are given in the relevant tables in the
Mound Occupational External Dosimetry TBD (ORAUT-TKBS-0016-6).

The primary sources of external dose at the Mound site are the two major production programs
involving polonium and plutonium. Tritium is not a source of external radiation dose. Laboratory
dose rates could also result in significant external doses, depending on the process and the amount of
material. Photon and neutron doses have been reliably measured using film dosimeters from the first
days of Mound operations. A summary of the characteristics of the major external dose sources is
presented below:

¢ Polonium Processing: Polonium is essentially a ‘pure’ alpha-emitter; however, alpha interactions
within the material matrix can generate neutrons with energy proportional to the energy of the
alpha particle. These neutrons’ energies will be degraded through scattering and moderation.
Thermal neutron interactions will include capture with emission of prompt gamma rays. Thus, the
polonium production work resulted in both photon and neutron dose rates.

The average energy of the Po-Be sources fabricated for nuclear weapons and other purposes is
reported to be approximately 4.5 MeV. This high average energy is measured with great
reliability using the NTA film dosimeters. Photon doses were reliably measured for all Mound
employees entering areas where radiation dose fields existed. NIOSH is confident that with the
existing data, appropriate neutron-to-photon ratios can be determined to provide.a bounding dose
estimate.

Initial polonium processing efforts at the Dayton Laboratory included considerable beta dose,
particularly of the extremities. The design process for the T Building, where polonium was
processed at Mound, took these high levels of beta radiation into consideration. Rooms 75 and 76,
where the loaded bismuth slugs were processed, were equipped with leaded windows (White
Paper T, 2002) and an “elevated platform (‘Rooms’ 275 and 276) was used to access valves and
doors by remote operations.” (King, 1995, Section 6.2.50). This evidence suggests that the beta
dose rates were controlled to a significant extent. That this is the reason that the site did not record
beta dose readings is documented in a January 4, 1960 memorandum from the health physics
supervisor, W.A. Bigler. The memo requires that open-window portions of the dosimeter film
will be read “on any film where the open window is visibly darker than the rest of the film.”
(Meyer, 1994, Volume I, Page 250) This change was made in response to the fact that health
physics personnel had noticed darkening of this portion of the film where it “had not been noted
before.” (Meyer, 1994, Volume |, page 164). The on-going TBD revision process will evaluate

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SEC-00090

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class as summarized in Section 3.0. This
Internal Procedures which are available q

The next four major subsections of this H

¢ The sufficiency and reliability of the
¢ The feasibility of reconstructing inte:
e The feasibility of reconstructing extel
© The bases for petition SEC-00090 as
7.1 Pedigree of Mound Data

This subsection answers questions that n
Data Pedigree addresses the background,
methodologies that may have changed o
they match; and whether data are internal
researcher’s confidence and later conclus
representativeness, and sufficiency for dé

approach is discussed in OCAS’s SEC Petition Evaluation
t http://www.cde.gov/niosh/ocas.

valuation Report examine:

available data. (Section 7.1)

al radiation doses. (Section 7.2)

(nal radiation doses. (Section 7.3)
submitted by the petitioner. (Section 7.4)

ed to be asked before performing a feasibility evaluation.
history, and origin of the data. It requires looking at site

er time; primary versus secondary data sources and whether
ily consistent. All these issues form the bedrock of the

ions about the data’s quality, credibility, reliability,
‘termining the feasibility of dose reconstruction. The

feasibility evaluation presupposes that data pedigree issues have been settled.

Since its inception, all Mound radiation n
comply with Federal radiation protection
exposure, as measured on a continuing b:
entered into personal radiation records fo}

Monitoring record-handling and storage

discussed in following subsections, wees record maintenance techniques have varied between

external and internal data. Individual wo}

In 1993, the DOE decided to close the Mi

Reconfiguration Program. This was an ef

expensive operation. The focus during th
retaining necessary resources and sustain
support of past missions were transferred
Archives and Records Administration (N]

the Kansas City Plant, Savannah River Si
Laboratory, associated DOE Operations 4

of Scientific and Technical Information (

transfer of document ownership and main
information assets of the weapons produc}
in Mound Records Transfer History (Lon

disposition to LANL (a petition basis) is

DOE has completed environmental reme
site. In May 2006, responsibility for mani

Corporation/Source One Management cor

Management (DOE/LM).

ponitoring procedures and record-keeping were carried out to
regulations. Each employee’s accumulated radiation
sis by various radiation detection dosimeter and assa‘

ys, Was
r permanent documentation. code

as varied over time, and with changing operators. As |

rkers’ files have been diligently maintained.

i
und Plant purstant to the DOE Weapons Complex

‘ort to realign the weapons complex into a smaller, less
realignment was to maintain the enduring stockpile while .
Ing weapons production competency. Records generated in
to various receiver sites, or dispositioned per the National
ARA)-approved retention schedules. Receiver sites include
‘e, Los Alamos National Laboratory, Sandia National

ind Field Offices, the DOE Historian's Office, and the Office
OSTI). Transfers of documentary materials also required
tenance responsibilities in order to preserve the existing
ition complex. Details of these records transfers are provided
b, 2007). In addition, a description of Mound records
included in Section 7.4.1.7.

iation and restoration of all but one Operable Unit at the
ging Mound records was transferred to the Stoller
tracting team, with oversight by the DOE Office of Legacy

|
1
50 of 95 |



IV. Designation Findings

Feasibility of Estimating Radiation Doses with Sufficient Accuracy

The Secretary established the feasibility determination for the class of employees
covered by this report based upon the findings summarized below.

(1) Mound separated radium-226, actinium-227, and thorium-228 from K-65 residues
and from irradiated radium. NIOSH has access to a limited number of bioassay
results for these radionuclides; however, the results are not definitive.

(2) While it is likely that the bioassay results that NIOSH has relate to the workers
directly involved in the separation operation, the fraction of these workers that
was sampled for the bioassays is unknown. For the time period of the designated
class, NIOSH determined that internal doses from these radionuclides cannot be
determined with sufficient accuracy.

(3) There is strong evidence that airborne contamination was produced by the
separation process. The limited number of individuals for whom radium-226,
actinium-227, and thorium-228 bioassay results are available suggests that the
larger population was not monitored for potential intakes. The reported airborne
contamination concentrations are relatively high in some cases, suggesting the
potential for non-trivial intakes and consequent internal doses.

(4) Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient
information to either: (1) estimate the maximum radiation dose, for every type of
cancer for which radiation doses are reconstructed, that could have been incurred
under plausible circumstances by any member of the class; or (2) estimate the
radiation doses of members of the class more precisely than a maximum dose
estimate.

(5) The Board concurred with the NIOSH evaluation and recommended the proposed
class for addition to the SEC.

(6) Although NIOSH found that it is not possible to completely reconstruct radiation
doses for these employees, NIOSH can bound the internal doses arising from
exposure to polonium, tritium, plutonium, radon, protactinium, Th-230, Th-232,
uranium, and stable metal tritides using the scenarios. NIOSH determined that it
is also possible to reconstruct occupational medical dose and all external dose.
Therefore, individuals with non-presumptive cancers may be considered for
partial dose reconstructions.

Health Endangerment

HHS Special Exposure Cohort Designation:
Mound Plant



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, 0.C. 20201

MAR - 3 2008

The Honorable Harry Reid
Majority Leader ‘
United States Senate
Washington, D.C. 20510

Dear Senator Reid:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 (EEOICPA) and 42 C.F.R. pt. 83, a petition was filed on behalf of workers from the Mound
Plant near Dayton, Ohio, to be added to the Special Exposure Cohort (SEC).

The Centers for Disease Control and Prevention’s (CDC) National Institute for
Occupational Safety and Health (NIOSH) evaluated the petition and presented its findings to the
Advisory Board on Radiation and Worker Health (Board) on January 8, 2008. The Board

' considered the petition, and on February 1, 2008, I received the Board’s recommendation
concerning this petition. I have also received the deliberations, findings, and recommendations
of the Director of NIOSH and the Director of CDC. I have designated the following class for
addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who worked in any areas at the Mound Plant
site from October 1, 1949, through February 28, 1959, for a number of work days
aggregating at least 250 work days or in combination with work days within the
parameters established for one or more other classes of employees in the Special
Exposure Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



SEC-00090 12-19-07 Mound Plant

Table of Contents
Evaluation Report Summary: SEC-00090 Mound Plant..........ssessesssssssseecececsecseeseenesseseeseeneeaesessneeeeeneeee 3
1.0 Purpose and Scope.......csscessecsessecseesesseesscsecsecsecasssesseescsncescavcssssseasessessnsnecsscsscsucsesererceresesseeseeaeseessens 0
2.0 Introduction wo. eeeececeeecseseseeeseescssesssesscsesesesnsscsesceeseescsucacsesessesecsisaesecsesecsesssaeseseasseseensaeensaeeneseenes 9
3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis .........s.sscssssssseseessereeeeseentenre 10
4.0 Data Sources Reviewed by NIOSH

5.0

6.0

4.1 Site Profile Technical Basis Documents (TBDs) ..
4.2. ORAU Technical Information Bulletins (OTIBs) and Procedures
4.3 Facility Employees and Experts
4.4 Previous Dose Reconstructions .
4.5 NIOSH Site Research Database
4.6 Other Technical Sources........
4.7 Documentation and/or Affidavits Provided by Pe'

ioners

Radiological Operations Relevant to the Proposed Class .
5.1 Mound Plant and Process Descriptions
5.2 Mound Functional Areas
5.2.1 Polonium Research and Production.
5.2.2 Plutonium-238 Research and Development .
$.2.3 Tritium Production see
5.2.4 Substitute Materials, Radium-226, Actinium-227 and Thorium-228
$.2.5  Thorium-232 Extraction...
5.2.6 Thorium-230 and Protactinium-231
5.2.7 Rare Isotope Programs .....
5.2.8 Uranium-234 from Plutonium-238.
5.2.9 Thorium-229 from Uranium-233 (Irradiated Thorium-232)
5.3 Mound Radiological Buildings.
5.3.1 Mound Site Decommissioning
5.4 Radiological Exposure Sources from Mound Operations
5.4.1 Alpha.
5.4.2 Beta
5.4.3. Neutron.
5.4.4 Photons .
5.4.5 Incidents

Summary of Available Monitoring Data for the Proposed Class
6.1 Mound Internal Monitoring Data .
6.1.1 Tritium Bioassay
6.1.2 Polonium-210 Bioassay
6.1.3. Plutonium-238 and Plutonium-239
6.1.4 Radon Isotopes



SEC-00090

12-19-07 Mound Plant

oe

‘Smallest reported activity in database.
Chest counting MDAs reported in the Mound TBD, Tab|
for Pu-239.

°

Routine bioassay monitoring included col
Table 6-1. For example, only those work
were monitored monthly for Pa-231. Tw
the plutonium isotopes, typically as a foll
inferred from personnel sampling records|

Individuals identified as being involved i
in excess of the reporting limits, were req}
Administrative persorinel were not moniti
personnel if their work on a specific proje
monitored annually by whole-body or che
Mound used the action levels in Table 6-
target organ dose limit. Results in excess
worker on the “hot roster” to control furtl
in place by 1949 when Mound operations!
followed the limits stated in the National

7
Table 6-1: Bjoassay Programs and Action Levels
Bioassay program Period Action levels” Monitored workers Frequency
|
In vitro monitoring :
r
Po-210 (Postum) recovery 1945-1974 10 cpm 50. mI | Operations personnel Monthy hrto
‘Ae-227, Ra-206, Th-228 1951-1960 [83 epm 24 hr | Research personnel Weekly 24 hr
Th-232 sludge, re-drumming 1955-1975 2.8 opm 24hrTM | | Th Refinery personnel Monthly 24 hr
Th-230 (lonium) research 1956-1959 3.5 cpm 24hrTM |_| Research personnel Bi-Weekly 24 hr
Pa-231 extraction 1956-1960 2.2 epm24hr* | |Research personnel Monthly 24 br
U-233 research 1958-1960 20 epm 1,500 mi | [10 Research personnel Weekly 24 hr
7" . 1957 to plant yl |. | Recovery personnel Weekly Spots

Tritium (hot gas) production Ds? 10 uCiL’ | Weekly 26 he
Pu.239 neutron source 1957 +0 pant Py 5 com abe Processing personnel Weekly 24 hrto

closure annually
Pu238 heat source 1960 t Blan 55 com 2a br? Processing personnel Weekly 24 hrto

closure annually

1983 to plant eb :
Am-241 & Am-243 83 0 0.0 pCiva Potentially exposed personne! _| As needed
Cm-244 1983 t0 plant | o.9 pcid® Potentially exposed personnel _| As needed

In vivo monitoring
Whole body counting 1 1960-1970, [Not Available | Operations personnel ‘Annual
Chest counting 183 t0 Plant | Variable® Operations persénnel |Annual
‘AL = action levels; observed counts per minute for $0 m) or 24-hour samples tht result in a worker dose of 300 mrem/wk tothe target organ,

le 5-19 for Am, Pu, Th, snd U isotopes. MDAs range from 0,1 nCi for Am241 to 130 nCi

i

lection of spot and 24-hr urine samples, as identified in
prs conducting research to separate and purify protactinium
nty-four hour samples were also requested for Po-210 and

w-up to a potential intake. Monitoring frequencies were

an internal exposure incident, or who had urinalysis results
ired to submit additional 24-hr urine samples for analysis.
red and monitoring was discontinued for operational

ct was no longer needed. Operational personnel were

ist counting, or if there was a suspected exposure incident.

to evaluate and control worker doses to a 300 mrem/week
f action levels triggered re-sampling and placement of the
‘er exposures, if necessary. Typical dosimetry controls were
were moved from the Dayton facility. These controls
Bureau of Standards Handbook 52 (NBS, 1953).

i j
i

36 of 95



SEC-00090

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Mound Plant

Table 6-6: Summary of External Monitoring Data in the MESH Database
(Table 6-6 spans two pages)

Year Number of Workers Number of Records Number of Beta

Monitored Available’ Records
1949 620 620 1
1950 630 630 0
195] 669 669 0
1952 654 654 0
1953 579 579 0
1954 321 321 0
1955 209 209 0
1956 168 168 0
1957 203 203 0
1958 302 302 0
1959 384 384 0
1960 502 502 0
1961 608 608 1
1962 663 663 ]
1963 751 751 1
1964 993 993 lL.
1965 ~ 1036 1036 5
1966 1323 1323 2
1967 1397 1397 2
1968 1436 1436 423
1969 1485 1485 554
1970 1506 1506 1208
197] 1396 1396 "835
1972 1412 1412 219
1973 1410 1410 142
1974 1331 1331 866
1975 1539 1539 1075
1976 1059 1059 755
1977 1306 2452 1464
1978 1324 8757 1978
1979 1464 8889 1717
1980 1600 9355 1324
1981 1792 10099 1376
1982 1987 9244 1373
1983 2300 9403 2018
1984 3315 10955 5718
1985 3508 10996 6362
1986 3309 12421 4889
1987 3957 14504 5083
1988 4638 16382 5000

45 of 95



ottling

Public Health Service

i .
rR ‘
mG DEPARTMENT OF HEALTH & HUMAN SERVICES

National Institute for

Occupational Safety and Health
Centers for Disease Control

and Prevention (CDC)
200 Independence Avenue, SW
Washington, DC 20201

DATE:
TO: The Secretary
Through: DS
COs
ES
CDC
FROM: Director

National Institute for Occupational Safety and Health

SUBJECT: Designating Certain Employees of the Mound Plant near Dayton, Ohio, as
Members of the Special Exposure Cohort under the Energy Employees
Occupational Illness Compensation Program Act of 2000 — ACTION

Action Required: Submit Report to Congress by March 3, 2008
ISSUE

Attached for your approval and signature is a proposed designation to add certain employees
from the Mound Plant as members of the Special Exposure Cohort (SEC) under the Energy
Employees Occupational Illness Compensation Program Act (EEOICPA), 42 U.S.C. § 7384q
(Tab A).

DISCUSSION

EEOICPA established an SEC, a designation applied to certain classes of employees who
worked at United States nuclear weapons production facilities of the Department of Energy
(DOE) or Atomic Weapons Employers (AWEs). EEOICPA confers upon SEC designees a
presumption of causation regarding the relation of their cancers to their employment at a DOE or
AWE facility. This presumption allows them to obtain federal compensation under EEOICPA if
they incur at least one of a list of “specified cancers” that, under EEOICPA, are presumptively
linked with occupational exposures to radiation at DOE and AWE facilities. EEOICPA initially
included four classes of employees in the SEC and provided that the President could designate
additional classes as members of the SEC if certain statutory conditions are met. The authority
to designate additional members was delegated by the President to the Secretary of the
Department of Health and Human Services (HHS), who promulgated procedures for doing so



SEC-00090 12-19-07 Mound Plant

7.3.4.3 | Neutron Dose

Neutron dose monitoring was identified as an area requiring improvement during operation of Dayton
Units HI] and TV. When the polonium operation moved to the Mound site, neutron dose monitoring
began after August 1949, though operations with polonium began in February of that year. The health
physics program did not assume a need for neutron dosimetry prior to the beginning of dose
monitoring in late 1949. Once begun, neutron dose monitoring with neutron-track emulsion was
likely to measure the neutrons associated with the Po-Be sources with reasonable accuracy, based on
the calibration protocol used.

- Unmonitored neutron doses may be bounded using neutron-to-photon ratios based on Mound data.
NIOSH also has considerable Mound NTA processing data, which provides another option to validate
the claimant favorability of the neutron dose calculated using the neutron-photon ratio and the
measured photon dose. Mound data includes NTA calibration with the plutonium tetrafluoride source
that likely provides a neutron spectrum most similar to the neutron spectra in Mound plutonium
facilities. In addition, the earlier doses determined with NTA film, once corrected for energy response
limitations (i.e., the fraction of the neutron spectrum that was not measured by the NTA), can be used
as another method of validation.

Calculation of missed neutron dose at Mound is more problematic than photon missed dose, which is
also based on total annual doses through the year 1977. Claimant-favorable assumptions are used to
overestimate the missed-dose as with the photon dose; however, correction factors applied to the
missed doses in accordance with the Mound Occupational External Dosimetry TBD result in a
significant multiplication of the likely missed doses. For this reason, use of a neutron-to- photon ratio
will likely result in a more reasonable estimate of neutron missed dose.

Given the fact that reliably-measured photon doses are associated with Mound workers, NIOSH can
bound the dose with sufficient accuracy.

7.3.4.4 Unmonitored Individuals Working in Production Areas

The requirement to wear external dosimeters at Mound was based on the areas an employee accessed.
This policy is described at several points in the comprehensive history of the Mound site external dose
monitoring program (Meyer, 1992). Since this is the case, it is unlikely that individuals routinely
entered production areas without dosimeters. Some individuals were not routinely monitored for
external dose; however, they were required to use a temporary or “visitor’s” badge upon entry to
controlled areas. Discussion of the policies for distributing visitors’ badges is also present in the
external dose history. Since all workers entering radiation-controlled areas were required to wear a
dosimeter, it is certain that those receiving the highest dose were monitored. For unmonitored
individuals, claimant-favorable assumptions for on-site ambient doses are applied as part of the
estimate.

Other information in routine health physics reports suggests that only some individuals were
monitored for neutron dose. This policy may be based on dosimeters being assigned only to
individuals working with neutron sources and initiators, and could result in unmonitored neutron dose
from alpha-n reactions associated with Pu-238 and, possibly to a lesser degree, Po-210 in the major
Mound processes. Because the workers who were monitored were the most highly-exposed, as well

71 of 95



SEC-00090

12-19-07 | Mound Plant
|

Neutron, 2001, Validation of Personnel
Scherpelz, et al; Pacific Northwest Nati
ID: 35720 ,

ORAU, 2003a, Processes and Characte;

locator, DOE Site Images, Mound Laboi

Ridge Associated Universities for NIOS

Ohio; SRDB Ref ID: 12328

ORAU, 2003b, Appendix A: Detectable|A

Images, Mound Laboratory, Data Captul

leutron Dosimeters in the Workplace at Mound, R. 1.
nal Laboratory; | PNWD- 3118; September, 2001; SRDB Ref

i
istics of Major Isotopes Handled at Mound, ORAU file

atory, Data Capture 11-18-03, Folder 2311, pp. 65-126; Oak
IH Office of Compensation Analysis and Support; Cincinnati,

mounts for Urinalysis, ORAU file locator, DOE Site
e 11-18-03, Folder 2311, p.1; Oak Ridge Associated

Universities for NIOSH Office of Compensation Analysis and Support; Cincinnati, Ohio; SRDB Ref

ID: 8641 pg 2

ORAU, 2003c, Specific 24-Hour Fecal Records, ORAU file locator, DOE Site Images, Mound

Laboratory, Data Capture 11-18-03, Fo!

Office of Compensation Analysis and Support; Cincinn:

ler 2311; Oak Ridge Associated Universities for NIOSH
ati, Ohio; SRDB Ref ID: 8641

ORAU, 2003d, Database of Ra-. Ac- Th Excretion Data, ORAU file locator, DOE Site Images, Mound

Laboratory, Data Capture 09-24-03, Fo

der 1805; Oak Ridge Associated Universities for NIOSH

Office of Compensation Analysis and Support; Cincinnati, Ohio SRDB Ref ID: 8754

ORAU, 2003e, Database of Excretion lata for Other Radionuclides, ORAU file locator, DOE Site

Images, Mound Laboratory, Data Captu
for NIOSH Office of Compensation An,

PAAA, 2006, Price Anderson Amendm
Mound from 1990 to Present, Departm
37733 4
Personal Communication, 2007, ORAU
October 25, 2007; SRDB Ref ID: 3733

‘Polonium, 1956, Pélonium, book by
Energy Commission; July 1956; SRDB
‘

1
Spitz, 1989, Retrospective Analysis of }
Occupational Monitoring Program Be
EG&G, Mound Technologies, Radiolo;
Ref 1D: Not currently in SRDB

Ten-Year Plan, 1977, Ten-Year Plan fc
Laboratory, Sam S: Freeman; Monsant
1977; SRDB Ref ID: 33360

UNC Geotech, 1990, DOE Indoor Rad
Geotech; Grand Juhetion, Colorado; A

re 09-24-03, Folder 1806; Oak Ridge Associated Universities
alysis and Support; Cincinnati, Ohio; SRDB Ref ID: 8757

nts Act (PAAA) Documents Regarding Fines Levied Against
nt of Energy, Office of Legacy Management; SRDB Ref ID:

interview with|Joyce Massie, S. M. Stoller Corporation,

oS

|
HV. ‘Moyer of The Ohio State University for the U. S. Atomic

Ref ID: 12703

i
olonium-210 Urinalysis Data Collected as Part of a Routine
een 1943 and 1965, H. B. Spitz; Quality Assurance Report;

gical Science; Miamisburg, Ohio; February 28, 1989; SRDB

ir Decontamination and Decommissioning for Mound

10 Research Corporation; MLM-MU-77-66-0001; June 30,

n Study, Office of Projects and Facilities Management, UNC

pril 12, 1990; SRDB Ref ID: 13191

94 of 95



a ees eT ae

Page 4 - The Secretary

RECOMMENDATIONS

Based upon the foregoing, the Director of NIOSH and the Director of CDC recommend that the
Secretary approve and sign the attached designation to add to the SEC certain employees from

the Mound Plant.

MAR - 3 2008

Disapproved , Date

Jol oward, M.D.

7 Attachments:

Tab A — Designation of a Class of Employees from Mound
Tab B - 42 C.F.R. pt. 83

Tab C - Mound SEC Petition

Tab D — NIOSH SEC Petition Evaluation Report, SEC-00090
Tab E - Board Recommendation Letter to Secretary Leavitt
Tab F - Transcripts of relevant Board discussions



SEC-00090

12-19-07 Mound Plant

as those most likely to be exposed at all, jall worker doses may be bounded by assignment of a

proportional dose from neutrons as descr]

7.3.4.5 Medical X-ray

In December 2003 and January 2004, an
decomposition, it became necessary to.s¢
films which could not be interpreted and
destroyed. DOE Administrative Record
destruction of the decomposed film. (Loi

In the absence of measurement data or ot
- organ doses for LAT: view can be calcul
default value of 2.5 and using this value
appropriate organ dose. For evaluation p
photon energies in the range of 30 to 25
with an uncertainty of +30% at the 99%
positive uncertainty should be used and a
99% confidence interval. (ORAUT-TKB

Based on the information available to NI
_can-be reconstructed with sufficient accu:

: Missed Dose

Calculation of missed external dose at M
available, in almost all cases through the

iibed in Neutron:Dose, Section 7.3.4.3.

[X-ray segregation project was conducted. Due to

gregate the decomposed X-ray film from the good film. The
posed a health hazard to workers were segregated and
Retention Schedule 21 Item 21.d provides for the immediate
ig, 2007)

her specific information, a claimant-favorable approach for
ited by multiplying the entrance kerma for the PA view by a
long with the ICRP (ICRP, 1982) tables to compute the
poses, X-ray doses are always considered acute with
keV. For actual dose calculations, a normal distribution
onfidence interval can be assumed. However, only the
multiplier of 1.3 can be used to include uncertainty at the
8-0016-3)

|
OSH, the medical X-ray dose for the class under evaluation

acy. a]

und is problematic because only annual dose results are
ear 1977. For the year 1978 and after, actual zero and non-

zero results are used.’ If cycle data are not available for the earlier period, then missed doses are

necessarily overestimated. In most cases,

single cycle, and the balance of the result!

frequency assumptions are based on Tabl
or assumed to be the maximum routine d
overestimating practice. Other cases may
individual cases, the method of arriving
in the dose reconstruction report.

7.3.5 External Dose Reconstruction FI

NIOSH has established that it has access

external radiation dose for every type of dancer for which
have been incurred under plausible circumstances by any
external radiation doses to members of th

annual total doses are assumed to have been received in a

& is assumed to be zero dosimeter results; monitoring

k 6-11 in the Mound Occupational External Dosimetry TBD,
simeter exchange frequency. This is known to be an
require less overestimating assumptions; however, for

at the assumed number of zero dosimeter results is explained

!
leasibility Conclusion
0 sufficient information to: (1) estimate the maximum
radiation doses are reconstructed that could
member of the class; or (2) estimate the

e class more precisely than a maximum dose estimate.

72 of 95



Special Exposure Cohort Petition
under the Energy Employees Occupational
Illness Compensation Act

Special Exposure Cohort Petition — Fort

U.S, Department of Health and Human Services

Centers for Disease Contro! and Prevention

Natlonal Institute for Occupational Safety and Health

MB Number. 0920-0639 Expires: 05/31/2007

B | Appendix — Petitioner 2

Use of this form and disclosure of Social

fecurity Number are voluntary. Failure to use this form or disclose

{ais number will not result in tne denial

of ary right, Lenefit, or privilege to which you may, be entitled...

Use th

This appendix formis to be used as neede:
parts applicable to him or her.

Refer to the General Instructions on comp!

Ifyou need more space to prov ae aad tion:
the form anc actach te comp eted continud

Except for signatures, please PRINT all inf

| information, use the contnvation page provided at the end of

ls Appendix for Petitioner 2.

. Petitioner 2, or his or her representative, should complete the

ting petitioner information for Parts A, B, or C.

tion page sy to Form B.
rmation clearly and neatly on the form.

@An Energy Employee (curre|

ht or former), ‘

| Start at C

QA Survivor (of a former Ene

If you are:

igy Employee), Start at B

QA Representative (of avcurre

Are you a contact person for an

Ad

petition by the survivor(s) or ery

A2_ Organization Information:
“Name of Organization
f

Position of Contact Person *
A.3__ Name of Petition Representative: |

Mr/Mrs/Ms, First Name Middle Initlal Last Name
A4 Address: |

Street Apt # P.O. Box

City State Zip Code
A5 Telephone Number: »
A6 Email Address: | :
A7 —Q Check ttie box at left to indicate you have attached to the back of this form written authorization to

form for this purpose Is provided.

ioyee(s) indicated in Parts B or C of this form. An authorization _

If you are representing a Survivor, go

Name or Social Seciirity Number of First Pe

ttitioner:

reer



SEC-00090

12-19-07 _| Mound Plant

Questionable results were all checked ag
identified by the test plan implementatio:
Quality Assurance Form.

In July 1999, approximately 350 (8 2” b:
miscellaneous bioassay records in the M
cabinets. The existence of these data wa

inst original logbook entries. All database alterations
were documented on Form TPOOI-I, MESH Record
: t

11”) “KARDEX” cards were discovered among the
und Occupational Radiological Exposure (MORE) records
mentioned in the Meyer bioassay history document (Meyer,

1992). A thorough search of the record archives revealed their existence. The Meyer document also

noted that the KARDEX data were the ci
that time period. Analysis of this new int
background that the logbook entries for tl

The approximately 2300 data points for 2
an Excel spreadsheet, and the pCi value ff
then printed out for each individual and p
the identified individual’s Phase II data p
_ new KARDEX data.

In general, the KARDEX data were calcu
PURECON database for the period 1960
that were >MDA were calculated using t
updating the PURECON database with th
data for:the period of 1960 to 1962, thus
database with the KARDEX data for:196)
” entered correctly. ‘
As detailed in the Pre-1989 Dose Assessi}
PURECON database for Pu was thorough
database was required based on an initial

rrect results and should replace any logbook data entered for
formation showed that the KARDEX data took into account
¢ same period did not.

38 individuals for the time period 1960-62 were entered into
pr a 24-hour sample was calculated. This information was
laced, along with a copy of the original KARDEX data, in

acket. In addition, the database was updated to include all

lated, to be 0.1 to 0.2 pCi lower than the data in the

hrough 1962. Ih several cases, existing PURECON data

ie new KARDEX data to be <MDA. The net effect of

le KARDEX data has been to take into account background 3
lowering the netiresult." Comparison of the PURECON .° ?
P showed that the majority of results in PURECON had been

3
nent Project Phase I Final Report (Volume I), the

ly reviewed for'errors. A complete QA review of the
random check of 5% of the existing data. This 100% QA

effort corrected approximately 2347 errors in 58,893 records, for an error rate of ~ 4%, All database

corrections were recorded. The corrected database was g'

completion of all additional data entries;
the final database QA. During all PURE
network server located at the MJW office

Polonium Bioassay Data
f

The Po bioassay database for Mound employees contains
from 1944 to 1973. Code-named PORECON, it was creal
individual dosimetry files located in MOR

ven one additional QA review following -
he person performing the initial data entry did not perform
‘ON database work, the database was maintained on a secure
5. : .

207,750 individual sample results spanning
‘ed from polonium data cards contained in
XE records. Since these data cards were transcribed from

original logbooks, QA of the database took two forms. The first was the double-key entry process,

whereby a data clerk éntered the “card” d
second independent entry. The database
alerted the sécond cletk if a discrepancy
was required to alert MJW supervisory st:

discrepancy, at which point the program accepted the data.

|

hta into a database and a different data entry clerk made a
reation program automatically checked the two entries and
as present. When a discrepancy occurred, the second clerk
ff. The supervisor interpreted the data and corrected the

52 of 95



SEC-00090

12-19-07 Mound Plant

Table 6-7 summarizes general dosiméter types used and assignment policies.

Table 6-7: Mound Dosimeter Use and Assignment Policies

Date

Photon dosimetry

February 21, 1949

Operations began in T Building. Film badges, one sensitive and one insensitive film, with 1-mm
cadmium filter read weekly and two pocket ion chambers read daily. Beta window not read.

December 1951

Film badges read every 2 weeks.

May 1966

Use of pocket ion chambers discontinued.

September 1968

New dosimeters with security credential. Based on Nevada Test Site badges but with different
filters. Modified later with TLD photon dosimeters plus Nevada Test Site neutron dose film. In
1977, questions were raised about low-energy photon dose underestimates with tantalum shields.

1972

Routine extremity dosimetry began.

December 1977

All-TLD dosimeters introduced.

October 1986

New soft-pack dosimeters.

June 1991

New hard-pack dosimeters with neutron track etch capability.

June 1993

Added neutron track etch capability for future use.

September 1949

NTA track etch film for fast neutrons first used in T and R Buildings. Read 10 fields at 980 power
magnification and averaged readings.

September 1956

Began reading 10 fields at 430-power magnification with projection microscope and averaged
values.

December 2, 1957

Returned to using 980-power projection microscope to read NTA film.

January 21, 1963

Began routine monitoring of night maintenance staff in Building P.

March 1963 Began using 400-power projection microscope. Reading 64 fields and averaged.

October 1964 Began using new projection microscope with better light

March 1966 Began badging all hourly Engineering Department staff members who spent a portion of their time
in radiation control areas of plant.

April 1967 Began using another new projection microscope, first at 500-power, then at 1,000-power.

August 1, 1968

Exchange frequency for Buildings R and SW personnel changed to 4 weeks.

Nov./Dec. 1977

All-TLD dosimeters introduced. Began using TLDs for neutron exposure monitoring.

October 1986 New soft-pack dosimeters.
June 1991 New hard-pack dosimeters with neutron track etch capability.
June 1993 Added neutron track etch capability for future use.

Table 6-8 below summarizes the beta-photon dosimeter types, exchange frequencies, and types of
workers who were monitored.

Table 6-9 below summarizes the neutron dosimeter types, exchange frequencies, and types of workers
who were monitored.

47 of 95



ry
if

Special Exposure Cohort Petition uU. S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Itinesa Compensation Act : National Institute for Occupational Safety.and Health

| OMB Number: 0920-0639 Expires: 05/31/2007
Special sure Cohort Petition — Form B | ge 2of7

Survivor Information — Complete Section B if re a Survivor or representing a Survivor.

B.1 Name of Survivor: |

MriNirs.JNis; First Name : Middle Initial Last Name
B.2 Social Security Number of Survivor: |
8.3 Address of Survivor:

Street [ Apt# P.O. Box |
City Stat¢ " Zip Code
B.4 Telephone Number of Survivor: | ( i
B.S Email Address of Survivor: |
B.6 ‘Relationship to Employee: O Spouse | O Son/Daughter Parent
} Q Grandparent Q Grandehild
Go to Part G.
C.1 Name ofEmployee: | a
MriMrs/Ms. First Name ~ Middle Initial “LastName '

C.2 Former Name of Employee (@.g.,|maiden /name/legal name changelother):

Mr/Mre/Ms. First Name Middle Initial Last Name
C.3 Social Security Number of Emplbyee: —
C.4 Address of Employee (if living): |

Street” | Apt ; P.O. Box

City * St | ZipCode :
C5 Telephone eel a !

C6 Email Address of Employee:

C.7 Employment Information Relate
C.7a Employee Number (if known):

C.7b Dates of Employment: Start! Ke End _ 2601
C.7¢ Employer Name: Monstnn, G76 uxt, aa.

‘

C.7d_ Work Site Location: Mou ve) Suk Matus BukG, OH

C.7e Supervisor's Name:

|
1 Go to Part E.

: Ans aa
Name or Social Security Number of First Fetitioner.

Nise) a7 Iw [e007

4
4



SEC-00090

12-19-07

Mound Plant

« Affidavit from former employee; OSA Ref ID: 103513 (7-30-07
© Affidavit from former employee; OSA Ref ID: 103554 (8-13-07)

« Affidavit from petitioner representative, plus a copy of the letter received from the U.S.

Affidavit from petitioner and her representative; OSA Ref ID: 103513 (7-30-07)

Department of Labor dated Jun 7, 2007 in regard to her dose reconstruction. This letter indicates
that the “prior dose reconstruction” may be invalid for not only the petitioner but for other Mound
Plant employees; OSA Ref ID: 103554 (8-13-07)

Petition SEC-00091:

¢ Form B petition; OSA Ref ID: 103209, (6-14-07)

* No affidavits were associated with this petition.

5.0 Radiological Operations Relevant to the Proposed Class

The following subsections summarize both radiological operations at the Mound Plant from February |
1, 1949 through August 17, 2007 and the information available to NIOSH to characterize particular |
processes and radioactive source materials. From available sources NIOSH has gathered process and .
source descriptions, information regarding the identity and quantities of each radionuclide of concern,

and information describing both processes through which radiation exposures may have occurred and

the physical environment in which they may have occurred. The information included within this

evaluation report is intended only to be a summary of the available information.

NOTE: Throughout this evaluation report, the term “Mound” will be employed to refer to all
historical phases of, and successive names for, the Mound Site. Mound was operated by several
different companies. Table 5-1 shows the operational chronology. These companies contracted to the

U.S. Atomic Energy Commission (1948-1974), the U.S. Energy Research and Development

Administration (1974-1977), or the U.S. Department of Energy (1977-present).

Table 5-1: Mound Plant Operational Chronology

Company* Years

Monsanto Chemical Company 1948-1961
Monsanto Research Corporation 1961-1988
EG&G Mound Applied Technologies, Inc 1988-1997
Babcock and Wilcox of Ohio, Inc. 1997-2002
CH2M Hill Mound, Inc. 2003-2006

S.M. Stoller Corporation (DOE Legacy Management)

2003-present

Accelerated Remediation Company (aRc): OU-1 Landfill

and PRS-441 Rail Yard remediation

2006-present

* The above information is from the Mound Records Transfer History (Long, 2007)

17 of 95



SEC-00090 12-19-07, Mound Plant

7.2.1.3 Plutonium

Pu-238 is the primary radionuclide of concern with respect to internal dose at the Mound site
beginning about 1959. The first production RTG, the SNAP-3A, was built in 1958 using Po-210
alpha decay as a heat source. President Eisenhower used the current to generate a radio transmission
from the Oval Office in 1959. Subsequently, the SNAP-3 was redesigned to use Pu-238 in order to
extend the life of the generator. The SNAP-3B was first launched in the Navy Transit satellite
program.

Production of Pu-238 was a large-scale project, eventually using the SM and PP buildings, and
extending from 1959 through the late 1970s. A number of material forms were used, including
Pu-238 metal, plutonium oxide, plutonium dioxide, and plutonium metal ceramic (cermet). The
generator projects included a number of spacecraft power sources for satellites, the Apollo program,
and planetary and interstellar space exploration programs employing the Pioneer and Voyager
spacecraft. Other sources were fabricated for use in buoys, for potential use in pacemakers, and in
diving suit heat sources. Production efforts were reduced in the period of the 1970s. During this time,
encapsulation of the Pu-238 was moved to the Savannah River Site, and after 1979, unencapsulated
Pu-238 was not routinely handled at Mound. The program had an indeterminate status for a number of
years, but operations with RTG fuel were officially moved to the INEEL site in 2006.

The Mound site featured only limited exposure to weapons-grade plutonium in small-scale research
operations and the preparation of a small number of neutron sources. Weapons-grade Pu-239 used in
the Mound plutonium neutron source project (R building, 1956-1958) was reported to be over 95%
pure by mass, with trace amounts of Pu-240 and Pu-241, which are not dosimetrically significant
(King, 1995). Additional information on Pu-239 feed material characteristics can be found in the
Mound site profile.

Plutonium bioassay results are available from 1956 through 1991 in the PURECON database.
Subsequent plutonium internal dose monitoring results are listed in the MESH database. Early results
were based on gross alpha measurements, and the resulting doses must be calculated based on the
potential exposure. Later measurements (1980 and after) were isotopic for Pu-238 and Pu-239. These
data may be supplemented with available process information to estimate a reasonable bounding dose.

7.2.1.4 Other Radionuclides with Bioassay Monitoring Data

The Mound site conducted diverse activities in research and chemical engineering; a number of which
are discussed in Sections 6.1.4 through 6.1.10. Each process is summarized below with respect to
methodology used to reconstruct internal dose.

¢ Protactinium-231, 1954-1958: This limited program featured bioassay data for the primary
radionuclide beginning in 1955, and this value is used to assign missed dose as well as potential
dose from intakes implied by positive results. These data may be supplemented with available
process information to estimate a reasonable bounding dose.

59 of 95


Mound Plant

SEC-00090 12-19-07
A summary of the number of records/year applicable to the proposed class time frame is presented in
Table 6-2.

' 1

Table 6-2: PORECON Polonium Record Summary

Year 1949 1950 1951 1952 1953 1954 | 1955 | 1956 | 1957 | 1958 | 1959 | 1960 | 1961
Records | 16,550 | 18,064 | 17,332 | 18,360 | |10,957 |°2,638 | 1,787 | 1,752 | 2,309 | 2,754 | 3,219 | 5,124 | 6,472
Year 1962 1963 1964 | 1965 1966 | 1967 | 11968 | 1969 | 1970 | 1971 | 1972 | 1973
Records [ 7,743 | 7,890 | 8,343 | 7,090 [16,659 | 7,526 | 6,444 | 3,194 | 1,043 | 353 74 31
6.1.3 Plutonium-238 and Plutonium-239

Bioassay of the plutonium isotopes at Md
the development of specific methodologi

und underwent
's to isolate and

considerable change and improvement with
count Pu-238 and Pu-239. The various

methodologies are discussed in the Mound Occupational Internal Dosimetry TBD (ORAUT-TKBS-

0016-5); however the major features of tl
summarized in Table’ 6-3 below.

¢ internal dose monitoring program for plutonium are

. ‘Table 6-3: Summary of Historical Plutonium Analytical Procedures * “4 *
Period Reporting level” Analytical method i
1954-1960 (Kirby, 1954) Alkaline earth phosphate co-precipitation; plutonium separation with

0.05 dpm 1.5L" cerium carrier; gross alpha for plutonium; proportiorial counting;

0.5 dpm 1.5 L''(Corrected recoveries 68546 due to colloidal plating of metabolized Pu.

DL} *

1961-1967 (Kirby, 1954) Sample acidification; alkaline earth phosphate co-precipitation;

0.1 dpm 1.5L" plutonium separation with cerium carrier; gross alpha for plutonium;
proportional counting; recoveries 90 + 3%. Uranium and plutonium
results reported Separately only in 1966 using anion exchange
methods.

1968-1977 MD-20736 (Mound 1963) || Alkaline earth phosphate co-precipitation; plutonium separation with

0.1 dpm 1.5L" cerium carrier; anion exchange; electro-deposition; gross alpha
reported for plutonium; proportional counting.

1978-1979 MD-80030 (Mound 1981) Alkaline earth phosphate co-precipitation; plutonium separation with

0.1 dpm 1.5 Lt cerium carrier; anion exchange; electro-deposition; alpha
Spectroscopy for, Pu-238 and Pu-239/240; Pu-242 tracer.

1980-present MD-80030 (Mound 1981) || Alpha spectroscopy for Pu-238 and Pu-239/240; anion exchange;
0.07'dpm 1.5 L” for routine | | Pu-242 tracer; blanks counted for decision level determination.

samples i

The 24-hr reporting levels are based on a standard|
Reference Man in ICRP Publication 23 (ICRP, 19
Detection limit was corrected for a low chemical r

rn

ample volume of 1. L. Standard man in ICRP Publication’2 (ICRP, 1959) and
5) both have a urine volume of 1.4L. Actual collected urine volumes will vary.

covery of 10% due to colloidal plating of plutonium.

38 of 95



under the Energy Employees Occupational Centers for Disease Control and Prevention
Niness Compensation Act Natlonal Institute for Occupational Safety and Health

| OMB Number: 0920-0639 Expires: 05/31/2007

| Spectaf Exposure Cohort Petition U.S. Department of Health and Human Services|
\
\

Special Exposure Cohort Petiti rm B.

D.1 Labor Organization Information

Name of Organization |

Position of Contact Person
D.2 Name of Petition Reprasentativg:

D.3 Address of Petition Representative:

Street : . Apt# P.O. Box

City Stat Zip Code
0.4 = Telephone Number of Petition Representative: d

D.S Email Address of Petition Representative:

D.6 Period during which labor organization represented emptoyees covered by this petition
(please attach documentation): Start End

0.7 = Identity of other labor organizations that may velvecont or have represented: this class of :
émployess (if known): '

Name or Social Security Number of First Pptitloner: _*



SEC-00090 12-19-07 Mound Plant

Plant from February 1, 1949 through August 17, 2007. The details of the petition basis are
addressed in Section 7.4.

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of
employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The
NIOSH-proposed class includes all Mound employees who were monitored, or should have been
monitored, for internal Ra-Ac-Th exposures from October 1, 1949 through February 28, 1959. The
petitioner-requested class was reduced as a result of the feasibility evaluation documented in Section
7.0. The petitioner-requested class was reduced because, except for the class above, NIOSH has
obtained sufficient information to reconstruct doses for the entire evaluation period. NIOSH cannot
estimate internal Ra-Ac-Th exposures from the arrival of K-65 sludge in October 1949 through
February 28, 1959, when the related area of work was decontaminated and decommissioned and
sufficient monitoring was in place.

4.0 _ Data Sources Reviewed by NIOSH

NIOSH identified and reviewed numerous data sources to determine information relevant to
determining the feasibility of dose reconstruction for the class of employees proposed for this petition.
This included determining the availability of information on personal monitoring, area monitoring,
industrial processes, and radiation source materials. The following subsections summarize the data
sources identified and reviewed by NIOSH.

4.1 Site Profile Technical Basis Documents (TBDs)

A Site Profile provides specific information concerning the documentation of historical practices at
the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external
dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for,
individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis
Documents (TBDs) that provide process history information, information on personal and area
monitoring, radiation source descriptions, and references to primary documents relevant to the
radiological operations at the site. The Site Profile for a small site may consist of a single document.
As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into
Mound Plant operations or related topics/operations at other sites:

¢ ORAUT-TKBS-0003, Technical Basis Document for the Savannah River Site, Rev. 01, Oak Ridge
Associated Universities; August 21, 2003; SRDB Ref JD: 20178

¢ TBD for the Mound Site — Introduction, ORAUT-TKBS-0016-1; Rev. 00; September 9, 2004;
SRDB Ref ID: 19784

© TBD for the Mound Site - Site Description, ORAUT-TKBS-0016-2; Rev. 00 PC-1; July 7, 2006;
SRDB Ref ID: 30057

° TBD for the Mound Site - Occupational Medical Dose, ORAUT-TKBS-0016-3, Rev. 01 PC-2;
March 31, 2006; SRDB Ref ID: 30059

11 of 95



SEC-00090

12-19-07 | Mound Plant

selected laboratory notebooks were thou;
However, once the boxes were reviewed

retrieved from LANL had already been at Mound in the form of microfilms or other records. The

retrieved data were only used for cross-r
containing laboratory notebooks were re}
reconstruction project. These boxes wer}

project (once scanned, the originals wer¢ packed into LSA drums ultimately shipped to NTS'for

burial). fi
4

Jn 1999, Mound Security began consolidating the classified repositories within the site as Mound
began to work towards site closure. Evehtually, all classified documents were moved to A-basement.

The combined collections (now ~1 00,00}
Two sets of the hard/drive and DVDs wi
went to OST] in 2003.

After the Non-Nuclear Reconfiguration
, the Dayton Federal Record Center.

7.4.1.8 Mound Plant Employee Health
: 1

ght to be some useful for the pre-1989 project.
by the scientist, it was determined that bioassay data

eferencing existing data. As a result of the review, 43 boxes
turned from LANL to Mound for use in the dose
e incorporated into the A-basement classified scanning

documents) were scanned using Image Alchemy software.
re created; one set was sent to NNSA/AL and the second set

nded, all remaining unclassified records were transferred to

Records Kept in Building 61

SEC00090: Mound'Plant Employee He
.and kept in Building'61 prior to their sh
that were involved with the removal and|

cin Building 61 fora period of time prior’

| 639 potentially coktaminated lab notel
imaged using Image!Alchemy Software.
Document Consolidation Project (CDCR
Emergency disposal approval was grant
ROMs which then became the official r¢
approved DOE method.

In the affidavit provided by the petitiong
controlled building [sic]. Dosimetry an
eventually eliminated | for most employee
was discovered in this building, no follo}
area.

At the time of this writing, NIOSH has
Building 61 that would impact NIOSH’:
were made to contact the SEC-00090 pe
Petition SEC-0009 lito discuss this incid
the approximate date of this issue.
|

Air concentration measurements can be
general environment, in accordance wit
(ORAUT-TKBS-001 6-4), as discussed

ith Records were removed from their storage site at Mound

ipment to the desert site.. I. was the Supervisor over the crews

shipments of these records (materials). ‘These materials sat

to their shipment to Nevada. 5 vote
tte aby

ooks were buried at NTS after they were electronically

These lab notebooks were indexed as part of the Classified

) toa Searchable Classified Records Database (SCRD).

d by NARA in August 1999. Images were transferred to CD-

cord, and the contaminated notebooks were destroyed per an

. ’
r, she also states: Building 61 was a non radiological building
other monitoring processes were systematically reduced and
is stationed in this building. When contaminated equipment
-up monitoring was provided to employees working in the

ot yet been able.to verify a contamination incident for
ability to bound the dose for the proposed class. Attempts
titioner. NIOSH was able to contact another person listed in
ent; however, this person could not remember the details or

used to assign internal doses from radioactive material in the
the Mound Occupational Environmental Dose TBD
in Section 6.3 of this evaluation. While this is an important

80 of 95 ;



SEC-00090

ee ee

12-19-07 Mound Plant

4.5 NIOSH Site Research Datalbase

NIOSH also examined its Site Research
the proposed class. There were 879 doc

atabase to locate documents supporting the evaluation of
ments in this database that were identified as pertaining to

Mound. These documents were evaluated for their relevance to this petition. The documents include
historical background on external and internal dosimetry programs and evaluations; annual, semi-

annual, and quarterly technical summary
Mound Plant; evaluations of specific bui

4.6 Other Technical Sources

reports; annual environmental reports; annual reviews of the
dings; site surveys; and facility and process descriptions.

In addition to its own Site Research Database, NIOSH also examined the following databases and

records repository:

e PORECON (Poldnium Reconstruction) Database: Mound-owned database that contains bioassay

data

¢ PURECON (Plutonium Reconstructi
data

¢ MORE (Mound Occupational Radiol]
Specific health physics records were

e MESH (Mound Environmental, Safet
~. ‘¢ontains dosimetry (internal and exte|

© Pre-1989 Dose Assessment Project:
reconstruction project on internal dog

n) Database: Mound-owned database that contains:bioassay

pgical Exposure) Records Center where original employee-
filed by employee name ion t

ly, and Health) Database: Mound-owned database that

‘nal) results, medical information, and employment history.
JW Corp., as a Mound subcontractor, conducted a dose

es received prior to 1989. The dose reconstruction efforts

resulted in two reports, Phase I and Phase II, which are owned by Mound.

4.7 Documentation and/or Affi

In qualifying and evaluating the petition,
petitioners:

Petition SEC-00090:.

© Copy of letter presented and submitt
Department of Labor, Ohio; OSA R

© Copy of Dayton Daily News (Ohio)
OSA Ref ID: 103188 (6-4-07); 1034:

© Copy of Dayton Daily News (Ohio)
Ref ID: 103188 (6-4-07); 103455 (7-

davits Provided by Petitioners

NIOSH reviewed the following documents submitted by the

d to the official,record on May 15, 2007 to the U.S.
f ID: 103188 (6-4-07); 103455 (7-20-07)

ticle, Report Says Ill Mound Workers Treated Unfairly;
5 (7-20-07)

rticle, Mound Plant Records Buried in New Mexico;.OSA
20-07) ;

16 of 95



SEC-00090

12-19-07 _| Mound Plant

TBD for the Mound Site —- Occupatioi
October 6, 2004; SRDB Ref ID: 197:

TBD for the Mound Site - Occupatio
September 9, 2004; SRDB Ref ID: 1

TBD. for the Mound Site — Occupatioi
August 11, 2004; SRDB Ref ID: 197!

4.2

An ORAU Technical Information Bulleti

guidance for preparing dose reconstructi

Procedure provides specific requirements
including preparation of dose reconstruct

reviewed the following OTIBs and proce,

OTIB: Maximum Internal Dose Esti

0002, Rev. 02; February 7, 2007; SRI

OTIB: Dose Reconstruction'from Oc
ORAUT-OTIB-0006, Rev. 03 PC-1;

OTIB: Interpretation of Dosimetry D.

Rev. 01; October'l1, 2005; SRDB Re

OTIB: Internal Dose Overestimates

0018, Rev. 01; August 9, 2005; SRDE

00; February 6, 2007; SRDB Ref ID:

OTIB: Internal Dose Reconstruction
ID: 29984

OTIB: Internal Dosimetry Coworker
June 22, 2007; SRDB Ref ID: 32524

OTIB: Calculation of Dose from Intai
-Rev. 00; April 26; 2007; SRDB Ref I

PROC: External Dose Reconstructio
ID: 29985 *

}

ORAU Technical Informat|

OTIB: Estimating Doses for Plutoniu

al Environmental Dose, ORAUT-TKBS-0016-4; Rev. 00;
9

al Internal Dosimetry, ORAUT-TKBS-0016-5; Rev. 00;
790,

al External Dosimetry, ORAUT-TKBS-0016-6; Rev. 00;
D1
on Bulletins (OTIBs) and Procedures

in (OTIB) is a general working document that provides

ns at particular sites or categories of sites. An ORAU

and guidance regarding EEOICPA project-level activities,
ions at particular sites or categories of sites. NIOSH
dures as part of its evaluation:

ates for Certain DOE Complex Claims, ORAUT-OTIB-
B Ref ID: 29947 :
upationally Related Diagnostic X-Ray Procedures,
December 21, 2005; SRDB Ref ID: 20220 :

uta for Assignment of Shallow Dose, ORAUT- OTIB-001 7,
f1D: 19434 |

r Facilities with Air Sampling Programs, ORAUT-OTIB-
Ref ID: 19436

Strongly Retained in the Lung, ORAUT-OTIB-0049, Rev.
29975

,,ORAUT-OTIB-0060, Rev. 00, February 6, 2007, SRDB Ref

Data for the Mound Site, ORAUT-OTIB-0061, Rev. 00;
|

es of Special Tritium Compounds, ORAUT-OTIB-0066,
D: 31421 \

ORAUT-PROC-0006, Rev. 01; June 5, 2006; SRDB Ref

12 of 95



SEC-00090 12-19-07 Mound Plant

The bioassay program to support the recovery/purification process of protactinium began in August
1955 (Meyer, 1992). The samples were subjected to various precipitation and dissolution procedures
to extract radium, thorium and protactinium fractions (Kirby, 1952; Kirby, 1954; Kirby, 1959). The
available protactinium data were found in a historical file within a notebook during the Pre-1989 Dose
Reconstruction Project and are now compiled in the Data Base of Excretion Data of Other
Radionuclides (ORAU 2003e).

6.1.6 Thorium-230

The bioassay program for Th-230 ran from March 1956 through September 1958. Initially, 24-hour
urine samples were collected, thorium separation was performed, and the thorium fraction was
analyzed. It appears that this process did not provide the desired results and, after about 10 samples
(about mid-May 1956), the procedure was changed to a “radium separation.” It was most likely
assumed that Ra-226 was in equilibrium with its parent Th-230; thus, all counts would be considered
ionium counts.

Primary Th-230 bioassay records consisted of a log book and duplicate records in a brown notebook
(ORAUT-TKBS-0016-5). Secondary Th-230 results included a form (Form 0-634) and then began as
weekly reports on March 17, 1958. Weekly reports included Name, Isotope, and Result. Results
reported on Form O-634 included: Name, Badge Number, Date, Type of Analysis, Isotope, and Result
(MJW, 2002, Phase 1). The Database of Ra-Ac-Th Excretion Data now serves as the repository for
these data (ORAU, 2003d).

6.1.7 .Thorium-232

The Thorium-232 Refining Program was a process intended to produce thorium salts. : These salts
were to be produced in a newly-constructed refinery and used to produce metallic thorium for the

. thorium fuel cycle of the breeder reactor. The research and development for the refining process,
known as the Monex Process, was done in the R Building. The directive to construct the required
refinery was issued in March 1955, but construction was canceled in May of the same year. Research
work on the pilot plant continued and was completed in July 1955.

Although a small number of samples were processed between 1951 and 1954, the primary urinalysis
sampling to support Th-232 refining and subsequent re-drumming of source materials began in
August 1955 and continued until November 1959.

Approximately 170 samples are available for Th-232 in the years between 1960 and 1967. A total of
25 samples are available from the years 1972, 1978, and 1979 (combined). Bioassay records indicate
that urine samples from persons involved in the Thorium-232 Program were analyzed for both radium
and thorium. The thorium is assumed to be Th-232, Th-228, and Th-230.

41 of 95



SEC-00090 12-19-07 Mound Plant

Upon request (and as applicable), the Stoller Corporation/Source One Management contracting team
provides employees’ original hardcopy records in addition to database printouts (prior to 1958), which
ensures the ability to confirm data. These hardcopy records are in the form of various preprinted
forms, cards, or reports (depending on what was in use at the time). Per Dose Reconstruction
Training, ORAUT-TRNG-0051, when performing dose reconstructions, personnel performing dose
compare available hard copy data with database printouts.

The history and general quality of available Mound monitoring record data sets are summarized in
following subsections. Dosimeter performance, bioassay procedures, and the QA/QC procedures
associated with various monitoring campaigns were quite extensive at Mound and have been
described in several documents. The ORAUT internal and external TBDs (ORAUT-TKBS-0016-5,
ORAUT-TKBS-0016-6) provide some details. Extensive details of procedures and their evolution are
contained within Meyer’s external monitoring and bioassay history documents (Meyer, 1992; Meyer,
1994). :

7.1.1 Internal Monitoring Data Review

Unless otherwise noted, the following characterizations of Mound internal data have been taken from
three documents describing work performed for the Pre-1989 Dose Assessment Project (MJW, 1998;
MJW, 2002, Phase I; MJW, 2002, Phase II). Internal monitoring data collection and assessment was a
primary goal of Phase I of that project. Below is a summary of more detailed information available in
the documents referenced above.

Plutonium Bioassay Data

The PURECON database was established in 1991 by the University of Lowell Research Foundation.
This work was undertaken to meet the requirements of DOE Order 5480.11, Radiation Protection for
Occupational Workers (DOE, 1988), which became effective January 1, 1989. A document entitled
Plutonium Historical Dose Reconstruction Program provided the historical backdrop for this effort
(Meyer and Reeder, 1992). In brief, Mound staff recognized that it needed to develop more reliable
internal dosimetry record-keeping with respect to plutonium, which resulted in building the computer
database from the original raw data.

As noted above, QA/QC and repair work has been performed on the PURECON database by MJW
during its work on the Pre-1989 Dose Assessment Project (MJW, 2002, Phase I; MJW, 2002, Phase
Il). During its initial assessment of the existing database (5% check), MJW noted that for all
PURECON records checked for errors of all types, there was an 8.2 % error rate was observed. This
was considered unacceptable because some of these errors dealt with misidentification of bioassay
data that could directly affect the results of the MJW dose screening program. Details of these checks
are provided in the Phase I Report, Volume I, Appendix II]-2 (MJW, 2002, Phase 1).

Also provided in Volume Il, Appendix A, Subpart 2 of the Phase I Report, is a memo submitted to
Mound in September 1997 with recommendations regarding assessment and repair of the entire
PURECON (and tritium) databases. The recommendations were approved and a description of the
work performed is discussed in Section II(C)(1) of Volume I. In essence, a test plan was devised that
allowed continued testing of the PURECON database against a predefined set of test conditions
(derived from a proposed Pu-screening algorithm) until a zero error condition was returned.

51 of 95



SEC-00090 12-19-07 Mound Plant
6.1.5  Protactinium-231
6.1.6 Thorium-230
6.1.7 Thorium-232
6.1.8 Substitute Materials, Radium-226, Actinium-227, and Thorium-228 Records
6.1.9 Uranium Records......l.. 42

6.3 Mound Air Sampling Data .......

6.1.10 Americium-241 and d
6.2 Mound External Monitoring ]]

7.0 - Feasibility of Dose Reconstruction
Pedigree of Mound Data.......,

7A

72

73°

74

7A

Internal Monitoring Data Review.

7.1.2 External Monitoring J
Internal Radiation Doses at M
Process-Related Inter

7.24

7.2.1.1
7.21.2
7.21.3
7.214
7215
7.2.1.6.
7.21.7
7218

Tritium........
Polonium-2]|
Plutonium
Other Radi
Other Radi
Radon
Missed Inter!
Decommissi

7.2.2 Ambient Environmen

7.23
724

Internal Dose Reconstruction ......
Internal Dose Reconstruction Feasibility Conclusion

External Radiation Doses at

73.1

7.3.2
73.3
7.3.4

7.3.5 External Dose Reconstruction Feas
Evaluation of Petition Basis for SEC-0009'
Evaluation of Major Thpics Detailed
Monitoring af Workers.
Incident Occhrrence and Reportin;
Employees Prohibited-from Receiving Monitoring

TAA

Process-Related External Radiation Doses at Mound

73.1.1

7.3.1.2 Dosimetry Records

Radiation E,

Ambient Environment
Mound Occupational

External Dose Reconstruction .

73.4.1
73.4.2
73.43
73.44
73.4.5

741.1

TAN2

TAAB

TAAA

TALS

TA16
i

lurium-244
ata

for the repose Clas:

ata Review

al Dose
ning and Decot

ial Internal Radiation Doses at Mound

ound... |
jposure Environment

al External Radiation Doses at Mound.
-Ray Examinations......

Photon Dosel.. 70
Electron Dog 70
Neutron Dos| 71
Unmonitored Individuals Working in Production Areas. 71
Medical X-ray... 72

Mound Doct

Occurrence Reporting
The “Rad” Database .

Petition SEC-0009

mentation......... |

6 of 95



SEC-00090

+ 12-19-07 Mound Plant

DOE, 1988, Radiation Protection for Oacupational Workers, DOE Order 5480.11, U.S. Department

of Energy; Washington, D.C.; SRDB R

Evaluation, 1970, Evaluation of Accidei

Counting and Bioassay Results, H. F. A

|
tal Personnel Exposures to Plutonium-238: Whole Body
derson; W. E. Sheehan; J. R. Mann; R. W. Bistline; Health

ef ID: 8073

Physics 18(6):631-639; June 1970; SRIDB Ref ID: 8752

Guido, J., 2003, Response to Beverly Li

Additional Personnel Exposure Informat
2004; SRDB Ref ID: Not currently in S)

ICRP, 1959, Recommendations of the h
Publication 2; International Commissio
England; SRDB Ref ID: 11106

ICRP, 1975, Report of the Task Group
for Radiological Protection; Pergamon

ng Concerning A Response To NIOSH Request for
ion and personnel communication with Wes Proctor, May,
DB ,

|

ternational Commission on Radiological Protection,
m for Radiological Protection; Pergamon Press; Oxford,

, |

)

n Reference Man, Publication 23, International Commission
Press; Oxford, England; 1975: SRDB Ref ID: 22735

ICRP, 1982, Limits for Intakes of Radionuclides by Workers, Publication 30, International

Commission for Rattiological Protectior
22733

ICRP, 1 987, Lung hence Risk from In
International Commission for Radiolog
available '

'
Incident Reports, 1973-81, Monsanto R}

King, 1995, Mound Site Radionuclides
Energy; Miamisburg, Ohio; 1995; SRD

Kirby, 1952, Tentative Procedure for t

m; Pergamon Press; Oxford, England; 1982: SRDB Ref ID:
| -
loor Exposure to Radon Daughters, Publication 50,

cal Protection; Pergamon Press; Oxford, England; Commonly

esearch Corporation; SRDB Ref ID: 25502 ~

by Location, W. King; MD-22153 Issue 1; U.S. Department of
B Ref ID: 3240

e Analysis of Mixtures Containing Radium-226, Actinium-227

and Thorium-228, H. W. Kirby; AEC Research and Development Report MLM-773, Mound

‘Laboratory, Miamisburg, Ohio; 1952; §

\
Kirby, 1954, Determination of Radium
Interim Report), H..W. Kirby and R. M
MLM-1003; Mound Laboratory; Miamj

Kirby, 1959, The Radiochemistry of Pr
NAS-NS 3016; Subcommittee on Radi
Council; Washington, D.C.; December.

i]
Long, 2007, Mound Records Transfer

Meyer, 1992, History of Mound Bioass|
Mound Applied Technologies; Miamis|

4
4

RDB Ref ID: 1962, page 512.

226, Actinium-227 and Thorium-228 in Human Urine (Ad
Brodbeck; AEC Research and Development Report

sburg, Ohio; ee SRDB Ref ID: 1962, page 522

tactinium, H. W. Kirby; U.S. Energy Commission Report
chemistry; National Academy of Sciences-National Research
1959; Commonly available

History, Beverly Long; January 3, 2007: SRDB ID 36234

ay Programs, H. E. Meyer; MLM-MV-93-93-0003;:EG&G
burg, Ohio; 1992; SRDB Ref ID: 1962

92 of 95



SEC-00090

12-19-07 Mound Plant

SEC-00090: Incident occurrence and c
another of radioactively contaminated

Incidents at the Mound Site were reporte
could potentially have been reported in th
Undetected or unmonitored intakes occu

completed using any'number of methods.

either co-worker data or by using the app

occurring prior to orfollowing a period
different options for ‘calculating unmonit
while helpful, is not hecessary for dose rj
ascertained, claimant- favorable assumpti
favorable assumptions may include usin,
type associated with ithe intake is not kni
higher dose; or assignment of an arbitrar}
in the maximum dose.

TALS Employees Prohibited from Rei
i:

SEC-00090: Employees working in non
i
The basic principle of dose reconstructio}
. Which:a worker ‘was exposed using avail
cases where radiation exposures in the
available data, default values based on re

as substitutes. EEOICPA recognized that the process of

dealing with uncertainties and limited dal
reasonable, claimant-favorable estimates|

itique reporting will show a pattern of one incident'afier

taterials in non-controlled areas for storage and shipment.

d in the Corrective Action Reporting System (CARS) and

¢ ORPS (DOE) system, as discussed in Section 5.4.5.

at many DOE facilities, and dose estimates can be
Estimates of the unmonitored dose can be made by using

yoximated recorded doses for a specific worker of interest

f unmonitored dose. OCAS-PR-004 describes several

pred dose in various situations. A definitive intake date,

econstruction. In cases where a definite intake date cannot be

ions may be made in lieu of specific information. Claimant-

the absorption type that results in the highest dose when the

wn; use of an intake rate (acute or chronic) based on the

date for an assumed acute intake based on a date that results

eiving Monitoring -

controlled areas were prohibited from receiving monitoring.

n is to characterize the occupational radiation environment to
able worker and/or workplace monitoring information. In,
orkplace environment cannot be fully characterized based on
asonable, claimant-favorable scientific assumptionsiare used
estimating radiation doses would require
hods were established for arriving at

e received by an individual who was not

ta, and thus, me’
of radiation do:

monitored or inadequately monitored for exposures to radiation, or for whom exposure records are

missing or incomplete. To the:extent that the science and data involve uncertainties, these

uncertainties are typically handled to the
NIOSH has used the best available scien
reconstruction. ]

4

4
For unmonitored individuals, on-site am
co-worker dose distributions are assigne

74.1.4 Mound Dodumentation

r}

i}
SEC-00090: Mound;Lab documentation
They even went so far as to send Mound
retrieve documents that he took home in
health issues. Therefore any documenta:

Tn an interview with the Records Manag

that he had taken records ‘from the site to|

bring the records back to the site where
t

|

advantage, rather than to the detriment, of the claimant.
ce to develop the methods and guidelines for dose

ient doses or claimant-favorable dose estimates derived from

as appropriate.

was very closely guarded by management and procedure(s).
security to the home of [employee’s name removed] to

un attempt to provide himself defense in the case of future
ion is only within Dept..of Energy Records. i
r at the time of this incident, she was told by the employee
his home. The Records Manager told him that he needed to
le could copy them so he could take home the copies. After

76 of 95



SEC-00090 12-19-07 Mound Plant

In addition, the document goes on to say:

Since track fading is of significance in deriving dose determinations for personnel working in our
areas with low energy neutron spectrums, calibration procedures utilizing the PuF4 sources were
devised to incorporate corrections for track fading. Dosimeter badges of personnel have always
been exchanged on varying frequencies based on the employee's degree of involvement and
potential exposure. Exchanges have been made for periods of one or more days, one week, two
weeks, and four weeks. Predominantly, most badges are routinely exchanged on either a two week
or four week basis. The calibration procedure involves the exposure of film in badges to determine
film response to known exposure for any increment of time up to four weeks. Each calibration
exercise involves exposing different sets of badges to the same total dose, but at different rates
over a four week period. All badges are processed at the same time on the Monday following the
Sour week period. We typically expose 5 sets of badges to total dose of 1.0 rem. The badges,
assuming we expose all to 1.0 rem, are exposed as follows:

Set 1 - Exposed to 250 rem per week for 4 consecutive weeks

Set 2 - Exposed to 333 rem per week for 3 consecutive weeks prior to process date
Set 3 - Exposed to 500 rem per week for 2 consecutive weeks prior to process date
Set 4 - Exposed to 1.0 rem during the week prior to the process date.

Set 5 - Exposed to 1.0 rem on the process date.

The response for each batch in tracks is plotted versus time and appropriate factors derived for
dose evaluation for any segment of time up to four weeks. In routine operations, the assumption is
made that exposures have been uniformly received by the employee during the time period the
badge was worn. Health Physics survey groups closely review scheduled operations for non-
routine special operational activities. Personnel performing special operations are monitored with
badges for the exact period of the activity and appropriate factors are used for evaluating dose
received. (Variables, 1977, pdf pages 5-6)

NIOSH concludes that NTA film sensitivity to low-energy neutrons and track fading are not SEC
issues at Mound.

74.3.5 D&D Era Bioassay

There have been concerns expressed by numerous former workers about whether the bioassay
requirements matched the exposure potential to workers during the D&D era. In addition, there were
several Price Anderson Act violations and fines during this period. NIOSH continues to investigate
whether these occurrences compromise its ability to perform dose reconstructions with sufficient
accuracy.

85 of 95


SEC-00090 i

12-19-07 Mound Plant

10.0 References

42 C.F.R. pt. 81, Guidelines ‘for Determ
Employees Occupational Illness Compe
Register/Vol. 67, No. 85/Thursday, p 22

42 CFR. pt. 82, Methods for Radiation
Occupational Iiness Compensation Pro}
19392

42 C.F.R. pt. 83, Procedures for Desig
Exposure Cohort Under the Energy Em,
2000; Final Rule; May 28, 2004; SRDB

42 U.S.C. §§ 7384- 7385 [EEOICPA], Ey
Program Act of 2000, as amended

OCAS-IG-001, External Dose Reconstr}
Safety and Health (NIOSH); Cincinnati.

OCAS-PR-004, Internal Procedures fo

!
|
ing the Probability of Causation Under the Energy

sation Program Act of 2000; Final Rule, Federal
296; May 2, 2002; SRDB Ref ID: 19391

\Dose Reconstruction Under the Energy Employees
gram Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID:

ating Classes of. Employees as Members of the Special
loyees Occupational Illness Compensation Program Act of
Ref ID: 22001

ergy Employeés Occupational Illness Compensation

ction Guideline, Rev. 2; National Institute for Occupational

Ohio; August 25, 2006; SRDB Ref ID: 29929

the Evaluation of ‘Special Exposure Cohort Petitions, Rev. 0,

Natiorial Instituté for’ (Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, ~

2004; SRDB Ref ID: ‘32022
ORAUT- OTIB- 0002; Maximum 'Internd
Oak Ridge Associated Universities; Feb

ORAUT-OTIB-0006, Dose Reconstructi
Procedures, Rev. 03 PC-1; Oak Ridge
20220

ORAUT-OTIB-0017, Interpretation of
Oak Ridge Associated Universities; Oc!

ORAUT-OTIB-0018, Jnternal Dose O'
01; Oak Ridge Associated Universities;

ORAUT-OTIB-0049, Estimating Dose
Ridge Associated Universities; Februar}

ORAUT-OTIB-0060, Internal Dose Ret
February 6, 2007, SRDB Ref ID: 29984

ORAUT-OTIB-0061, Internal Dosimet

Associated Universities; June 22, 2007:
i

4

1 Dose Estimatl for Certain DOE Complex Claims, Rev. (02;
ruary 7, 2007; SRDB Ref ID: 29947 —_

ion from Occupationally Related Diagnostic X-Ray

Associated Universities; December 21, 2005; SRDB Ref ID:

Dosimetry Data for Assignment of Shallow Dose, Rev. 01;

ober 11, 2005; SRDB Ref ID: 19434
|

erestimates for Facilities with Air Sampling Programs, Rev.
August 9, 2005; SRDB Ref ID: 19436

for Plutonium Strongly Retained in the Lung, Rev..00; Oak
6, 2007; SRDB Ref ID: 29975

construction, Rev. 00, Oak Ridge Associated Universities;

ry Coworker Data for the Mound Site, Rev. 00, Oak Ridge
SRDB Ref IDs/32524

90 of 9

- tA

\
q
{
4
t



Page 3 — The Secretary

dose monitoring continued throughout Mound’s operational history. Records of radiation
exposures from personnel dosimeters are available from the beginning of operations, and for all
years of the proposed class time period. Mound facilities and soil are unlikely to have
contributed significantly to the ambient environmental dose. The ambient environmental dose
would be accounted for in, and bounded from, the occupational monitoring data for personnel.

The health endangerment determination is governed by EEOICPA and 42 C.F.R. § 83.13(c)(3)
and § 83.14(b). Pursuant to these requirements, if it is not feasible to estimate with sufficient
accuracy radiation doses for members of the class, then NIOSH must determine that there is a
reasonable likelihood that such radiation doses may have endangered the health of members of
the class. The regulations require NIOSH to assume that any duration of unprotected exposure
may have endangered the health of members of a class when it has been established that the class
may have been exposed to radiation during a discrete incident likely to have involved levels of
exposure similarly high to those occurring during nuclear criticality incidents. If the occurrence
of such an exceptionally high-level exposure has not been established, then NIOSH is required to
specify that health was endangered for those workers who were employed for a number of work
days aggregating at least 250 work days within the parameters established for the class or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC. NIOSH has determined that members of the class were not exposed to
radiation during a discrete incident likely to have involved levels of exposure similarly high to
those occurring during nuclear criticality incidents. However, the evidence NIOSH reviewed
indicates that some workers in the class may have accumulated chronic radiation exposures
through intakes of radionuclides. In summary, NIOSH determined that it is not feasible to
estimate with sufficient accuracy the radiation dose and that the health of the proposed class of
employees may have been endangered.

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the
workers in the proposed class, NIOSH determined that it is possible to reconstruct certain
internal dose, all external dose, and occupational medical dose. NIOSH intends to use any
available, reliable data that may be included in an individual’s file (and that can be interpreted
using existing NIOSH dose reconstruction processes or procedures) to support a partial dose
reconstruction for non-presumptive cancers and/or cases that have less than 250 work days of
employment.

NIOSH is continuing to investigate whether it is feasible to estimate dose for workers from the
1990s through 2006, who were included in the petition by the petitioners.

After consideration of the NIOSH presentation, the Board voted to advise the Secretary to add
the class. The Board vote was 11-0, with one member recused due to conflict of interest. The
Board letter to the Secretary, received on February 1, 2008, is Tab E. The transcript of the Board
discussion is Tab F.

The petitioner may seek an administrative review of certain HHS decisions, either a class denial
or a 250-workday health endangerment requirement, as specified in the HHS SEC procedures
(42 CFR. § 83.18(a), Tab B).



SEC-00090 12-19-07 Mound Plant

7.3.3. Mound Occupational X-Ray Examinations

Diagnostic X-ray procedures were a contributor to the occupational radiation exposure of Mound
workers. In general, the dose from such exposures was not measured, considered, or included as part
of the overall occupational exposure of the employee, although it clearly was occupationally-related.
Diagnostic medical X-rays administered in conjunction with routine or special physical examinations
required for employment are a valid source of occupational exposure. ‘Unlike occupational exposures
incurred during normal work processes, individual diagnostic medical X-ray exposures were not
monitored, necessitating reconstruction of doses acquired in this manner. (ORAUT-TKBS-0016-3)

Mound employees received posterior—anterior (PA) chest X-rays at hiring, at specified intervals
thereafter, and at termination. In 1983, a policy modification required X-rays for terminating
employees only if they had not had a chest X-ray within the previous 9 months; this changed to 6
months in 1988. In 1988, a lateral (LAT) view was required for women known to have undergone
breast augmentations; the frequency of these examinations is not known. ORAUT-TKBS-0016-3 lists
examination frequencies over the years for different groups based on information obtained from the
Mound data files. The records returned by DOE include the occupational medical X-rays performed
for Mound employees. These are reviewed during dose reconstruction. Typically, the average
frequency is less than one per year for most employees. Typically, dose reconstructors assume annual
frequencies as an overestimating assumption. ;
Prior to 1980, details about the X-ray apparatus and technique parameters are not known and default
values were used for entrance kerma (ORAUT-TKBS-0003). Since at least 1980, the X-ray apparatus
at Mound was a stationary enclosed unit with the control panel separated from the tube head by a wall.
From 1980) through 2003, the equipment consisted of a single-phase, TWX-325 control unit with a
Eureka Emerald 125 X-ray tube, Eureka Linear IJ automatic collimator, and S&S 1417B vertical
cassette holder (VCH) used with no grid and 14- by 17-in. Kodak X-O-Matic Regular film. Actual
measurement data obtained by the Ohio Department of Health were used. ORAUT-TKBS-0016-3
summarizes technique parameters and entrance kerma for PA and LAT views, respectively. For the
period before 1980, no external collimation was assumed when converting entrance kerma to organ
doses.

Although there is no specific evidence in the history data file (Mound, 2002) to indicate the use of
photofluorography at Mound, evidence suggests that General Electric mobile X-ray units might have
been used at various U.S. Atomic Energy Commission, Energy Research and Development
Administrations, or U.S. Department of Energy sites (NCRP, 1989). A review of files from the 1940s
and 1950s reveals that when photofluorography was used, an unusually large number of X-ray
examinations would be performed in a given day. Thus, a larger than normal number of X-ray records
for a given day might be a positive indicator of the use of photofluorography. However, in the
absence of specific data on the use of photofluorography at Mound, or even that such equipment was
present on site, this analysis assumes that photofluorography did not occur at Mound. The analysis
will be performed in accordance with the guidance in ORAUT-OTIB-0006, Dose Reconstruction from
Occupationally Related Diagnostic X-Ray Procedures.

69 of 95



SEC-00090 12-19-07 Mound Plant

5.4. Radiological Exposure Sources from Mound Operations

This section discusses the potential radiological exposure present at Mound during the period under
evaluation. These sources include alpha and beta emissions, neutrons, and photons as well as a
variety of incidents and accidents.

5.4.1 Alpha

The primary alpha-particle-emitting isotopes at Mound varied from area to area depending on the
operations. Table 5-3 lists the alpha-emitting radionuclides of most concern, their radioactive
half-lives, specific activities, and primary alpha energies.

Table 5-3: Principal Alpha-Emitting Radionuclides Present at Mound

Radionuclide Half-Life Specific Activity (Ci/g) Alpha Energy (MeV)
Americium-241 (Am-241) 432 years 34 5.5 (85%), 5.44 (13%) _
Actinium-227 (Ac-227) 21.77 years 73 4.9 (0.5%, 4.95 (0.7%)
Plutonium-238 (Pu-238) 87.7 years 17 5.5 (72%), 5.46 (28%)
Plutonium-239 (Pu-239) 241 x 10" years 62x 107 5.16 (88%), 5.11 (11%).
Plutonium-240 (Pu-240) 6.54 x 10° years 23x10" 5.17 (16%), 5.12 (24%)
Plutonium-242 (Pu-242) 3.76 x 10° years 3.9 x 10 4.9 (76%), 4.86 (24%)
Polonium-208 (Po-208) 2.90 years 5.9x 10 521
Polonium-209 (Po-209) 102 years 17 4.88
Polonium-210 (Po-210) 138 days 4.5x10° 331
Protactinium-231 (Pa-231) | 3.28 x 10° years 47x 107 5.0 (79%), 4.73 (11%) _
Radium-223 (Ra-223) 11.4 days 5.1 x 10° 5.71 (54%), 5.61 (26%), 5.75 (9%
Radium-224 (Ra-224) 3.66 days 1.6 x 10 5.68 (94%), 5.45 (6%) _
Radium-226 (Ra-226) 1.60 x 10° years 1.0 4.78 (95%), 4.60 (6%)
Radon-219 (Rn-219) 3.96 seconds 13x10” 6.82 (81%), 6.55 (11%), 6.42 (8%)
Radon-220 (Rn-220) 55.6 seconds 9.2.x 10° 6.30
Radon-222 (Rn-222) 3.82 days 15x10 5.49
Thorium-227 (Th-227) 18.7 days 3.1 x10" 6.04 (23%), 5.98 (24%), 5.76 (21%)
Thorium-228 (Th-228) 1.91 years 8.3 x 10° 5.43 (71%), 5.34 (28%)
Thorium-230 (Th-230) 7.70 x 10° years 19 x 10° 4.68 (76%), 4.62 (24%)
Thorium-232 (Th-232) 14 x 10” years LI x10” 4.01 (76%), 3.95 (24%)
Uranium-233 (U-233) 1.59 x 10° years 9.5 x 10° 4.82 (83%), 4.78 (15%)
Uranium-234 (U-234) 2.45 x 10° years 62x 10° 4.77 (72%), 4.72 (28%)
Uranium-235 (U-235) 7.04 x 10° years 2.1.x 10° 4.4 (57%), 4.37 (18%), 4.58 (8%)
Uranium-238 (U-238) 4.47 x 10° years 3.4.x 107 ~ 4.20 (75%), 4.15 (25%)

29 of 95



SEC-00090 12-19-07 Mound Plant

4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related
dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1
summarizes the results of this review for the period of February 1, 1949 through August 17, 2007.
(NOCTS data available as of December 6, 2007)

Table 4-1: No. of Mound Site Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 4g9i*

Total number of claims submitted for energy employees who meet the proposed class defi
criteria (February 1, 1949 through August 17, 2007) 485*

Number of dose reconstructions completed for energy employees who meet the proposed class
definition criteria 348

Number of claims for which internal dosimetry records were obtained for the identified years in the
proposed class definition 420

Number of claims for which external dosimetry records were obtained for the identified years in the
proposed class definition 430

Number of claims for which some internal and some external records were obtained for the identified
ears in the proposed class definition.. . 412

* Out of a total 485 claims, five have not yet received a dosimetry response from the site; therefore, we are assuming 480
total submitted claims.

There are 485 Mound claims with some employment between the years of 1949 and 2007. However,
five claims have not yet received a dosimetry response from the site; therefore, only the 480 claims
that have received a dosimetry response from the site were reviewed for this evaluation. NIOSH
reviewed each claim to determine whether internal and/or external personal monitoring records could
be obtained for the employee. As indicated in Table 4-1, NIOSH has been able to obtain internal
monitoring data for the majority of the claims that met the proposed class definition. Of the total
number of claims submitted, 420 (88%) have internal monitoring data and 430 (90%) have external
monitoring data.

The dose reconstruction claimant interviews (CATI) conducted with the claimants provide some
detailed information regarding work locations, hours worked, incidents, and hazards encountered.
The interviews also identified conditions for which there would have been potential for either internal
or external exposures.

15 of 95



SEC-00090

¥

7.2.1.7__Missed Internal Dose

Missed dose is calculated using bioassay
that could have been received, but were n
cases for Mound). Missed dose is assign|
each radionuclide and the bioassay meth
(ORAUT-TKBS-0016-5). Missed dose i
have been received, but for which no dos|
“unmonitored dose.” Some employees m
material. Doses for these individuals ma’
reports on Mound research, measured air

Mound Plant

\data specific to individuals and represents dose from intakes
lot detected by the bioassay method used (urinalysis in most
ed based on the minimum detectable amounts (MDAs) for

d listed in the Mound Occupational Internal Dosimetry TBD
applied only for monitored individuals. Doses that may

k monitoring was performed, are more properly termed

jay have received unmonitored exposures to radioactive

be bounded using process information in the technical
concentrations, jor a combination of the two.

mination

7.2.1.8 Decommissioning and Deconta:

Contractors responsible for performing d
and implementing radiation control progr,
These contractor programs included prov!
exposures. The potentials for radiation &

commissioning activities were responsible for developing
‘ams consistent with DOE requirements in 10 CFR pt. 835.
sions to monitor external and internal personnel radiation
posure during decommissioning were generally

significantly less than those during Mound production operations, and monitoring programs were

commensurate with the specific decommi

air monitoring, bioassay, and external ex,

provided to the contracting DOE office a1
« external and internal dose monitoring rest
+ can be extensive in terms of the number

:

ssioning operation being performed. Data collected’ included
osure monitoring. Personnel monitoring results were

d included in individual:claim files and comprise the

ults for each individual. The internal data for these personnel
if radionuclides for which bioassay was conducted.

7.2.2. Ambient Environmental Internal Radiation Doses at Mound

Unlike some of the other major DOE faci
site-wide ambient contamination, and thei
related to ambient working conditions. Nj
for purposes of assessing internal radiatio}

dose reconstructions. Except for some da

considered a viable approach due to unkn
actual breathing zone’ air concentrations.
available monitoring data for those perso
ambient/environmental doses. Further ev}
for this evaluation report. In any case, th
in broadly-dispersed record sources.

ities, Mound did not generally experience significant

‘e was less concern about the potential for internal dose
levertheless, the |use of facility ambient air monitoring data

in doses was evaluated for purposes of performing EEOICPA
ita for airborne radon and tritium, use of these data was not
own factors potentially affecting the representativeness of
Personnel ambient exposure/dose is accounted for in the

nel and these data can be used to bound the

pluation of these exposures was not performed or required
existing Mound air monitoring data are currently.contained

64 of 95



Special Exposure Cohort Petition
under the Energy Employees Occupational
Hiness Compensation Act

Special, Exposure Cohort Petitio
Soar

Complete at teast one of the following entries
the required information related to the selectio!

F.4

monitoring.
(Attach documents and/or affidavits]

Describe as completely as possible!
documentation and/or affidavit(s) In

(We have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation dbses potentially Incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area

Centers for Disease Control and Prevention:
National Institute for Occupational Safety and Health

Expires: 06/31/2007,
Page 5 of 7

{
US, Denartner of Health and Human Services

OMB Number: 0920-0639

in this section by bhecking the appropriate box and providing
. You are not required to complete more than one entry.

to the back of the petition form.)
to the extent it might be unclear, how the attached.
icate that potential fadlation exposures were not monitored.

The NICSH site profile appears to make mary assumptions kegarding ezposure assessment which each

carry with them a degree of uncertainty and potential error. Of note are the reported'high
temperature processing procedures invoiving both Plutonium, Thorium and Polonium isotcpes. ©

for those for whom any exposure data ia a

lenvironmentsl monitoring data are sufficient fox individual dose characteriszations without

several assumptions and extrapolations reg
addition any application of more recent
underestimate exposures given the prgressil
lproduction technologies. in this same vein
administrative procedures used for exposur
accurate nor consistent.: | Deficiencies in

jailable, 4t appears that neither biomonitoring no.

jacding bioavailibility, absorbtion and excretion. In
pesure daat to|older situations is quite likely to

ly we beliave that the health physics technologies and
2 assesement in the earliest years were neithar

dose astimations are expected and tod many assumptions

and extrapolations
F.2D We have attached
radiation monitoring records for me!
destroyed; or that there Is no informs
from the site where the employees

(Attach documents and/or affidavits

Describe as completely as possible,
documentation and/or affidavits) in
proposed class have been lost, alter

bers of the Proposed class have been lost, falsified, or
tion regarding monitoring, source, source term, or process %
orked.

to the back of the! petition form.)

to the extent it might be unclear, how the attached
licate that radiation monitoring records for members of the
ied illegally, or destroyed.

‘The Mound facility reportedly sent 45}

‘Alamos as a health hazard. One cant

|hygiene at the fa

1993. these records were found to b¢ contaminated with radiation and buried at Los

The most significant fact being that these records wete considered a health threat
from uptake of radioactive particulate, This does not speak well for the historical:

8 boxes of plantirecords to Los Alamos in

jot but guess what these records contained.

i
|
J.

Part F is conti

nued on the following page.

Name or Social Security Number of First Petitio

ner:

ve improvements in engineering controls and changes in



re

Special Exposure Cohort Petition
under the Energy Employees Occupational |
lliness Compensation Act

Special Exposure Cohort Petition — Form |
ST =

U.S. Department of Health and Human Services

OMB Number: 0920-0639

Centers for Disease Control and Prevention
‘National Institute for Occupational Safety and Health

Expires: 05/31/2007
Page 1 of 7

General Instructions.on Completing this Fy

Please read each of Parts A — G in this form}
than one petitioner, then each petitioner shoul
to them. Additional copies of the first two pag
pose.. A maximum:of three petitioners Is alloy

If you need more spade to provide additional
the form and attach the completed continuati

{f you have questions about the use of this fo
request to speak to someone in the Office of
1-800-356-4674.

ed.

Information, use thi
in page(s) to Form

Compensation Anal

prm (complete instructions are available in a separate packet):
Except forsignatures, please PRINT all information clearly and heatly on the form,

and complete the parts appropriate to you. If there is more
ld comptete those sections of parts A—C of the form that apply
les of this form ~— atthe end of the form for this pur-

im, please call the following NIOSH toll-free phone number and

continuation page provided at the end of
B:

lysis and Support about an SEC petition:

OA Representative (of a current

QA Labor Organization, I Start at D. on Page 3.

ityou An Energy:‘Employee (current pr former), + | StartatC on Page.2

are: xX} A Survivor (of a former Energy| Employee), StartatB on Page2
Start at A

lor former Energy Employee),

on Page 1

petition by the survivor(s) or employee(s) Indicated In,

Ad Are youa contact person for an organization? Yes (Gor t0A.2) i No (Go to A.3)
A2 Organization Information: i
Name of Organization
Position of Contact Person
A3 Name of Petition Representative:
Mr/MrsJMs, First Name Middle Initial Last Name
A4 Address: !
Street ; _ Apt# P.O. Box
City ‘ State Zip Code
AS  Télephone Number: L
A‘6 Email Address: |
A7 OQ Check the box at left to Indicate you have attached to the back of thls form written authorization to

Parts B or C of this form. An authorization

Name or Social Security Number of First Petiti



SEC-00090

12-19-07 | Mound Plant

whether an estimated unmonitored ia will be necessary to bound doses for organs sensitive

to non-penetrating radiation (i.e., ski

breast, testes, lip). NIOSH is confident that with the

existing data, appropriate neutron-to-photon ratios cat be determined to provide a bounding dose

estimate. '

¢ Plutonium Processing: Plutonium pracessing also resulted in mixed-field doses from photons and
neutrons. Since Pu-238 was used as & heat source rather than as a neutron source (in the primary
processing operation), neutron dose arose from alpha-n interactions of plutonium and its
compounds. Most processing took place after the health physics program began reading and
recording non-penetrating dose from |beta and low-energy gamma radiation, so doses are measured

for the most exposed workers.

7.3.1.2 Dosimetry Records

Records of radiation exposures from personnel dosimeters are available from the beginning of

operations, and for all years of the propo:

ed class time period. The MESH database serves as the

primary electronic repository for these records. As discubsed in Section 6.1, annual measured doses

are available for all monitored employees.

‘

7.3.2 Ambient Environmental Extern
The ambient environmental external dosd
outside operational facilities,:such as pro!

(Guido, 2003;'Meyer; 1994)

al Radiation Doses at Mound
|

is the occupational dose'received by individuals while
ess buildings. External dose from radioactive materials

outside the body may be the result of dirgct radiation from radioactive materials in soil; from adjacent

Operational facilities and waste storage at
effluent releases, and‘from re-suspension|
TBD (ORAUT-TKBS-0016-4) and Occuj
(ORAUT-PROC-0060) provide the histo:
occupational environmental doses for uni
above-mentioned references is that Mout
significantly to the ambient environment:

leas, from submersion in air containing radionuclides from
from soil. The Mound Occupational Environmental Dose
pational Onsite Ambient Dose Reconstruction for DOE Sites
ic background, rationale, and data for reconstruction of
jonitored personnel at Mound. The conclusion from the
facilities and éoil are unlikely to have contributed

I dose. In addition, the TBD evaluates external doses from

submersion in air containing radionuclides released in effluents and in resuspended site soil. The

annual effective air-submersion external
period 1949 through 2002 were less than

xposures from all radionuclides in these sources during the
5.0E-10 Sv (ORAUT-TKBS-0016-4). The conclusion of the

TBD is that submersion dose from effluents is insignificant and does not need to be considered in dose
reconstruction. The ambient environmental dose would be accounted for, and bounded from, the
occupational monitoring data for personnel; therefore, further evaluation of the ambient environmental

dose is not necessary in this evaluation.

68 of 95



Special Exposure Cohort Petition
under the Energy Employees Occupational
Wess Compensation Act

St

josure Cohort Petition — Forn}

Name of Survivor:

Department of Health and Human Services|
Centers for D:sease Control and Prevention

National Inst tute for Occupat.ona Salety and Heath
OMB Number, 0920-0639 Expires: 05/31/2007
7 . ‘Appendix -— Petitioner 3

US,

B.1 '

Mr./Mrs./Ms. First Name | Middle Initia! Last Name
B.2 Social Security Number of Survivor:
8.3 Address of Survivor: :

Street. | Apt # P.O, Box

City i State | Zip Code
B.4 Telephone Number of Survivor: d H
B.5 ° Emall Address of Survivor:
B.6 _—Relatlonship to Employee: ( Spouse Q -Son/Daughter O Parent

( Grandparent Q, Grandchild
a 7 - EE
jee 0tO,Fart C,
ployeéiinfo 6 ) tio

C.1. Name of Employee; ( | ae —
| Minis IMs, Firet Name Middle Inigel Tast Name
C2 Former Name of Employee (e.g., maiden name/legal name change/other): ‘

Mr/Mrs./Ms. ‘First Name Middlé times Last Name ‘
C.3  Soctal Security Number of Employe_. _— | -
C.4 Address of Employee (ff living): — | - ian i 4 ’

Street aa ht ag Apt P.O. Box

City. : State ue | Zip Code
C.5 Telephone Number of Employee. pre pi een | =
C6 . Email Address of Employee: Wa Le i
C.7 _ Employnient Information Related to Petition:
C.7a Employee Number (if known): _
C.7b Dates of Employment: Start & end -Oan, |, 1987
C.7c Employer Name: Wen wseay ch lo 2

\
C.7d_ Work Site Location: Vile un cp Lab . — :
Bhleamisburg, Chirag  S¢e3ei
+ a : 7t<
C.7e Supervisor's Name: ' H
Sign Patt G of the original petition.

Name or Social Security Number of First Pet

tioner:



SEC-00090

12-19-07 Mound Plant

74.1.5 Occurrence Reporting

SEC-00090: The (DOF) (ORPS) Occurri
historic data. It is of course ‘ “not” an o;
to the desert due to being radioactive:
fi

Incidents at the Mound Site were reportd
potentially have been reported in the OR!
with the employee metry records. Ri
complete diseussionjon the buried record

1416 The “Rad” Database
SEC-00090: The “rad” data base whic!
of the data that doestexist has no value.
The Mound Site has used several databa:
external employee doses. Databases’ suc|
the External Exposure Analysis System
all merged into the Mound Environment
September 1989.
application forms or:via a number of aut
contains the following information:

Internal exposure data (ES&H): 194

Safety data (ES&H): 1979-2003
Environmental data (ES&H): 1992-1
‘

Employee data (AR): 1944 -. present (in\various levels of detail)
External exposure data (ES&H): 1947 — present (in various levels of detail)

ence reporting and processing system will contain some
en record. These records were removed from the Mound site

id in the Corrective Action-Reporting System and could
IPS (DOE) system. In addition, incident reports were filed
egarding the buried records, refer to Section 7.4.1.7 for a

Ss.

did exist was not a well designed software and the integrity ,

es over the course of its history to record both internal and

h as PORECON and PURECON for internal exposures, and
EXAS) and External Radiation Analysis Data (ERAD), were
al, Safety, and Health system (MESH) database as of

is accomplished either via manual entry of data using

mated data upload procedures within the application. ‘MESH

ari

~ present (in various levels of detail)

Medical data (ES&H) 1990s only: same audio data from 2000-2002

995 only

See Section’6.0 for a full discussion on data integrity.

f)
7.4.1.7_Mound Plaht Employee Health

Records Removed to LANL

SEC-00090: Mound ‘Plant Employee He

from the Mound Plaht site in 2005 and b;

and permission of | the Dept. of Labor (E1
contamination. I

NIOSH and the ORAU Team have revie|
interviewed three former workers involv}
two former Mound Records Managers al

Ith Records are not available. These records were removed
ried in the Los Alamos, N.M. desert without the knowledge

ergy Compensation Program) due to radioactive

ed existing documentation relative to this concern, and
ed with the records transfer to LANL. These workers include

d a researcher who reviewed the records. In addition,

NIOSH reviewed thé Mound Records Tr nsfer History (Long, 2007), which discusses the Mound

Records Transfer Hi8tory. Based on its

investigation, NIOSH has determined that the records did not

contain data’related fo employees’ healt records that would prevent the.reconstruction of doses with

sufficient accuracy. {
}

78 of 95



Tab F

Transcript of relevant Board discussion at Board Meeting



SEC-00090 12-19-07 Mound Plant

Table 5-2: Chronology of Significant Mound Laboratory Programs and Events
(Table 5-2 spans three pages)

Year Activity

1989 | Removal of soil contaminated with uranium near Building 34.

1990__| Pu-238 decontamination of inactive laboratories in the R Building.

1991 | Removal of Pu-238-contaminated waste line connecting the HH Building with the WD facility.

1993 | DOE decision to transfer defense mission from Mound
 Pu-238 decontamination of PP Building 38 and Acid Leach Field (Area D).

1994 | Demolition of SM Building structure contaminated with Pu-238.

1995- | Decontamination and decommissioning of approximately 116 contaminated structures and 400 contaminated land
2006 areas

2006 Remediation of final Mound Plant site land areas (OU-1 Landfill, PRS 441 Rail Yard, and sanitary waste
treatment system) initiated

5.2. Mound Functional Areas

The following subsections describe the key functional areas of the Mound Plant. The source for most
of the information below is ORAUT-TKBS-0016-2, which provides additional information regarding
Mound functional areas.

5.2.1 Polonium Research and Production

Polonium research and production activities conducted at the Dayton Laboratory benefited from
improved facilities at the Mound site specifically designed for those processes. These included the
encapsulation of the process in purpose-designed process equipment with provisions for remote
operation. A detailed description of this equipment is included in an unpublished chapter of the book
Polonium by H. V. Moyer (Mound Po, various dates; Polonium, 1956). The controls used
concentration cells to perform worked that had been performed at the Dayton Laboratory in open-
faced hoods.

In 1954, Mound began using Po-210 to produce thermoelectric energy. The first RTG was produced
in 1958. Po-210 was primarily produced by neutron irradiation of naturally-occurring Bi-209 slugs to
produce Bi-210 via a (n, y) reaction followed by beta decay to Po-210. Prior to 1956, Mound’s first
primary mission was to manufacture initiators for nuclear weapons. This included the extraction of
Po-210 from neutron-irradiated bismuth slugs and beryllium-machining operations. Po-210 was also
used in the first Space Nuclear Auxiliary Power (SNAP) program in 1961. Mound polonium research
and production was gradually phased out in 1971.

5.2.2. Plutonium-238 Research and Development

Pu-238 research and development activities began at Mound during the mid-1950s. Pu-238 research
programs were transferred from Lawrence Livermore National Laboratory to Mound in 1959. The
first production of metallic Pu-238 was achieved in the spring of 1960. The research and development
(R&D) activities were directed toward the development and production of stable RTGs. More than
500 RTGs were produced for a variety of applications, including electric power generation for
satellites, life support systems, spacecraft, pacemakers, and an artificial heart. The first SNAP

21 of 95



SEC-00090 12-19-07 Mound Plant

contained within them (see Section 7.1.1 for more details). The boxes contained photocopies,
printouts, and excerpted or redacted formerly-classified laboratory notebooks. The record copies of
the returned notebooks were scheduled, imaged, indexed with the Document Control classified
collection, and included in the hard drive and CD shipments. Two sets of the hard drive and CDs
were created; one set was sent to NNSA, and the second to OSTI in 2003. LANL was to image the
remaining 415 boxes of contaminated, classified documents to make them available electronically.
Per the Records Manager at the time, LANL never received the DOE funding to image the collection.
In 2002, the DOE OFO General Counsel informed the BWXT Records Manager that LANL had
requested approval to destroy the collection, but no further communication regarding the subject was
located. DOE/LM recently received documentation validating the request and authorization for
destruction of the collection.

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00090

The following major topics were detailed in Petition SEC-00090. Italicized statements are from the
petition; the comments that follow are from NIOSH. Please note that the petitioner made statements
in the petition, attached a letter that was included in the petition, dated May 15, 2007, and provided an
affidavit. All three of these comments made by the petitioner covered the same issues, but were
worded differently. One wording was chosen to answer the issue of concern.

7.4.1.1 Monitoring of Workers

SEC-00090: Mound developed a culture of haphazard, administrate [sic] very controlled monitoring
of workers with regard to the employee input. [Another similar statement was made in a letter dated
May 15, 2007, and attached to the petition. It reads:] Monitoring of potentially radioactive materials
and Mound Plant Employees was done in a haphazard way, with changing criteria almost daily.
Monitoring of personnel via dosimeter, urinalysis, etc. was even more sporadic and eventually
administratively denied to all except those employees chosen by “Rad Control”. In place
Administrative Controls prohibited the collection of Radiological data for most all Mound employees.

Historical documents exhibit an on-going program of evaluation and modification of the internal and
external monitoring programs. Changes were made to the program based on changing workplace
conditions and resulting changes in the character of the potential exposures. Changes were also made
to take advantage of new technology in order to obtain more accurate measurements. Finally, changes
were required over the years to ensure compliance with contractual radiation safety requirements and,
later, with federal radiation safety regulations. Data are available in archived records and, in most
cases, electronic databases containing transcription of the archived records. Information sources
include film badge and TLD readings, air monitoring data, and results from bioassay programs, nose
swipes, fecal analyses, whole-body counts, and chest counts. There have been concerns expressed by
numerous former workers about whether the bioassay requirements matched the exposure potential to
workers during the D&D era. In addition, there were several Price Anderson Act violations and fines
during this period. NIOSH continues to investigate whether these occurrences compromise its ability
to perform dose reconstructions with sufficient accuracy.

7.4.1.2 Incident Occurrence and Reporting

75 of 95


SEC-00090 12-19-07 Mound Plant

Plutonium data are now readily available from the PURECON database. The PURECON database
was established in 1991 by work performed by the University of Lowell Research Foundation. This
work was undertaken to meet the requirements of DOE Order 5480.11, Radiation Protection for
Occupational Workers (DOE, 1988), which became effective on January 1, 1989. In brief, Mound
staff recognized that it needed to develop more reliable internal dosimetry record-keeping for
plutonium; this resulted in the construction of a computer database from the original raw data.
Subsequent QA/QC and repair work on the PURECON database has been performed (and
documented) by MJW during its work on the Pre-1989 Dose Assessment Project (MJW 2002, Phase 1;
MJW, 2002, Phase II).

_A summary of the number of records/year applicable to the proposed class time frame is presented in
Table 6-4.

Table 6-4: PURECON Plutonium Record Summary

Year 1956 _| 1957 | 1958 | 1959 | 1960 | 1961 | 1962 | 1963 | 1964 | 1965 | 1966 | 1967
Records |__78 95 81 98 343 808 | 1,454 | 2,267 | 2,797 | 3,632 u 3,718

Year 1968 | 1969 | 1970 | 1971 | 1972 | 1973 | 1974 | 1975 | 1976 | 1977 | 1978 | 1979
Records | 3,299 | 2,699 | 2,642 | 2,384 | 2,804 | 2,312 | 2,093 | 1,573 | 1,160 | 1,322 | 1,365 | 1,238

Year 1980 | 1981 | 1982 | 1983 | 1984 | 1985 | 1986 | 1987 | 1988 | 1989 | 1990 | 1991
Records | 1,227 | 1,250 | 1,276 | 1,380 | 1,388 | 1,422 | 1,318 | 939 926 | 1,112 | 1,562 |

6.1.4 Radon Isotopes

Sources of radon (Rn-222), thoron (Rn-220), and actinon (Rn-219) were present at Mound due to
radium and thorium processing and separation of Pa-231 and Ac-227. Thorium sludge from Th-232
extraction and purification operations was stored outside in drums from 1954 to 1966. In 1966,
thorium sludge stored in individual drums was transferred to storage basins in Building 21. The
thorium was re-drummed and removed from Mound in 1974 and 1975. In 1975, 1,258 drums of
Cotter Concentrate were stored to support purification of Pa-231 and Th-230. Table 6-5 shows the
results of various radon surveys at Mound.

39 of 95



Special Exposure Cohort Petition
under the Energy Employees Occupational
iness Compensation Act

Special Exposure Cohort Petition — F

jorm B

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Page 7 of 7

Public reporting burden for this collectior
including time for reviewing instructions,
have any comments regarding the burda
including suggestions for reducing this b}
Road, MS-E-11, Atlanta GA, 30333; ATT
address. Completed petitions are to be
Persons are not required to respond to tt
valid OMB number.

In accordance with the Privacy Act of 19)
following:

The Energy Employees Occupational Ili
(EEOICPA) authorizes the President to
Special Exposure Cohort (SEC). EEOIC!
assistance of the National Institute for O
Control and Prevention. Information obta
classes of employees in the SEC will be
Board on Radiation and Worker Health 4

Records Containig identifiable informati
Privacy Act, 09-20-147 “Occupational Hq
HHS/CDC/NIOSH.” These records are ti
Disclosures that NIOSH may need to mal
below.

NIOSH may need to disclose personal i
agencies, other government or private
retrieve records required by NIOSH; (b) i
individuals can provide information to as:
NIOSH; (d) collaborating researchers, ur
(e) Federal, state and local agencies for
Congressional staff member in response|

This notice applies to all forms and inforr

with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and
forms is mandatory for the consideration
provide required information may not be

ae

Public Burden Statement

of information is estimated to average 300 minutes per response,
gathering the information needed, and completing the form. If you
In estimate or any other aspect of this collection of information,

lirden, send them to CDC Reports Clearance Officer, 1600 Clifton

N:PRA 0920-0639. Do not send the completed petition form to this
lubmitted to NIOSH at the address provided in these instructions,
¢ information collected on this form untess it displays a currently

visement

74, as amended (5 U.S.C. § 552a), you are hereby notified of the

Privacy Act Ad

less Compensation Program Act (42 U.S.C. §§ 7384-7385)
esignate additional classes of employees to be included in the

A authorizes HHS to implement its responsibilities with the
cupational Safety (NIOSH); an Institute of the Centers for Disease
ined by NIOSH in connection with petitions for including additional
lused to evaluate the petition and report findings to the Advisory

ind HHS: :

in become part of an existing NIOSH system of records under the
falth Epidemiological Studies and EEOICPA Program Records.
pated in a confidential manner, unless otherwise compelled by law.
ke for the processing of your petition or other purposes are listed

tifying information to: (a) the Department of Energy, otherfederat
ies and to private sector employers to permit these entities to
Hentified witnesses as designated by NIOSH so that these

‘ist with the evaluation of SEC petitions; (c) contractors assisting
der certain limited circumstances to conduct further investigations;
law enforcement purposes; and (f) a Member of Congress ora

to a verified Inquiry. .

national requests that you may receive from NIOSH in connection
|

) is voluntary but your provision of information required by these
lof a petition, as specified under 42 CFR Part 83. Petitions that fail to
considered by HHB.

Name or Social Security Number of First

oF

4

L_

Petitioner:



SEC-00090 . 12-19-07 Mound Plant

e Research on metal tritides and tritium targets

¢ Recovery and purification of tritium from waste generated by Mound and other DOE sites
¢ Research into production of alternative reactor fuels such as thorium

¢ Research and development of the joining of exotic metals

« Research and development of technologies for radioactive waste management

The potential internal sources would have been dependent on the operational area and activities. The
major sources of intakes have been polonium, plutonium, and tritium. Bioassay monitoring was
typically conducted for the radionuclides determined by the site radiation protection program to be of
primary dosimetric concern.

Mound listed the following radionuclides as primary radionuclides because they could deliver
relatively high doses to human receptors, had widespread use at the site in multiple buildings and
facility processes, and had sufficient site documentation to evaluate internal dosimetry. Tritium was
included due to potential absorption via hydrogen exchange across the skin barrier. (ORAUT-TKBS-
0016-5)

© Po-210 ; © Pu-241*
“e Pu-238 © Pu-242*
“e Pu-239 . e Pa-23]1
© Pu-240* © H3

* Pu-240, Pu-241, and Pu-242 are not dosimetrically significant.

Radionuclides of secondary concern to Mound staff were assessed with limited internal dosimetry
data due to the limited worker exposures. Short-lived radioactive gases and their respective daughter
products were generated at Mound by activities involving uranium and thorium chain extraction and
separation activities, as well as by the manufacturing of sealed sources. Exposures to these gases were
minimized by a ventilation system installed in 1980 and were largely restricted to the SW building
where radium and actinium work took place. The following are the secondary radionuclides in
addition to daughter products from the uranium and thorium decay chains:

« Am-241 © = U-233

© = Cm-244 © = Th-232

© U-238 ¢ = Th-230

e U-235 © = Th-228 ;
© U-234

Comparison results to quantify “short” and “long-lived” radionuclides or specific measurements of
-“Short-Lived Daughter Products” are contained in health physics periodic reports starting in March
1952.

57 of 95


The Secretary established the health endangerment determination for the class of
employees covered by this report based upon the findings summarized below.

(1) Pursuant to 42 C.F.R. § 83.13(c)(3), NIOSH established that there is a reasonable
likelihood that such radiation doses may have endangered the health of members
of the class. Pursuant to 42 C.F.R. § 83.13(c)(3)(ii), NIOSH specified a minimum
duration of employment to satisfy this health endangerment criterion as “having
been employed for a number of work days aggregating at least 250 work days
within the parameters established for this class or in combination with work days
within the parameters (excluding aggregate work day requirements) established
for one or more other classes of employees in the Cohort.”

(2) NIOSH did not identify any evidence from the petitioners or from other resources
that would establish that the class was exposed to radiation during a discrete
incident likely to have involved exceptionally high-level exposures, such as a
nuclear criticality incident, as defined under 42 C.F.R. § 83.13(c)(3)(i).

(3) The Board concurred with NIOSH’s finding that the health of the class may have
been endangered and defined the class according to the 250-workday requirement
specified under 42 C.F.R. § 83.13(c)(3)(ii).

Vv. Effect and Effective Date of Designation

The Secretary submits this report on the designation of one additional class to the
SEC for review by Congress, pursuant to 42 U.S.C. §§ 7384/(14)(C)(ii) and
7384q(c)(2)(A), as amended by the Ronald W. Reagan National Defense
Authorization Act for Fiscal Year 2005, Pub. L. No. 108-375 (codified as amended in
scattered sections of 42 U.S.C.). Pursuant to 42 U.S.C. § 7384/(14)(C)(ii), as
amended by the Ronald W. Reagan National Defense Authorization Act for Fiscal
Year 2005, Pub. L. No. 108-375 (codified as amended in scattered sections of 42
US.C.), the designation in this report will become effective 30 days after the date of
this report’s submission to Congress “unless Congress otherwise provides.”

VI. Administrative Review of Designation

The health endangerment determination of the designation provided in this report
may be subject to an administrative review within HHS, pursuant to 42 C.F.R. §
83.18(a). On the basis of such a review, if the Secretary decides to expand the class
of employees covered by this designation, the Secretary would transmit a
supplementary report to Congress providing the expanded employee class definition
and the criteria and findings on which the decision was based.

HHS Special Exposure Cohort Designation:
Mound Plant



SEC-00090 12-19-07 Mound Plant
Table 6-5: Radon Ikotope Survey Data by Building and Period
Survey Gas concentration (pCi/I) WLM yr
Building dates Radon Thoron Actinon WL &
SW Tunnel 10/12/79 88,000 28,000 640,000
SW19 before vent 6/79-10/79 67-1160 :
SW19 after vent 3/80-4/80 7743.4 0.03 0.4
12/89 2.6 Not
Detected
12/99 1.045.8° |
4/00 0.747.2
1998-2000 5.8412
sw2l 5/83 17.5-52.8 * i
12/89 34-18 | 0.3-0.7 | 0.4-1.3. | 4.7-15.3
4/90-6/90 117-161 0.85 10.0 median
125 median :
sw22 6/90 125
Sw4s8 12/89 32
Old SD 12/89 1,512.4
Fire station 12/89 1.2114 |
Paint shop 12/89 0,941.2 |
A y 10/88-2/89 0.151.1
All other buildings 12/89 4 |}. 0.4-0.9
Outside facilities" 5/83 0.24-0.59 ad
Reported background 0.1 to 2.1 i
. Avgrage = 0.5 |

a. Working level months per year (WIM yr") were
b.' Bolded conceritrations were derived from charcoal

The following radionuclide-specific prog:
collected during work performed for the
otherwise, the source first summarizing tl

|
letermined as WL (2000 hr yt!) (1/170 he WLM),
canister measurements.

am and internal data availability information was initially
re-1989 Dose Reconstruction Project. Unless noted
e information presented below is the “Other” Radionuclides

Position Paper contained within the Phase II final Report (MJW, 2002, Phase II). Available bioassay

data for the following radionuclides have
Excretion Data of Other Radionuclides ((
(ORAU 2003e).

6.1.5  Protactinium-231

Programs involving the recovery and purifi

been compiled into Excel spreadsheets titled Database of
RAU 2003d) ahd the Database of Ra-Ac-Th Excretion Data

ification of Pa-231 began in the early 1950s and continued

intermittently to September 1979. The initial campaign ran from August 1954 through October 1958

and used a Mallinckrodt raffinate known
Pa-231 used another type of residue from
material had been identified as a useful s

as “Sperry Cake” as a feed material. Later efforts to recover
the uranium refining process called Cotter Cake. This
urce of radionuclides during research associated with the

Ionium (Th-230) program. One thousand, two-hundred-fifty-one drums of this material were received

during 1975 for processing in the pilot pl.
1979, during which 22 drums were proce:

nt built in the SW building. This plant ran from 1974 to
sed to recover 339 g of Th-230 and 890 mg of protactinium.

40 of 95



SEC-00090 12-19-07 | Mound Plant
Table 6-6: Summary of External Monitoring Data in the MESH Database
E iTable 6-6 spans two pages)
Year Number of Workers Number of Records Number of Beta
Monitored | Available* Records?

1989 4386 \ 15769 386
1990; 4191 14947 127
1991 i 4227 13151] 166
1992 5036 _ 12958 42
1993 7589 |__24374 24
1994 6294 17571 18
1995 2246 6182 22,
1996 1325 | 4478 133
1997 : 1056 |, 3488 125

1 1998 947 | 3112 32
1999 1017 ' 3617 84
2000 978 a 3117 7
2001 846 | 2617 12
2002 781 | 2419 29
2003 603 | 898 0
2004 70 : 158 3
2005 : 58 | 14 OL e

ay. oye : :
Prior to 1977, only individual.annual summaries are available; therefore, the number of records equals the number”

of employees. After 1977, dosimeter readigs are available. Records typically include both photon and neutron
measurement results. *

> The number of beta records represents the number of results where the beta dose is greater than the recorded deep
dose for a given dosimeter.

‘ 46 of 95 |



Tab A

Designation of a Class of Employees to the Special Exposure Cohort



SEC-00090

12-19-07

Mound Plant

The letter, as written! by the petitioner, c:
103188).

_ SEC petitions 00090'and 00091 were me
disposal at LANL and NTS. The Histor
records history and the records disposal

In November 1989, the U.S. Environmer
National Priorities List (CERCLIS No. G
Mound Site under the DOE Weapons Cg
effort to realign the Weapons complex in}
was to maintain the stockpile while retai
past missions were transferred to various
Records Administration (NARA)-appro
City Plant, Savannah River Site, Los Ala
associated DOE Operations and Field Off
Scientific and Technical Information (O:
Na

Mound Data Buried at the Nevada Test

TI).

ite (NTS)

1

There are 1,639 potentially- -contaminate:
electronically imaged sing Image -Alch¢
the Classified Docurhent Consolidation F
(SCRD).: Emergency disposal approval
transferred to CD- ROMs which then bec;
destroyed per an approved DOE method

Mound Data Buried at the Los Alamos.

my ‘Software.

In be found in petition SEC-00090 (OSA Ref ID:

ged. Both petitions listed concerns regarding records
of Mound (Long, 2007) provides in-depth review of the
t LANL and NTS. :

tal Protection Agency (EPA) placed the Mound Site on the
116890008984), In 1993, DOE made a decision to Close the
implex Reconfiguration Program. The reconfiguration was an
‘0 a smaller, less-expensive operation. The realignment focus
jing the required resources. Records generated in support of
receiver sites, or dispositioned per the National Archives and
ed retention schedules. Receiver sites include the Kansas
mos National Laboratory, Sandia National Laboratory,

ifices, the DOE Historian’ s Office, and the Office of:

lab notebooks that were buried at NTS after they were

[hese lab notebooks were indexed as pait of

roject (CDCP) to a Searchable Classified Records Database
as granted by NARA in August 1999.: Images were. *
fame the officialirecord, and the contaminated notebooks were

The issue of Mound ‘records buried at LA
February 7, 2007. Glen Podonsky of the
as members of the Board. In the interve
knowledge of this issue, and reviewed al

There were 458 boxés of inactive classifi
shipped from Mound’s classified Long J]
LANL at the direction of DOE Albuquey
DOE/MEMP. Copies of receipts for co
LANL in August 1995 were sent to DOH
folder or document Iével. They were no
classification. This collection contains ¢
financial and program records including
reservoir R&D and engineering reports.

Forty-three of the 458 boxes were return
Project being performed by MJW Corpo

f
4

E

{

q

i

74 of 95°

ational Laboratory (( LANL) "
T

NL was a topic of discussion at the ABRWH meeting on
Department of Energy participated in this discussion, as well
ing months, NIOSH has interviewed individuals with direct
available pertinent documentation.

jed contaminated and potentially-contaminated records
erm Storage facility and the T Building classified vault to

que Weapons Quality Di

itaminated or potentially-contaminated records shipped to
MEMP. These boxes were never formally inventoried at
included in the'tracking database because of the

lassified R&D notebooks created in the 1950s and 1960s,

detonator assembly, acceptance, surveillance reports, and

ision and supported by

ed to Mound to support the Pre-1989 Dose Reconstruction
ation because it was believed that bioassay data were



SEC-00090

12-19-07 Mound Plant

Individual dosimeter cycle results are no
group was unable to recover any individ:

mainframe computer. A summary report

employees from 1947 through 1977 (Gui
pp. 207-211). Individual dosimeter resul
with early termination dates (before abo

balance of individual employee cycle data.

Positive photon doses are present in the rj

operations, and neutron doses were first

Recorded beta doses are uncommon in

Dayton Units II] and IV did include som
optical density of the monitoring film be’
low-energy radiation, including beta part!
window’ portion of the film could be use

read and are nota part of employee recor}

164). The reason for this lack of data is
was specifically designed to isolate the pi

read the open-window portion of the film]
insensitive films as well) as part of the cal

measurements was to permit better evalu:
p. 310). -Evaluation of the MESH databa:

complete in that, at the end of 1977, the Mound dosimetry
al monitoring data for the previous years from the

was generated Of the annual recorded doses of all monitored
do, 2003; Meyer, 1994, Volume III, 1973 Appendix 3,

s survive in some employee claimant files for employees

it 1960). Discovery efforts are on-going to retrieve the

|

ecords for many, workers from the beginning of Mound site
iecorded in 1949.

ound site records until approximately 1960. Data from

beta measurements. Photon exposures were based on the
ind a shield (eg., brass, Cd, Te, Ta) sufficient to block

cles; the optical density of the ‘unshielded’ or ‘open-

{1 to estimate beta doses. However, early beta doses were not
ds until at least January 1960 (Meyer, 1994, Volume I, p.

hat beta dose rates were likely low in the T Building, which
rocess solutions, On December 1, 1965, technicians began to
as well.as the area behind the shield (and the sensitive and
libration procedure. The purpose of the additional

tion of low-energy gamma photons.(Meyer, 1994, Volume I,
e for beta results generally supports Meyer’s report of beta

monitoring. Though.a few results are noted for earlier dates, significant numbers of beta results are -

not noted until 1968.

Table 6-6 presents a summary of the avai

minimum number of records believed to
number of beta results that were greater t
been included in Table 6-6.

lable external monitoring records. To obtain a count of the
e beta-only measurements, the database was queried for the
an the recorded deep dose. This resultant yearly count has

44 of 95



SEC-00090

12-19-07

Mound Plant

7.3.4 External Dose Reconstruction

By December 6, 2007, EEOICPA claims)
report had been submitted to NIOSH. O
reconstructions for 348 claims.

There is an established protocol for asse:
(these protocol stepsiare discussed in the

¢ Photon Dose

Electron Dose

Neutron Dose

Unmonitored Individuals Working in|

Medical X-ray

73.4.1 Photon Dose

Photon doses are reliably measured at Mi
described in the Occupational External D
bias factors, as necessary, are applied in

For external doses based on'dosimieter ré
more precisely than maximui doses. Be
before} missed external doses are‘estimat}
information is available (e.g., routine dos
detection for Mound dosimeters), missed|
more precisely than maximum doses. Th

73.4.2 Electron Dose

Electron doses are reliably measured usin
stated above, the Mound radiation protec
portion of the dosimeter prior to 1960. Hi
film was noted, the site program began ré
more precisely than maximum doses in
doses were not read or recorded, sufficien

i

Production Are:

meeting the proposed class definition being evaluated in this
those 491 clainhs, NIOSH has completed dose

sing external exposure when performing dose reconstructions
following subsections):

aS

|

und using the various dose measurement methodologies
losimetry TBD (ORAUT-TKBS-0016-6). Correction and
ccordance withIthis document.

ults (zero and non-zero), measured doses can be estimated
lcause individual cycle data are not available for 1977 and '
ed less precisely than the measured:doses. Since sorhe
jimeter exchange frequencies-and minimum levels of ~
external doses, though overestimated, are also estimated .
refore, NIOSH can bound the dose with sufficient accuracy.

Ww

g the “open-window” portion of the Mound dosimeters. As
ion program did not record the measurement from this
lowever, when darkening of the open-window portion of the
fading the affected films. Electron doses can be estimated
ost years at Mound; however, for years when open-window
it information is

available to estimate maximum doses to the

organs for which shallow dose is calculated. Therefore, NIOSH can bound the dose with sufficient

accuracy.

Electron missed doses are applied in acca
information bulletin Interpretation of Do.
OTIB-0017).

1

dance with the

‘imetry Data Sor

70 of 95;

methodology defined in the technical
Assignment of Shallow Dose (ORAUT-



SEC-00090 12-19-07 Mound Plant

“Other Radionuclides” Bioassay Data

For the purposes of this report, “other” radionuclides are defined as radionuclides other than tritium,
Po-210, or plutonium isotopes. Bioassay data for other radionuclides were collected from several
sources and compiled into Excel spreadsheets as part of the Pre-1989 Dose Reconstruction Project.
Unlike the plutonium (PURECON) database or the polonium (PORECON) and tritium databases,
which were created from fairly well-organized individual dosimetry records, the “other radionuclide”
information was generally very poorly-documented and the interpretation of the bioassay results were
often at best scientific approximations. It appears that because the activities involving the other
radionuclides were not large-scale operations, the documentation of associated bioassay sample
information was secondary. to the larger plutonium, polonium, and tritium sampling and analysis
programs.

Logbooks served as the primary source of information MJW used to construct the Excel spreadsheets.
Additional results came from Kardex files. A total of 215 records were found in, and extracted from,
the PURECON database. The curium and americium data found in PURECON represent the only
data discovered to date for those radionuclides.

Difficulties encountered in attempting to interpret available bioassay records are noted in a paper
entitled MJW Corporation Position on “Other” Radionuclides for the Pre-1989 Dose Assessment
Project (MJW, 2002, Phase II). MJW notes therein that gross alpha counting was used to obtain the
available results. Some of the results were not associated with a name, social security number, or
health physics number. Often, there were no units associated with a result. In many cases, there were
results for an element such as radium or thorium, but it was unclear which isotope was intended.
There, was no information on the age, solubility, or chemical form of the elements. In some cases, it
appears bioassay results were repeatedly reported for two, or sometimes three, different radionuclides.
For example, a person may have identical results for protactinium and Th-232. In other cases, urine
samples may have been analyzed for radium/actinium/thorium by differential decay analysis of the
radium fraction. The same urine sample may have also been analyzed for Th-232 by doing a Ra-Th
separation. The results of the differential decay analysis appeared to conflict with the Th-232 analysis
in that the dominant radium isotope is Ra-223 whereas Ra-224 would be expected. This would seem
to indicate that the thorium results should have been interpreted as Th-227.

The methodologies used to reconstruct dose for these radionuclides are discussed in Section 7.2.1.4.
7.1.2 External Monitoring Data Review

After polonium operations began in February 1949, the results of the pocket dosimeter measurements,
film badge readings, and neutron doses were entered in each employee’s radiation exposure record on
Form 1015-X, which remained in use until December 1959. Beginning in May 1959, neutron
exposure data were entered on punch cards and processed by the External Exposure Analysis System
(EXAS) program. Beginning on January 2, 1960, results of both photon and neutron monitoring film
were entered on punch cards (Meyer, 1994, Volume I, 1960 Appendix I, pp. 133-138). After that
time, dose data based on film measurements were entered on Form 1015-X.

Beginning in March 1963 pocket dosimeter results were entered into a file-card system. The use of
punch cards for recording pocket dosimeters ended, and a Kardex file cabinet was purchased for the

55 of 95


SEC-00090 12-19-07 Mound Plant

comprises the residue after extraction f other valuable rare earths; however, the lot also included
oxalate sludge, recycle metal (thorium metal pieces and turnings), thorium oxide (calcined sawdust),
and thorium sulfate (Monex, 1955). The sludge was quite corrosive and many of the 6,000 drums
were deteriorated and leaking upon receipt. Although the thorium refinery project had been
terminated, the drums posed a high maintenance legacy. Drum deterioration was constant and failure
was frequent. For this reason, several hundred drums were periodically re-drummed in the summer
months between 1954 and 1966. By 1962, each had been re-drummed twice. Drums were stored in
various locations throughout the plant, and in 1964, authorization was received to build a facility
(Building 21) to store the material. This facility was completed in 1966, by which time the entire lot
had been re-drummed a third time. The facility was essentially a “silo” with no doors or windows and
two storage bays. One thousand thirty-eight drums were emptied into the smaller of two basins, and
3,576 were dumped in the large basin (Meyer, date unknown). The remaining drums apparently
remained in outdoor storage areas. Since the lot was composed of a variety of materials, some of the
drums were likely to have been less corrosive, and so were not repeatedly re-drummed.

5.2.6 Thorium-230 and Protactinium-231

Starting in 1946, the Manhattan Engineer District began seeking supplies of Th-230 (U-238 series)
and Pa-23] (U-235 series). The Th-230 was to be used in the Redwing nuclear tests and kilogram
quantities were needed for nuclear weapons test diagnostics. Pa-231 and Pa-233 were to be produced
by neutron irradiation of Th-230 and Th-232. An Jonium (Th-230) Program was mounted and in 1949
Argonne National Laboratory developed a pilot plant using Th-230-enhanced wastes (known as Cotter
Concentrate, St. Louis airport cake or simply Airport Cake) from Mallinckrodt in St. Louis. This was
a raffinate produced after solvent extraction of uranium with diethyl ether and after extraction of Ra-
226. In November 1955, Mound was directed to construct a facility, within three months, to recover
Th-230 from the Airport Cake. By May 18, 1955 five shipments totaling 400 grams (8.16 Ci) had
been provided to the AEC. While directed to deliver another 500 grams, Mallinckrodt failed to
deliver the required additional Airport Cake. Leftover Airport cake from the first runs was processed,
but with difficulties due to concentrated impurities. In the late 1950s, Mound sent the remaining 22
grams of Th-230, along with 250 grams of thorium oxide, to Idaho for irradiation in the high-flux
Materials Testing Reactor (MTR). The capsules were allowed to decay for a year in the reactor canal,
but it is not known if they were ever processed for recovery of Pa-231 and Pa-233.

Pa-231 was produced in the early 1950s to be a surrogate for Pa-233 for a study of the physical and
chemical properties of the element. In the thorium breeder reactor blankets, 27-day Pa-233 was
created in the sequence Th-232 — Pa-233 — U-233. Production of Pa-231 proceeded intermittently
between the 1950s and September 1979, the first campaign occurring during the period of 1954
through 1958. The feed materials were U-235-bearing raffinates from Mallinckrodt, Fernald, and the
Cotter Corp. in Canon City, Colorado. Processing R&D started in 1954 in Room 167 of the R
building. Following lab scale pilot tests, Room 145 of the R building was set up to process five-
kilogram batches. A pilot plant was installed in the HH building in July 1955. During March 1956,
the operation was moved into the SW building and took advantage of some of the thorium refinery
equipment. Approximately 20,000 Ib. (80 drums) of this Sperry Cake was processed at Mound. This
processing consumed approximately half of the material in order to produce the single gram of
protactinium requested by the AEC. The remaining drums were to be used to produce another gram,
but this work concluded after another 240 mg were produced.

23 of 95


SEC-00090 12-19-07 Mound Plant

Tritium-handling technologies began in the mid-1950s in support of weapons and non-weapons
programs. Tritium was recovered for reuse in weapons. Metal tritides were used at Mound primarily
to trap H-3 using uranium tritides. In addition, research was conducted on metal tritides. Tritium
targets might also have been processed.

Other major Mound operations included:

¢ Manufacture of enriched stable isotopes for medical, industrial, and general research

¢ Development and manufacture of chemical heat sources

« Recovery and purification of tritium from waste generated by Mound and other DOE sites

« Development of radioisotope heat sources used by the National Aeronautics and Space
Administration and other programs

e Research and development of chemical explosives and pyrotechnics, adhesives, plastics, and
elastomers for the nuclear weapons program

¢ Research and development of thermonuclear energy fuel systems

¢ Research and development of the joining of exotic metals

. Development of instrumentation for the nuclear safeguard program

© Research and development of separation of gases and energy conversion systems

¢ Research and development of technologies for radioactive waste management

Table 5-2 lists the significant Mound Laboratory Programs and Events.

Table 5-2: Chronology of Significant Mound Laboratory Programs and Events
(Table 5-2 spans three pages)

Year Activity

1943 | Planning begins for the Dayton facilities

10-44 | Polonium operations begin at Unit II

1946 _ | Mound Laboratory planning started.

1948 | Mound Laboratory occupied.

1949 | ¢ Polonium operations moved from Dayton Units to Mound Laboratory.

First program separated Ra-226 from barium-rich uranium ore, with pitchblende residue called K-65.

« Experimental extraction of Ra-226 from the K-65 was conducted in the R Bldg. In October, Mound received
200 Ibs. of K-65 ina single drum.

© Study of processes for decontamination of radioactive waste generated by Hanford Pu production reactors.

From 1949-1953, three different types of processing wastes were studied to concentrate constituents such as
Cs-137, Ru-106, Sr-90, Zr-93, Co-60, Nb-94, Sb-125, Te-123, Ni-63, rare earth elements, and Pu-239. Bench-
scale testing began in the R building.

19 of 95



May 15, 2007

U.S. Departinent of Labor
Final Adjudication Branch
1001 Lakeside Avenue, Suite 390
Cleveland, OH 44114
Re:

Objection to NIOSH Dose Reconst

File Number:

truction Methodology and 42 U.S.C.73841(9) (B) and 42

U.S.C 7384n (6)
1am appealing the Denial
A. Causation of my docum

|
f my claim based on the following reason(s):
ented Cancers: Current research does not eliminate

Hodgkin’s Lymphoma and Basal

ell Carcinoitia from causation by the exposure factors that

were prevalent at the Mound Plant!

Site. (NIOSH - Sanford Cohen Audit of Mound)

B. Monitoring and Health Records of Mound Lab Plant Employees:

1. Monitoring of potentially radioactive materials and Mound Plant Employees was done ina

haphazard way, with changing criteria almost daily,

Monitoring of personnel via dosinieter,

urinalysis, etc. was even more sporadic and'eventually administratively denied to all except those

employees chosen by ‘Rad Control”:
of Radiologi¢al data for most all V

In place Administrative Controls prohibited the collection
lound employees.

2., Mound Plant Employee Health Records are not available, These records were removed

from the Mound Plant site in 2005|and buried in the Los Alamos, N.M. desert without the
knowledge atid permission of the Dept. of Labor (Energy Compensation Program) due to ,

radioactive contamination.

: 3, Mound Plant Employee Heal Records.¥ were femoved from their storage site at Mound and .

kept ‘in Building 61 prior to their shipment to the.

site. J: was the Supervisor over the crews

that were involved with the removal and shipment of these records (materials). These materials

sat in Building 61 for a period of
Jam requesting that the U.

¢ prior to their shipment to Nevada.

. Department of. Labor place the Mound Plant Site in the

Special Exposure Cohort Status; s9 that Motind workers who were exposed to radiation have the
opportunity that has been given to ther nuclear and radioactive plant workers to receive
assistance and compensation benefits. I will be subjnitting a Petition for Special Exposure’

Cohort Status with the U.S. Dept.

Sincerely,

Ce:

Senators George Voinovich

f Health and Human Services.

and Sherrod Brown and Representative David Hobson

Copy" submitted to U.S. Dept. of Labor at 8 EOICPA Hearing on May 15, 2007

File



SEC-00090

12-19-07 |

Mound Plant

those workers who were employed for at}
established for the class or in combinatio
SEC classes (excluding aggregate work d

NIOSH is required to document its evalu
reconstruction expertise as well as techni
Universities (ORAU). Once completed,

least 250 aggregated work days within the parameters
n with work days within the parameters established for other
lay requirements).

ation in a report] and to do so, relies upon both its own dose
bal support from} its contractor, Oak Ridge Associated
IOSH provides the report to both the petitioner(s) and to the

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH

evaluation report, together with the petiti
considers appropriate, in order to make r
to add one or more classes of employees
advice of the Board, the Director of NIO!
of HHS will make the final decision, taki}
Board, and the proposed decision issued
seek a review of certain types of final de

3.0 Petitioner-Requested C

pn, petitioner(s) comments, and other information the Board
commendations to the Secretary of HHS on whether or not
0 the SEC. Onte NIOSH has received and considered the
H will proposeja decision on behalf of HHS. The Secretary
ng into account the NIOSH evaluation, the advice of the

by NIOSH. As part of this decision process, petitioners may
isions issued by the Secretary of HHS?

ass/Basis & NIOSH-Proposed Class/Basis

Two petitions associated with the Mound Site requested that NIOSH consider classes for addition to

the SEC:

1. Petition SEC-00090, qualified on Au:
who worked in all areas within the bi

ust 17, 2007, requested the following class: All employees
undaries at the Mound Plant ‘from February 1949 — present.

2. Petition SEC-00091, qualified on September 24, 2007, requested the following class: A/l

employees who worked within the bo
December 31, 1970.

ndaries of the Mound Plant from February 1, 1949 through
|

The petitioners provided information and| affidavit statements in support of the petitioners’ belief that

accurate dose reconstruction over time is
00090 petitioner claimed that personal m
Laboratory (LANL) and at the Nevada T

impossible for the Mound workers in question. The SEC-
pnitoring records are buried at Los Alamos National
st Site (NTS). NIOSH is aware that Mound records were

buried at LANL. NIOSH determined tha} this concern was sufficient to qualify the petition. During

the evaluation of this petition, NIOSH de
recovered or are otherwise accounted for
interview with a former Mound Records

lermined that the applicable buried records have been
(based on information NIOSH has collected, including an
Manager).

The information and statements providgd by the petitioner qualified. the petition for further

consideration by NIOSH, the Board, and

IHHS. Petition SEC-00091 was qualified based on its

timeframe being completely encompassed by Petition SEC-00090. Consequently, NIOSH
merged the Petition SEC-00091 into Pet|tion SEC-00090. This report, SEC-00090, evaluates
the feasibility of reconstructing doses for all employees who worked in all areas at the Mound

ij
i

2 See 42 C.F.R. pt. 83 for a full description of the
available at http://www.cde:gov/niosh/ocas.

jprocedures summarized here. Additional internal procedures are

10 of 95



SEC-00090

|
12-19-07 | Mound Plant

SEC ER-related Interview by ORAU
Dosimetry; November 5, 2007 and D}

SEC ER-related Interview by ORAU

November 6, 2007; SRDB Ref ID: 34

SEC ER-related Interview by ORAU
SRDB Ref ID: 36876

SEC ER-related Interview by ORAU
SRDB Ref ID: 35953

SEC ER-related Interview by ORAU
2007; SRDB Ref ID: 36878

SEC ER-related Interview by ORAU
August 16, 2007; SRDB Ref ID: 359

SEC ER-related Interview by ORAU
6, 2007; SRDB Ref ID: 36934

SEC ER-related Interview by ORAU
2007; SRDB Ref ID: 36879 :

SEC ER-related Interview by ORAU
Ref ID: 36881

SEC ER-related Interview by ORAU

- Specialist; November 6, 2007; SRDB|

SEC ER-related Interview by ORAU
Manager of Radon Group; Date not i

SEC ER-related Interview by ORAU
Protection; October 23, 2007; SRDB

SEC ER-related Interview by ORAU

Bioassay Lab Manager; October 29, 4

SEC ER-related Interview by ORAU

‘Team with sede Specialist, Manager of Internal
pcember 7, 2007; SRDB Ref ID: 36873

|

Team with Laborer-then Material. Handler-then Electrician;
875

Team with Senior Research Specialist; November 9, 2007;
Team -with Senior Health Physicist; September 9, 2007;

[Team with member of Nuclear Physics Group; November 8,

[Team with Subject Expert about Mound Records Disposal;
2 u

‘Team with Decontamination Worker-then RCT; November

ITeam with Electrician and Union Official; November 6,..

Team with Internal Dosimetrist; ‘October:31, 2007; SRDB

[Team with Custodian-then D&D Worker-then Health

Ref ID: 36882

\Team with Seni
lentified; SRDB
|
(Team with Radiological Engineer- then Supervisor for Health
Ref ID: 36884

ior Health Physicist-then HP Specialist -then.
Ref ID: 36883

[Team with Member of HP Group-then HP Supervisor-then
007; SRDB Ref ID: 36877

[Team with Internal Dosimetrist- then Dose Reconstruction

Manager; October 24, 2007; SRDB Ref ID: 36886 a

SEC ER-related Interview by ORAU

Supervisor-Environmental Monitorin;

[Team with Operating Chemist-Internal Dosimetry
Analytical Development-Nuclear Operations-Research

Specialist; Octobér 30, 2007; SRDB Ref ID: 36887 |

14 of 95 |



SEC-00090 12-19-07 Mound Plant

There was also a program involving U-233 beginning in 1966 and continuing into the mid-1970s
(Meyer, 1992). In this program, 1.5 kg of aged U-233 were processed to obtain 30 mg of Th-229.
However, the Annual Overview section of the Meyer document only indicates a bioassay program for
uranium through 1966. Available uranium bioassay records are limited to 44 bioassay results from
1965-1966. Of these, five were specifically labeled as U-233 results.

A gross alpha procedure was used for analyzing the uranium content of spot urine samples. The
majority of available uranium urine sample results do not indicate which isotope of uranium was
suspected to be present. Spot samples were used for screening; 24-hour samples were collected when
a more precise or definitive result was needed. An anion exchange procedure was used on the later
samples.

6.1.10 Americium-241 and Curium-244

Documentation for Am-241 and Cm-244 is very limited. Primary records for Am-241 and Cm-244 are
unknown. The available data were first discovered in (and extracted from) the PURECON database
during the Pre-1989 Dose Assessment Project (MJW, 2002, Phase 11). Seven bioassay results are
available for Am-241 for one person in 1987. Thirty-eight Cm-244 results are available for six
workers in 1983, and two results for an individual in 1986. All Am-241 and Cm-244 urinalysis data
are in units of activity (pCi). The MJW Report (MJW, 2002, Phase II) assumed that Am-241 and Cm-
244 data in Mound dosimetry records are in units of activity excreted per 24-hour period. From
currently available records, it is unclear in which programs the monitored people were involved.

6.2 Mound External Monitoring Data

The following discussion provides a summary of the Mound site external dosimetry program as well
as the types, quantity, and quality of data that can be used for external dose reconstruction. Details
regarding the dosimeters used are presented in ORAUT-TKBS-0016-6. Additional information
regarding the external dosimetry equipment, methodologies, and techniques in use during most of the
proposed class time period is provided in the History of Personnel External Dosimetry Program at the
Dayton Project and Mound Laboratory 1946-1993 (Meyer, 1994).

In 1948, as initial operations were being planned for the newly-established Mound Laboratory,
Mound’s health physicists, employed by the Monsanto Chemical Company, consulted with their
counterparts at the Oak Ridge National Laboratory concerning external dosimetry techniques that
would be appropriate for continuing the Po-210 production operations previously conducted at
locations in the Dayton area. A continuous external dose monitoring program began. This program
developed policies and made programmatic corrections as necessary. Mound used a film badge
external dosimetry monitoring system from 1946 to 1977. From 1977 to the present, Mound has used
a TLD system. Records of radiation exposures from personnel dosimeters worn by workers and co-
workers are available for all years of the proposed class time period. The MESH database serves as
the primary electronic repository of these records. It contains all radiation doses measured for Mound
employees from 1947 to 2005. Periodic health physics reports contain summaries of the number of
dosimeters read for each period, and the number of results in each of several dose ranges. When
individual doses cannot be reconstructed more precisely, maximum doses can be based on these
reported results.

43 of 95



The Honorable Michael 0. Leavitt January 30, 2008

« NIOSH determined that health|may have been endangered for these LLNL facility workers.
The Board'concurs with this determination.

Enclosed is suppotting documentation| from the recent Advisory Board Meeting held in Las Vegas,
Nevada where this class of the special exposure cohort was discussed. If any of these iteriis are
unavailable at this,time, they will follow shortly.

wn

incerely,.

F
q

aul L. Zieméf; Ph.D.
hairman 1

Enc.



Special Exposure Cohort Petition U.S. Department ot Mealtn ana Human >dervices

under the Energy Employees Occupational Centers for Disease Control and Prevention
lliness Compensation Act National Institute for Occupational Safety and Health

OMB Number. 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 3 of 7

Labor Organization Information — Complete Section D ONLY if you are a labor organization.
D.1 Labor Organization Information:

\
Name of Organization \ /\
Position of Contact Person

0.2 Name of Petition Representative:

0.3 Address of Petition Representative:

Street Apt # P.O. Box

City State Zip Code
D.4 ‘Telephone Number of Petition Representative: ( iT
0.5 Email Address of Petition Representative:
D.6 ~~ Period during which labor organization represented employees covered by this petition

(please attach documentation): Start End
D.7 identity of other tabor organizations that may represent or have represented thie clase of
employees (if known):
Go to Part E.
a

Name or Social Security Number of First Petitioner.



SEC-00090 f

12-19-07 Mound Plant

5.1

The Miamisburg Closure Project (MCP),
Miamisburg Environmental Managemen
Laboratory, Plant or Facility. The site to}
mound. Thé 306-acré facility occupied a

Mound was the nation’s first postwar U.
It was established to consolidate and con’
the Manhattan Project. The Dayton Proj
January 1, 1943 to December 31, 1949.

Dayton Site’s primary activity was to pr
processes removed polonium as a contri
bismuth. (For detailed information on th
site description in ORAUT-TKBS-0016-|
Dayton Project are covered in SEC Petiti

Construction of the Mound Plant began i
February 1949. There were originally 14

Mound Plant and Process Descriptions

as it is currently called, has also been known as the

Project (MEMP), the Mound Site, and formerly, the Mound
k the “Mound” name from a nearby Native American burial
ill in the center of Miamisburg, Ohio.

. Atomic Energy Commission (AEC) site to be constructed.
inue the polonium work conducted at the Dayton Project for
ct was operated by Monsanto Chemical Company from
Several Dayton units became part of the Mound facility. The
duce Po-210 to fabricate atomic warhead initiators... Dayton
jutor in the uranium-238 series or from neutron-irradiated
Dayton Project facilities and their activities, see the Mound
P.) Energy employees who worked for Monsanto on the

pn Evaluation Report SEC-00049.

n 1946, with polonium processing becoming operational in
buildings with 360,000 square feet of space. Mound went

on to play an important role in research and development, manufacture of weapons, and evaluation

and maintenance of éxplosive componen|
included tritium recovery, isotope separa|
in support of space programs, support of
processing. Radioisotopes of uranium an
discontinued or transferred the projects t

At Mound, the natrowly-focused poloniu
production of weapons components usin
and non-weapohs programs, especially cl

s for the nuclear defense stockpiles. Other work there
ions methods, development and production of heat sources
he fossil fuels program, and a variety of nuclear materials
\d thorium were:studied until 1985. At that time, the DOE
other facili es! . : oi
Im production work expanded to include the development and
Pu-238. Mound’s main focus was to support DOE weapons
hemical explosives and nuclear technology. One of its

principal missions was to research, develop, and manufacture non-nuclear explosive components for

nuclear weapons that were then assembl

Much of Mound’s Cold War work invol

used in early atomic Weapons, and the re}

facility began to manufacture a variety 0:

d at other sites. |

ed production of the polonium-beryllium (Po-Be) initiators
earch and manufacture of radionuclides. In the 1950s, the
nuclear weapons parts, including cable assemblies,

explosive detonators, and electronic firing sets. Mound work evolved to include stable isotope

separation, fossil fuels research, develop!
providing electrical power for space exp

Early Mound programs investigated the
applications. Research and development

weapons, and weapons use.. Po-210 pro:

Developing, producing, and providing si
1957. Explosive timers were developed j
Ferroelectric transducers and firing set c

ment of radioisotope thermoelectric generators (RTGs) for
loration, and other non-nuclear research and development.

hemical and metallurgical properties of Po-210 and. its
included the fabrication of neutron and alpha sources for
juction declined in the 1960s until it was phased outjin 1971.

irveillance of detonators for military applications began in
1959, and manufacture of timers began in 1963. '

mponent development and manufacture began in 1962.
i

18 of 95.



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, D.C, 20201

MAR - 3 2008

The Honorable Mitch McConnell
Minority Leader

United States Senate
Washington, D.C. 20510

Dear Senator McConnell:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 (EEOICPA) and 42 C.F.R. pt. 83, a petition was filed on behalf of workers from the Mound
Plant near Dayton, Ohio, to be added to the Special Exposure Cohort (SEC).

The Centers for Disease Control and Prevention’s (CDC) National Institute for
Occupational Safety and Health (NIOSH) evaluated the petition and presented its findings to the
Advisory Board on Radiation and Worker Health (Board) on January 8, 2008. The Board
considered the petition, and on February 1, 2008, I received the Board’s recommendation
concerning this petition. I have also received the deliberations, findings, and recommendations
of the Director of NIOSH and the Director of CDC. I have designated the following class for
addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who worked in any areas at the Mound Plant
site from October 1, 1949, through February 28, 1959, for a number of work days
aggregating at least 250 work days or in combination with work days within the
parameters established for one or more other classes of employees in the Special
Exposure Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



SEC-00090 12-19-07 Mound Plant

(ORAU 2003e). Data sources included logbooks, cards, and non-plutonium data extracted from the
PURECON database.

In addition to daughter products from the uranium and thorium decay chains, secondary radionuclides
included:

e = Americium-241 ¢ Radium Isotopes: Ra-228, Ra-226,
© =Curium-244 Ra-224, Ra-223
¢ Uranium Isotopes: U-238, U-235, U-234, ¢ Radon Isotopes: Rn-222, Rn-220,

U-233 Rn-219
© Thorium Isotopes: Th-232, Th-230, Th-228 Protactinium-231
¢ = Actinium-227

Mound also engaged in biomedical research using Calcium-45, Iron-59, Cobalt-60, Zinc-65 and other
radionuclides. The quantities were minor compared to the primary and secondary radionuclides, and
they were used in very few buildings for limited periods. Most of these radionuclides were present as
sealed sources. Worker exposure was less likely, and bioassay data were not collected.

Mound bioassay included primarily in vitro urine data and limited fecal sample results. Jn vitro urine
data are the primary source of information to support dose reconstruction. Fecal analyses, in vivo
chest counting, and air sampling information are considered of limited use due to limited availability
(ORAUT-TKBS-0016-5). Additionally, these latter data are not kept in a central electronic database,
but rather are maintained as hard-copy records, usually associated with an individual worker’s file.
Fecal monitoring results from 1990 onward are available from MESH; 29 fecal results associated with
eleven people sampled between 1966 and 1982 are in the PURECON database. Derived air
concentration (DAC) data are available electronically from 2000 onward, but all other air monitoring
data are on hardcopy. Jn vivo data are only available on hardcopy.

Various bioassay programs were conducted at Mound from 1945 to the present using routine urine
samples collected from workers (Meyer, 1992). Table 6-1 lists primary bioassay programs with
reported radionuclide action levels for a urine sample in counts per minute, workers who were
monitored, and frequency of monitoring.

35 of 95



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational _ Centers for Disease Control and Prevention
lines Compensation Act National Institute for Occupational Safety and Health

7 OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3 O IMWe have attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
tadiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation
guidelines. .

(Attach report to the back of the petition form.)

F.4 0 (We have attached a scientific or technical report, issued by a government agency of the
Executive Branch of Govemment or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published In a peer-reviewed
Joumal, that identifies dosimetry and related information that are unavallable (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

| {Attach report to the back of the petition form.)

age En

- Signature of Person(s) ‘Submitting

-1 of three persons may sign the petition.
D- QB ROOT
Date

ee — lay ah2007
‘ a Dat

_ (g-1°C
Signature a Date
Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of

fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on thls form is accurate and true. *

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

L
| If there are additional petitioners. they must complete the Appendix Forms for additional petitioners.
t vom NE Appendix forms are located at the end of this docunent,

rome Se rence nerd

Name or Social Security Number of First Petitioner:



SEC-00090 12-19-07 Mound Plant

5.4.5 Incidents

Documentation of incidents is typically limited to reports of elevated urine activity or specific
information describing the exposure scenarios. Based on information NIOSH reviewed, area access
controls (e.g., designated/isolated work areas, gloves, vented fume hoods, and glove boxes), personnel
protective equipment, and engineering controls were used to limit worker exposure.

Incident reports are available through the Corrective Action Reporting System (CARS). The DOE
also had an accident reporting system, known as the DOE Occurrence Reporting System (ORPS). An
Energy Employee’s (EE’s) dose from an incident is expected to be included in the individual dose
record provided by the site. If the EE (monitored or unmonitored) states that he/she was involved in
an incident(s) in a telephone interview and there are no records in the claim file, an additional data
request is made to Mound to attempt to verify the verbal information.

6.0 Summary of Available Monitoring Data for the Proposed Class

Radiation protection was a major concern at Mound from the beginning of operations. Initial Mound
external and internal radiation monitoring and protection programs were implemented. when work
with radioactive materials was undertaken (Meyer, 1992). As at other DOE sites, advances in
monitoring knowledge and assay skills led to monitoring improvements and expansion of the scope of
Mound worker monitoring.

The primary sources of monitoring data for this evaluation include the NIOSH Site Research Database
(SRDB), the NIOSH OCAS Claims Tracking System (NOCTS), logbooks and forms located during
data capture events at Mound, and three Mound databases. The Mound databases are designated as
the Polonium Reconstruction (PORECON) database, the Plutonium Reconstruction (PURECON)
database, and the Mound Environmental, Safety, and Health system (MESH). Two additional
databases, the “Data Base of Excretion Data of Other Radionuclides” (ORAU 2003e) and the
“Database of Ra-Ac-Th Excretion Data” (ORAU 2003d) have been compiled in part from non-
plutonium data found in the PURECON database and from logbooks, cards, and forms reviewed
during the Pre-1989 Dose Assessment Project. These latter two databases and the PURECON and
PORECON databases contain only internal monitoring data.

Additional data that are available include specific process information regarding Mound operations,
including radionuclides and proportions in process systems for some years. These are currently
available in the form of progress reports on research activities through 1951, in 1952 and 1953, and
from late 1960 onward. Individual reports document specific processes, such as Bismuth Recovery
Process, Engineering Research Final Report (Bismuth, 1952).

Personnel dose monitoring data are also available in periodic health physics reports, which include
summaries of external dose monitoring that state the number of dosimeters processed and the relative
doses received. These data are not sufficient to assign individual doses, but do allow assignment of
maximum doses when individual doses cannot be reconstructed more precisely based on other
records. These data are available for the years 1948 to 1954; additional partial data are available for
1955 through 1959. In this same category are complete records of air monitoring data for some
buildings in some years (e.g., R and T Buildings in 1949). This information allows calculation of air

33 of 95



SEC-00090

12-19-07 |

. Pu-238, and Pu-239. The major radio}
continuing through the 1960s.. In addi

n

R Building or the Research Building
involving a number of radionuclides

was conducted with metal tritides. B
biological half-lives were in the orde

SM Building or the Special Metallurg
1961. It was designed to receive a liq
a variety of programs, mainly heat so}
processing, waste treatment facilities.

Mound Plant

as built in 1948. It has handled a number of programs

ver the years, ihcluding Po-210, H-3, U-238, Ac-227,
nuclide was Pu-238 with research beginning in 1959 and
ition, R&D was conducted with tritium and experimentation
ecause some tritides were so poorly metabolized, their

of hours. i

ical Building was built in 1960 and became operational in
hid plutonium nitrate mixture from the SRP that was used in
urce projects. In addition, SM Building housed recovery
R&D, and analytical support activities.

SW Building was similar to R Buildi

ig, consisting of many laboratories engaged in a variety of

research, development, analytical, recovery, and surveillance activities. The “old cave” and “new
cave” areas consisted of several rooms set up for “hot” work with several types of alpha and
gamma radiation and project capabilities. Other major programs were the thorium refinery project,
rare isotope program, neutron source,| U-234 separation program, and the tritium programs. The
tritium programs included tritium enrjchment, effluent capture, process development, component

evaluation, and scrap recovery and tri
processing Cotter Concentrate (St. La
late in that decade. Pilot plant operati

}
T Building was host to a number of r¢

various radioisotopes, including Pu-2
programs were the polonium and triti
processing and separation, fuels rese:
development, and production prograi
An extensive renovation program fro
but the renovations were never used
essentially dormant from 1969 to 197|

in the early 1970s when a major effort

Other T Building activities included
mass spectroscopy, calorimetry, neuti
decontamination of T-Buildings oper:
completed (Mound, 1999).

ium waste solidification. SW building was used in
luis Airport Cake) starting in the early 1970s and terminated
ns in SW were designed to recover Th- 230 and Pa-231.

search, development, and production progratis using: '

9, Pu-238, U-233, U-235, and U-238. The two major

um programs. From 1949 to 1973, Po-210 programs included

ch and development, neutron source, and other research,

s. This work was performed on the first and second floors.
1966 to 1968 prepared the way for additional R&D work,

lue to unanticipated funding reductions. T Building was

2 due to this loss of funding. The tritium programs resumed

was undertaken to reduce the fugitive emissions of tritium.

londestructive testing, environmental testing, gamma and

on activation analysis, and safeguards R&D. In 1974,

tions and service floors (50% of the building) was

WD Building, which became operational in February 1949, was the central facility at Mound for

the treatment of radioactive liquid wa;

tes. From its inception, this facility included a low-level

alpha wastewater system, with SW, R, PP, SM, HH, Tt, B, and H Buildings as sources. On arriving
at WD Building, wastewater was precipitated, coagulated, and filtered, and the sludge was

solidified so it could be shipped off si
neutralized to the proper pH, monitor
Miami River.

e. The supernatant from the clarifloculator was filtered,
d to see if it was below standard, and released to the Great

26 of 95



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Tab D

NIOSH SEC Evaluation Report


Mound Plant

SEC-00090 12-19-07
Table 5-2: Chronology of S}gnificant Mound Laboratory Programs and Events a
(Table 5-2 spans three pages)
Year Activity
i
1950 | Separation of Po-208 and Po+209 from proton (acceleratdr) irradiation of bismuth.

© Separation of Ac-227 from irradiated

Ra-226. |

© Uranyl sulfate — heavy water fuel system research. in

* Civilian power reactor research invol

ing uranium, Pa-231, and Pu-239; mission ended in 1963.

1951 Small amount of research with Ra-226 {n preparation of cave operation in SW building. Involved irradiated
Ra-226 and recovery of Ac-227 and Tht228 from Ra-226. | :
1952 | Pilot plant installed in SW building for processing reactor waste. Reactor waste processing areas also included
Warehouses 9 and 13, WD, SD, SW, Rj and M. | +
1953 _| SW Building (tritium handling) constructed with a dirt floor.
1954 | « Invention of the Po-210-fueled thermoelectric generator.
¢ Initiation of several programs requiring tritium-handling technologies.
* Construction of thorium refinery for breeder reactor program (never operated).
1955__| # Repackaging of 6,000 55-gallon drums containing thoriuin ore and sludge was on-going through 1966 due to
deterioration and failure of the, drums!
© August 1955: Small research program in R Bldg involving recovery and subsequent purification of Pa-231 from
natural sources. }
@ June 1955: Radium Cave operation shut down (Ra-226, Ac-227, Th-228, Ra-223, Ra-224 daughters)
Decontamination and decommissioning ongoing until February 1959. H
1956 | Completed separation of 1.3 grams offPa-231 in Building HH. :
© Weighable quantities of Th-230 (ionim) separated. cave
© Pu-239/Be neutron. sources manufactifred. ; :
¢ Nuclear weapon detonator development, production, and|surveillance; mission ended in 1989...
1959 © Pu-239 reactor fuels laboratory operational. . | ot
© Tritium waste recovery and purification facility operational. . .
“| U-233 research involving about ten research personnel . : . .
* D&D completed for old cave .
1960 __| Pu-238 used in large quantities in prodyiction operations. Process areas included the R, SM, and PP Buildings.
1961 __| Development of Pu-238 heat sources fdr thermoelectric generators.
1963 ‘Several Po and Gadolinium polinide heat sources containing 100-1000 Ci of Po-210 were encapsulated in
refractory metal. . |
1964 | 190 mg of Ac+227 was processed in the new cave area.
¢ Thorium ore and sludge moved to bulk storage in Building 21
1965 __| Gaseous effluent control system operational in SW Building.
1967 | 54,000 Ci of high-purity Po-210 werd processed for Mound experimental work and commercial use.
* 14.5 kg of Pu-238 were recovered from waste material. :
1968 | PP Building 38 operational for processing Pu-238. i ‘
1969 |e Waste line break and subsequent contamination of the abandoned Miami-Erie Canal bed with Pu-238.
Began tritium recycling from retired weapon parts.
© 3,701 Ci of Po-210 were produced for both internal and external customers.
¢ Six SNAP 27,sources were produced.| Each source contained 3735 Ci of Pu-238
10/70 | Plutonium inventory was reduced to a thinimum level. 22.5 kg of Pu-238 scrap was shipped to SRS for burial.
-6/71 ‘
1972 | Tritium effluent control project began.
© Non-weapons polonium work terminated. ;
1973 | Pu-238 oxide was processed for four mblti-hundred watt (4.2 kg each) and 2 Viking sources (1.2 kg each)
1974 |e Thorium ore and sludge completely rémoved from site. i
 Po-210 decontamination of Technical (T) Building completed. ‘
1975 Pu-238 recovery operations terminated
1977 Californium Multiplier Neutron Radiography Facility installed.

20 of 95"



Special Exposure Cohort Petition U.S. Department of Health and Human Services!

under the Energy Employees Occupational Centers for D sease Control and Prevention
Mtness Compensation Act National Institute for Occupat‘onal Satety and Health
OMB Number: 0920-0839 Expires: 05/31/2007

Page 2 of 7,

Name_of. Survivor:

MrJMrs/Ms. First Name Middle Initial . Last Name
B.2 Social Security Number of Survivor: 1
B.3 Address of Survivor:

Street : Apt # P.O. Box

n

City Stale ip Code

B.4 Telephone Number of Surviver.
B.S Emaif Address of Survivor:

B.6 Relationship to Employee: Q Spouse
Q Grandparent

C.1 Name of Employee: . ar oct

Mr/Mrs/Ms,_ FirstName Middle Initial Last Name
C.2_ Former Name of Employee (e.g., maiden name/legal name change/other):

Mrivirs./Ms. First Name 7 Hhiddie initia Last Name
C.3_ Social Security Number of Employee:
C.4 Address of Employee (if living):

EL PASe:
Street ‘ Apt # P.O. Box
City ' State Zip Code
C.5 Telephone Number of Employee: Ny NA
C6 Email Address of Employee: VA

C.7 Employment Information Related to Petition:
C.7a Employee Number (if known):

C.7b Dates of Employment: Start 1956 End 1923
C.7c Employer Name: Mon. nd pat
C.7d Werk Site Location: Mia mis burg Ohio ¥53d2.

C.7e Supervisor's Name: >

_ —

Go to Part'e

Name or Social Security Number of First Petitioner: _. n



SEC-00090 12-19-07 Mound Plant

Once the database was complete, the second phase of QA was initiated. Supervisory staff compared
the results of al] 24-hour urine samples entered into the database with the original hard copy logbook
results. These samples were chosen for 100% review because 24-hour samples were typically
collected following a known or suspected intake, and therefore represented some of the larger results.
In addition to this review, 1% of the remaining records were compared to the hard copy results. The
goal was to verify that there was less than a 1% error rate in the database construction. Ifa larger
error rate had been found, additional QA would have been performed.

As this data comparison was performed, it turned up gaps of a few weeks to several years in the data
of several individuals. This was unusual because samples were typically collected on a weekly basis.
These gaps were researched using Microsoft Access to identify gaps by a preset time period such as
30 days, 60 days, etc., up to one year. These data gap printouts showed the length of the gaps, and
potentially, the data that were absent. Examples of a data gap printout are shown in Appendix D of
the Phase I Final Report (MJW, 2002, Phase I). The data gap research also helped identify those
periods of potentially-missing data in an individual’s file so that the paper records of weekly reports
and logbooks could be searched for the occurrence of a particular name. It should be noted that for
the early Po records, only the person’s name was used as a means of record identification. In many
instances, the name was not complete; in a few cases, only nicknames were entered. Consequently, it
is unknown if all records for an individual were reconstructed correctly in that regard.

Once the initial Po database entry work was complete, MJW turned its attention to additional sources
of Po data that had not been previously identified. As was previously discussed, the original Po
logbooks were consulted throughout the Po data entry process to resolve conflicts found on the Po
cards. As a result of continuing to consult these logbooks, additional data were discovered that had
never been captured on Po data cards. These new data were input into the Po database as they were
discovered.

Additional data added to the PORECON database came from a 3-ring binder containing two sets of 19
microfiche discovered in historical file drawers. Labeled “Po-210 Historical Exposure Data,” the data
entered on the fiche contained the worker's name, SSN, and Po bioassay data consisting of the sample
date and result. Because the origin of these data was unknown, they were treated as potential
information which may be missing from the PORECON database. Therefore, a 100% check of the
fiche data against the PORECON database was performed. The results showed that a few persons
listed on the fiche were not included in the database. They also showed that, for several individuals,
the fiche contained more sample information than the database. Finally, in a few instances, the fiche
data were in conflict with the database information. In this case, the original Po logbooks were again
consulted to resolve any conflicts.

Almost from the inception of the Pre-1989 Dose Reconstruction Project, there were reports by former
Mound staff of human bioassay data present in original logbooks sent for classified storage at the Los
Alamos National Laboratory (LANL). Discussions were initiated between DOE Mound and DOE
LANL in October 1997 regarding a limited search of the Mound logbooks. After several months of
discussion, MJW staff spent two days at LANL in March 1998 reviewing approximately 230
classified, potentially radiologically-contaminated logbooks. The results of this review showed that
about 10% of the logbooks examined contained human bioassay results for polonium. An additional
5% of the information gathered was also related to Po research, such as nose wipe data, blood sample
data, fecal sample data, and various animal studies. Additional discussions were then held between

53 of 95



SEC-00090 12-19-07 Mound Plant

7.4.1.7 Mound Plant Employee Health Records Removed to LANL

7.4.1.8 Mound Plant Employee Health Records Kept in Building 6]

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00090
7.4.2.1 Employee badges

7.4.2.2 Contamination Incident:

7.4.2.3 Plutonium through Ventilation Ducts

74.2.4

7.4.2.5 Documents taken from Mound

7.4.3 Evaluation of General Concerns.
7.4.3.1 Various Contamination Incident:
7.4.3.2 Inadequate Monitoring and Protection .
7.4.3.3 Actinium-227 Urine Samples.
7.4.3.4 Neutrons

7.4.3.5 D&D Era Bioassay

7.5 Summary of Feasibility Findings for Pet

8.0 Evaluation of Health Endangerment for Petition SEC-00090...........sessssessssseeseeseectesrestestesresseeees OF

9.0 NIOSH-Proposed Class for Petition SEC-00090 .0.......eeeesesesseseenesesteseeesesssnsseseseseseeseseensseeseseeee 87

10.0 References .....c.scceccsecssecsesseessessesserssssssesseesnessussneesseesesssesssecssersseesssssscesecssecssessessaseasessneesneeseseseesst® 90
Tables

4-1: No. of Mound Site Claims Submitted Under the Dose Reconstruction Rule .........:c.:ccsscssessesseenes 15

5-1: Mound Plant Operational Chronology...
5-2: Chronology of Significant Mound Laboratory Programs ani
5-3: Principal Alpha-Emitting Radionuclides Present at Mound......
5-4: Beta Emitters Associated with Polonium Production at Mound
5-5: Neutron Energy by Facility and Operation
5-6: Photon Energy by Facility and Operation..

6-1: Bioassay Programs and Action Levels....
6-2: PORECON Polonium Record Summary
6-3: Summary of Historical Plutonium Analytical Procedure:
6-4: PURECON Plutonium Record Summary ....
6-5: Radon Isotope Survey Data by Building and Period
6-6: Summary of External Monitoring Data in the MESH Database
6-7: Mound Dosimeter Use and Assignment Policies
6-8: Beta-Photon Dosimeter Types and Exchange Frequency
6-9: Neutron Dosimeter Types and Exchange Frequency...

7-1: Radon Isotope Survey Data by Building and Time Period
7-2: Radon-222 WLM Assumptions for Dose Reconstruction .
7-3: Summary of Feasibility Findings for SEC-00090.

7 of 95



SEC-00090 12-19-07 _| Mound Plant

"Table 6-8: Beta-Photan Dosimeter Types and Exchange Frequency

Dosimeter Exchange
Period Dosimeter type “holder: frequency Comments
2/1949-11/1951 DuPont DS52 Oak Ridge/steel Weekly All radiation workers
12/1951-1957 DuPont D552 Oak Ridge/steel Biweekly All radiation workers
1957-1960 DuPont (model unknown’ Oak Ridge/steel Biweekly All radiation workers
1961-1962 DuPont 558 Oak Ridge/steel Biweekly AllLradiation workers
1963-1968 DuPont D556 Oak Ridge/steel Weekly Some radiation workers
: Biweekly Most radiation workers
i Monthly General area workers
1968-1969 DuPont.D556 Oak Ridge/stee! Biweekly Dependent on work area
, Monthly
Quarterly
1970-1977 Kodak Type 3 Mound holder ' Biweekly Dependent on work area
Monthly 7
| Quarterly .
1977-1986 Harshaw 8810 TLD-700 Cycolac Biweekly Dependent on work area
i Monthly
: Quarterly
1986-1987 Harshaw 8810 TLD-700 Cycolac Monthly Dependent on work area
i Quarterly
1987-1991, Harshaw 8810 TLD-700 | | Cycolac Monthly ___| All employees monitored
f Paar) . at 1 Quarterly ‘ sty
1991-site closure _ | Harshaw 8801 TLD-700 | |Cycolac Monthly | Dependent on work area
oo Quarterly a
5
hoe

" Table 6-9: Neutron Dosimeter Types and Exchange Frequency

Dosimeter Exchange
Period Dosimeter type holder | frequency Comment
1949-8/1951 Kodak NTA Oak Ridge/stee) Weekly All radiation workers
8/1951-1957 Kodak NTA Oak Ridge/steél Biweekly
1957-1960 Kodak NTA Oak Ridge/steel Biweekly
1961-1962 Kodak NTA Oak Ridge/steél Biweekly
1963-1968 Kodak NTA Oak Ridge/steé! Weekly Some radiation workers
‘ Biweekly Most radiation workers
| Monthly General area workers
1968-1977 Kodak NTA Mound holder Weekly Dependent on work area
Biweekly
is Quarterly
1977-1986 Harshaw TLD-600 TLD-700 Cycolac y Weekly Dependent on work area
. . . Biweekly
| Quarterly
1986-1987 Harshaw TLD-600 TLD-700 Cycolac Monthly Dependent on work area
‘ Quarterly
1987-1991 Harshaw TLD-600 TLD-700 Cycolac | Monthly Dependent on work area
Quarterly
1991-2003 Harshaw TLD-600 TLD-700 Cycolac Hl Monthly Dependent on work area
: | [Quarterly

48 of 95



4

SEC-00090 12-19-07 Mound Plant

5.2.9 Thorium-229 from Uranium-233 (Irradiated Thorium-232)

Los Alamos provided a kilogram of U-233 in 1958. The U-233 and Th-229 were produced by
neutron irradiation of Th-232 as shown in the following reactions.

oo Th? ( 1.405E+10 yr) + on! > 99Th?®
90 Th 7 (22.3 min) > 9; Pa? +.) B°+y
o1 Pa 3 (27.0 da) > 9973 + 1 B°+y

92 U3 (1.59E+10 yr) > 99m 2? +20.

In 1966, small-scale separations of Th-229 were carried out within a new hot-cell facility in the SW
building. Processing of the U-233 began in two Type A glove boxes with a connecting fume hood
along the north wall of SW-22. The process also used bench tops in SW-140 and fume hoods in
SW-132.

The U-233 was dissolved in nitric acid. Liquid-liquid organic extraction was accomplished by adding
di-sec-butylpheny! phosphorate and TOPO in diethylbenzene. Thorium was stripped from the organic
phase with 0.5 molar oxalic acid followed by a second strip with 8 molar nitric acid. This process
required 20 to 30 hours for a 75 g batch. This program processed 1.5 kg of aged U-233 to produce 30
mg (6 mCi) of Th-229.

The Mound Plant ceased non-weapons work in 1971 and stopped production of weapons components
in 1995.

5.3. Mound Radiological Buildings

The following subsections provide a brief overview of the major Mound radiological buildings from
February 1, 1949 through August 17, 2007. The source for most of the information below is ORAUT-
TKBS-0016-2, which also lists the radionuclides of concern for each building along with other
information. For a detailed listing, refer to Mound Site Radionuclides by Location (King, 1995)

Mound Unit V Buildings:

e HH Building or Hydrolysis House derived its name from its primary function, the hydrolysis of
highly-radioactive bismuth chloride and aluminum chloride solutions. In 1963, the HH Building
was converted to stable gaseous isotope separation by use of thermal diffusion, liquid diffusion,
and cryogenic processes.

¢ PP Building or Plutonium Processing Building 38 was completed in December 1967. SM Building
processes, fabrication operations, and recovery processes were transferred to PP Building along
with waste treatment facilities, R&D (including material research), and analytical laboratory:
support activities. PP Building was used primarily for processing Pu-238 dioxide received from
the Savannah River Plant (SRP).

25 of 95



SEC-00090 12-19-07 Mound Plant

Early Mound site neutron dosimeter results were more,accurately measured using NTA film than the
spectra present at most AEC sites, due to the higher-energy spectrum associated with Po-Be sources.
For this reason, Mound neutron doses can be based substantially upon measured doses even in the
NTA film era. Periodic health physics reports demonstrate that not all workers were monitored for
neutron doses; however, neutron dosimeters were required for work in those areas with significant
neutron dose rates. For this reason, those workers with the highest potential neutron doses are
assumed to have been monitored, which provides a sufficient basis for estimation of a maximum
neutron dose for others workers.

6.3. Mound Air Sampling Data

Mound health physics program records include a number of air samples for alpha- and beta-emitters.
Typically, such data are of limited use in dose reconstruction due to the great uncertainties associated
with the doses estimated based on measured air concentrations. When possible, dose reconstructions
are usually performed based on data related to a specific claim (including bioassay data), which
provides a much more direct assessment of the uptake of a given radionuclide and the resulting organ
dose. Air concentration measurements are used to assign internal doses from radioactive material in
the general environment, in accordance with the Mound Occupational Environmental Dose TBD,
(ORAUT-TKBS-0016-4).

Measured air concentrations are useful for estimating maximum doses when bioassay data are
unavailable. Performance of routine air monitoring was a feature of the Mound health physics
program since the beginning of Mound operations. Air sample results are available in at least
summary form for the years 1949 through 1954. This information will be integrated into the revision
of the Mound Occupational Internal Dosimetry TBD. In some cases, this information will be used to
bound doses for unmonitored internal exposures, as described in Section 7.0 of this report.

7.0 Feasibility of Dose Reconstruction for the Proposed Class

The feasibility determination for the proposed class of employees covered by this evaluation report is
governed by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must
establish whether or not it has access to sufficient information either to estimate the maximum
radiation dose for every type of cancer for which radiation doses are reconstructed that could have
been incurred under plausible circumstances by any member of the class, or to estimate the radiation
doses to members of the class more precisely than a maximum dose estimate. If NIOSH has access to
sufficient information for either case, NIOSH would then determine that it would be feasible to
conduct dose reconstructions.

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose
reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential
radiation exposures of the class (discussed in Section 9.0 of this report). If the conclusion is one of
infeasibility, NIOSH systematically evaluates the sufficiency of different types of monitoring data,
process and source or source term data, which together or individually might assure that NIOSH can
estimate either the maximum doses that members of the class might have incurred, or more precise
quantities that reflect the variability of exposures experienced by groups or individual members of the

49 of 95



SEC-00090

12-19-07

7.4.3.2 Inadequate’ ‘Monitoring and Proj

Mound Plant

ection

The SEC-00091 petitioner presented se
and inadequately protected radiation wo
processed without engineering controls
non-uniformity of radiation monitoring,
development of radionuclides, including}
claimant clearly states that these comme:

eral non-specific concerns, including inadequately monitored
ers, large quantities of several radionuclides that were

r protection as would be expected by today’s standards,
manufacture of Po-Be neutrons, and research and

Ra-226, Ac-227, Th-228, Th-230, Pa-231, and U-233. The
its can be referred to as radiation exposures and radiation

doses were not monitored, either through Personal monitoring or through area monitoring.

\
NIOSH is aware that the engineering cot
today.
history and can estimate doses based on
other radionuclides, as mentioned above.
i

743.3 Actinium-327 Urine Samples

During interviews with former Mound
samples collected from employees invol
samples were not analyzed for a number
with them once they, were analyzed. Thi
< 2006)... NIOSH is continuing to investig:
reconstructions with’sufficient accuracy
vos 4 >
7.43.4 “Neutrons .
The workers associated with polonium r
years of Monsanto (1943- 1949) were no}
Exposure Cohort based on insufficient di

The potential for exposire to neutrons e
personal monitoring'for neutrons started
NIOSH can now estimate the potential nj
Documentation of Variables in the Asse:
1977), discusses track fading and NTA fi
document:

¥

Prior to the production of Radioisot
polonium- beryllium (PoBe) neutron
from these neutron sources, having
spectrum of neutrons ii in the radiatio

In addition, NIOSH is aware of the processes tha

can be quite different from the standards of
t occurred at Mound during its operational
internally-deposited radionuclides from bioassay results. The
have been discussed in Section 6.1.

trols of the pas

orkers, a concern was raised regarding Ac-227 urine bioassay
ed ina 1991] R-Building Corridor 5 D&D job. These

of years, and there were apparently quality control issues

is situation resulted in Price-Anderson Act violations (PAAA,
te this issue for! impact on our ability:to conduct dose +

for this situation. .

i
wt

{

. ‘ a
search and neutron source production during the very early
monitored for neutrons. SEC-00049 qualified as a Special
ata available to support internal dose construction.

isted for workers during the early years of Mound, and

in September 1949 (Meyer, 1994; ORAUT-TKBS-0016-6).
eutron exposures with sufficient accuracy. The

sment of Neutron Doses at Mound Laboratory (Variables,
Im sensitivity to low-energy neutrons. According to that

»pic Thermoelectric Generators (RTG) at Mound Laboratory,

sources were used for film calibration. The energy spectrum

in average ‘energy of about 4.5 MeV, corresponded to the
areas: (Variables, 1977, pdf page 3).

84 of 95



SEC-00090 12-19-07 Mound Plant

8.0 Evaluation of Health Endangerment for Petition SEC-00090

The health endangerment determination for the class of employees covered by this evaluation report is
governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not
feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must
also determine that there is a reasonable likelihood that such radiation doses may have endangered the
health of members of the class. Section 83.13 requires NIOSH to assume that any duration of
unprotected exposure may have endangered the health of members of a class when it has been
established that the class may have been exposed to radiation during a discrete incident likely to have
involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If
the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is
required to specify that health was endangered for those workers who were employed for a number of
work days aggregating at least 250 work days within the parameters established for the class or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC.

NIOSH has insufficient information regarding internal Ra-Ac-Th exposures at Mound from the arrival
of K-65 sludge in October 1949 through February 28, 1959, when the related area of work was
decontaminated and decommissioned and sufficient monitoring was in place. NIOSH’s evaluation
determined that it is not feasible to estimate radiation dose for members of the proposed class with
sufficient accuracy based on the sum of information available from available resources. Modification
of the class definition regarding health endangerment and minimum required employment periods,
therefore, is required.

9.0 NIOSH-Proposed Class for Petition SEC-00090

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of
employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH-
proposed class includes all employees of the Department of Energy (DOE), its predecessor agencies,
and DOE contractors and subcontractors, who were monitored or should have been monitored, for
internal Ra-Ac-Th exposures while working in all areas of the Mound site for a number of work days
aggregating at least 250 work days from October 1, 1949 through February 28, 1959, or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC.

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions
stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available
technical resources and many other references, including the Site Research Database (SRDB) and
several Mound databases, for information relevant to SEC-00090. In addition, NIOSH reviewed its
NOCTS dose reconstruction database to identify EEOICPA-related dose reconstructions that might
provide information relevant to the petition evaluation.

87 of 95



Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Emptoyees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Appendix — Petitio:

B.1 Name of Survivor:

Mr/Mrs./Ms. First Name Middfe Initial Last Name
B.2 Social Security Number of Survivor:
8.3 Address of Survivor:

Street Apt# P.O. Box

City State Zip Code
B.4 Telephone Number of Survivor: }
B.5 Email Address of Survivor:

B.6 Relationship to Employee: O Spouse Q Son/Daughter Q Parent
Q Grandparent Q Grandchild |

Mr/Mrs.(Ms) First Namé Middle Initial 7 Last Name
C.2 Former-Name of Employee (e.g., malden nameflegal name change/other):

Mr/Mrs./Ms. First Name Middle Initial ; Last Name
C.3 Social Security Number of Employe — _

C4 Address of Employee (if living); , \
- Street ; VA) he nhoé . _ P.O. Box
ay Sale CZip Code
C.5 Telephone Number of Employee. : - _—
C.6 Email Address of Employee: VA

C.7 Employment Information Related to Petition: ’
C.7a_ Employee Number (if known):

C.7b Dates of Employment: Start Seri: $a 12 End Via vl L986
C.7c Employer Name: 2, esean orp.
C.7d_ Work Site Location: Mound Plaxt ;

Me mts hula _kJhin SS 3¢R

€.7e Supervisor's Name:

_...__ Sign Part G of the original petition. .

Name or Social Security Number of First Petitioner: __- J



oT Designation

I, Michael O. Leavitt, Secretary of Health and Human Services (Secretary), designate
the class of employees defined in Section II of this report for addition to the Special
Exposure Cohort (SEC), as authorized under the Energy Employees Occupational
Illness Compensation Program Act of 2000 (E. A), 42 U.S.C. § 7384q.

MAR - 3 2008

v

Date "Michael O. Leavitt

II. | Employee Class Definition

Employees of the Department of Energy (DOE), its predecessor agencies,
and DOE contractors or subcontractors who worked in any areas at the
Mound Plant site from October 1, 1949, through February 28, 1959, fora
number of work days aggregating at least 250 work days or in .
combination with work days within the parameters established for one or
more other classes of employees in the Special Exposure Cohort.

III. Designation Criteria and Recommendations

Pursuant to 42 U.S.C. § 73844, for the class defined in Section II of this report, the
Secretary has determined, and the Advisory Board on Radiation and Worker Health
(Board) has recommended, that
(1) it is not feasible to estimate with sufficient accuracy the radiation dose that the
class received; and
(2) there is a reasonable likelihood that such radiation dose may have endangered
the health of members of the class.

The SEC final rule states in 42 C.F.R. § 83.13(c)(1) that it is feasible in two situations
to estimate the radiation dose that the class received with sufficient accuracy. First,
the rule states that radiation doses may be estimated with sufficient accuracy if
NIOSH has established that it has access to sufficient information to estimate the
maximum radiation dose for every type of cancer for which radiation doses are
reconstructed that could have been incurred under plausible circumstances by any
member of the class. Alternatively, radiation doses may be estimated with sufficient
accuracy if NIOSH has established that it has access to sufficient information to
estimate the radiation doses of members of the class more precisely than a maximum
dose estimate.

The Board, pursuant to 42 U.S.C. § 7384q, advised the Secretary to designate the
class as an addition to the SEC in a letter received by the Secretary on February 1,
2008.

HHS Special Exposure Cohort Designation:
Mound Plant



SEC-00090 12-19-07 Mound Plant

SEC Petition Evaluation Report for SEC-00090

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for all employees who worked in all areas
at the Mound Plant from February 1, 1949 through August 17, 2007. It provides information and
analyses germane to considering a petition for adding a class of employees to the congressionally-
created SEC.

This report does not make any determinations concerning the feasibility of dose reconstruction that
necessarily apply to any individual energy employee who might require-a dose reconstruction from
NIOSH. This report also does not contain the final determination as to whether the proposed class
will be added to the SEC (see Section 2.0). ,
This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83,
and the guidance contained in the Office of Compensation Analysis and Support’s (OCAS) Internal
Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004.

2.0 Introduction

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the
Department of Health and Human Services (HHS) add a class of employees to the SEC. The
evaluation is intended to provide a fair, science-based determination of whether it is feasible to
estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose
reconstructions.

42 C-F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH
has established that it has access to sufficient information to estimate the maximum radiation dose,
Jor every type of cancer for which radiation doses are reconstructed, that could have been incurred in
plausible circumstances by any member of the class, or if NIOSH has established that it has access to
sufficient information to estimate the radiation doses of members of the class more precisely than an
estimate of the maximum radiation dose.

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses
for members of the class, NIOSH must also then determine whether or not there is a reasonable
likelihood that such radiation doses may have endangered the health of members of the class. The
regulation requires NIOSH to assume that any duration of unprotected exposure may have endangered
the health of members of a class when it has been established that the class may have been exposed to
radiation during a discrete incident likely to have involved levels of exposure similarly high to those
occurring during nuclear criticality incidents. If the occurrence of such an exceptionally high-level
exposure has not been established, then NIOSH is required to specify that health was endangered for

' NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and
the detailed implementation guidelines available at http://www.cde.gov/niosh/ocas.

9 of 95



HHS Designation of Additional Members of the

Special Exposure Cohort
under the
Energy Employees Occupational Illness Compensation Program Act of 2000

Designating a Class of Employees from

Mound Plant
Miamisburg, Ohio

HHS Special Exposure Cohort Designation:
Mound Plant



SEC-00090 12-19-07 Mound Plant

Evaluation Report Summary: SEC-00090 Mound Plant

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH)
addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the
Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C.
§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as
Members of the Special Exposure Cohort under the Energy Employees Occupational Illness
Compensation Program Act of 2000.

Petitioner-Requested Class Definition

Petition SEC-00090, qualified on August 17, 2007, requested that NIOSH consider the following
class: All employees who worked in all areas within the boundaries at the Mound Plant from
February 1949 — present.

NIOSH-Proposed Class Definition

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of
employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH-
proposed class includes all employees of the Department of Energy (DOE), its predecessor agencies,
and DOE contractors and subcontractors, who were monitored, or should have been monitored, for
internal Ra-Ac-Th exposures while working in all areas of the Mound site for a number of work days
aggregating at least 250 work days from October 1, 1949 through February 28, 1959, or in
combination with work days within the parameters established for one or more other classes of
employees in the SEC.

Feasibility of Dose Reconstruction

NIOSH cannot estimate internal Ra-Ac-Th exposures from the arrival of K-65 sludge in October 1949
through February 28, 1959, when the related area of work was decontaminated and decommissioned
and sufficient monitoring was in place. With exception of this class, per EEOICPA and 42 C.F.R. §
83.13(c)(1), NIOSH has established that it has access to sufficient information to: (1) estimate the
maximum radiation dose, for every type of cancer for which radiation doses are reconstructed, that
could have been incurred in plausible circumstances by any member of the class; or (2) estimate
radiation doses of members of the class more precisely than an estimate of maximum dose.
Information available from the site profile and additional resources is sufficient to document or
estimate the maximum internal and external potential exposure to members of the proposed class
under plausible circumstances during the specified period. .

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because
NIOSH has determined that it does not have sufficient information to estimate internal Ra-Ac-Th
exposures for the members of the proposed class.

3 of 95



SEC-00090 12-19-07 Mound Plant

7.4.2.5 Documents taken from Mound

SEC-00090: J am intimately familiar with the story of the documents that [employee name removed]
took from Mound and that Babcock and Wilcox so desperately wanted to recover, as those documents
were stored, for some period, in my basement because of [employee name removed] concerns about
how Babcock and Wilcox would react to those documents, which clearly demonstrated their
mis-management would be perceived and received by responsible regulatory authority.

In an interview with the Records Manager at the time of this incident, she was told by the employee
that he had taken records from the site to his home. The Records Manager told him that he needed to
bring the records back to the site where he could copy them and take home the copies. After several
days, he had not done this. At this time, the Records Manager reported the event to the company
attorney who called Security and requested the dispatch of security personnel to the employee’s home
to retrieve the records. This is not an SEC issue.

7.4.3 Evaluation of General Concerns

7.4.3.1 Various Contamination Incidents

SEC-00091 presented a list of general statements by a former worker. She listed many concerns
which included: use of special clothing while mixing MOCA and not always wearing a radiation
badge, repeated showering, work with Be, travel from building to building for different jobs, death of
a young man from radiation in the T Building in the medical facility, persistent contamination in her
hair, radiation in her right arm so she could not touch her husband for three weeks, chemical storage
areas, and a resume of some of her job duties.

The substance MOCA is a polyurethane elastomer used in fabricating weapons components and is not
a radioactive material. Personnel working with non-radioactive weapons components (sometimes
called “small parts workers”) were often not monitored for radiation dose due to the lack of radiation
fields in these workplaces. Although no specifics are given in this example, it is clear that
contamination incidents occurred throughout the operating history of Mound. It has been
demonstrated that the doses resulting from such incidents can be estimated. Doses from internally-
deposited radionuclides are estimated from bioassay results, and external doses are measured using
film badges or TLDs. While this is an important issue, such issues do not have SEC implications. In
the case of an unmonitored worker who had the potential for radiation exposure, NIOSH can estimate
unmonitored dose based on co-worker data. Regarding the concern about a young man who died from
radiation in the T Building, current research has not, to date, resulted in the discovery of a record of
such an incident.

Approximately 400 NOCTS files were reviewed for incident reports. Approximately one-third of the
files contained incident reports describing the incident, the date of the incident, and what measures
were taken (e.g., nose swipe, urine samples). The bioassay results are also found in the individual
employee’s file. The dates of the incidents spanned the entire period under evaluation and included
spills, contamination of personnel and equipment, glovebox issues, and elevated air samples.

83 of 95



Report says il
Mound workers
treated unfairly

An independent auditor faults the site
profile being used to evaluate and often
reject compensation claims.

A newly released inde-
pendem anditor’s report
punches holes in the
source document that the
federa! government has

een using (0 evaluate —~

. in most cases, reject
— compensation claims
trom cancer-stricken for-
mer workers ut the Miam-
isburg Mound Plant.

‘The audit hy contractor
Sanford Cohen and Assa-
ciates offers a stinging cri-
tique of Maund’s program
for monitoring workers
fo foactive exposures

gests (hat poor monitoring
and record-keeping could
make, it impossible for the
government to accurate-
the daims of sick
Mound workers secking
federal compensation.
Sanford Cohen audited
a tecinical “site profile”
used by federal officials as
the basis sor determining
whether worker ilinesses
were caused by workplace
sures.
‘The National fnstitute
for Occupational Safety
and Health has used the
profule.tu provess 88 per-
cent of the claims fled hy
ound warkers — 70 per-
cent of which have been
rejected for compensation,
NIOSH will have to
reopen those claims if
the site orofile ultimate:
ly is revised by the federal
Adviyory Board on: Radlia
tion and Worker Heaith,
id NIOSH spokeswoman
manda Hames.
if the government deter-

liftcally reconstruct worker
exposures, Mound could
qualify for “special cxpo-
sure cohort” status that
would allow sick workers
to automaticaliy receive
lump-sum payments and
medical benefits if they
have certain cancers,
Atami workers who don't
have the status can spend
years fighting an uphill bat-
tle ta prove their illnesses
were caused by ou-thejob
toxic exposures.

Workers at the pre-
Mound Dayton Project
run by Monsanto Chemi-
cal Co., are close to being
approved for the special
siatus after a similar audit
found it wasn't possible
to accurately reconstruct
their dose

‘To date, the Labor
Departinent has paid 197
of 1,465 claims filed by 719
Mound workers with the
Energy Empk Occu-
pational HIness Compensa-
tion Act.

One problem painted
out in the audit: Suppor
staff — including adminis.
irative, maintenance, secti-
and janitorial work
ers — were unknowingly
to the same haz-
ards as radiation workers,
but not monitored.

“Tt is not clear,” the
audit said, “how dose
estimation would he per-
formed for maintenance
and support workers...
whose actual jobs could
have ied tn expnsures com-
parable lo radiation wer
ers.”

pe audit: Workers
likely exposed to



Special Exposure Cohort Petition us. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Contra! and Prevention
Wines Compensation Act’ : National Institute for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B ! ge 4of7

Proposed De! on of Employee Class Covered, by Petition — Complete Section E.
E.1 Name of DOE or AWE Faci iS = iS ate)

E.2 Locations at the Facility relevant to this petition:

APM NGS ANO_ERTRRAAL Utes Sinz aS (ALD) WITH LN»
FROM TY Bepnaoadey” !

£.3 List job titles and/or job duties of employees. included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you belleve should be
included in this class:
AL OMporets , awoke Sudeuoi@y AND CER CAL AT THe Noun
Vist
a4 Employment Dates relevant to this * Petition: :
sarees WT ses 1997 [ena __ Beek _PRESENTTM
Start End —_ |
Start :

ES Isthe petition based on one or a ivan unrecorded, or inadequately monitored or

recorded exposure incidents ?: Yes Q No

\) Hf yes, provide the date(s) of the incident(s) and a tomplete Sescription (attach additional pages
A necessary): 7

ITURE OF ZARD
Cap Raed) WENRRING OF WORKERS WTO RECARO TH Bmisviee kd
Auda’ Kcuennc’ ANO CAP Qué ROARIIG Wr Sirad He PATTER OF ONE

eZ

o Woes Nee nea Os Reo Cie Garment Mans IK. NONI -
ity’ i 6 i] Won - coatea ARES WRE Roce
X Rom Re aiwte WeimbeimG |

Go to Part F:

t
Name or Social Secuity Number of First Petitioner.

PET Thon Revise (7a [A04



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, 0.C. 20201

MAR - 3 2008
The Honorable Nancy Pelosi
Speaker of the House of Representatives
Washington, D.C. 20515

Dear Madam Speaker:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 (EEOICPA) and 42 C.F.R. pt. 83, a petition was filed on behalf of workers from the Mound
Plant near Dayton, Ohio, to be added to the Special Exposure Cohort (SEC).

The Centers for Disease Control and Prevention’s (CDC) National Institute for
Occupational Safety and Health (NIOSH) evaluated the petition and presented its findings to the
Advisory Board on Radiation and Worker Health (Board) on January 8, 2008. The Board
considered the petition, and on February 1, 2008, I received the Board’s recommendation
concerning this petition. [ have also received the deliberations, findings, and recommendations
of the Director of NIOSH and the Director of CDC. [ have designated the following class for
addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who worked in any areas at the Mound Plant
site from October 1, 1949, through February 28, 1959, for a number of work days
aggregating at least 250 work days or in combination with work days within the
parameters established for one or more other classes of employees in the Special
Exposure Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

MicHael O. Leavitt

Enclosure



SEC-00090 12-19-07 Mound Plant

Variables, 1977, Documentation of Variables in the Assessment of Neutron Doses at Mound
Laboratory, W. A. Bigler; Mound Laboratory; June 17, 1977; SRDB Ref ID: 3144

White Paper T, 2002, T Building Structural History and Process History Summary Background
Document (unpublished) BWXT of Ohio, November 2002; SRDB Ref ID: 25941

Yt-90, Preparation of Carrier-Free Yttrium-90, Document search underway; SRDB Ref ID: Not
currently in SRDB

95 of 95


SEC-00090 12-19-07 Mound Plant

7.4 Evaluation of Petition Basis for SEC-00090

The following subsections evaluate the assertions made on behalf of petition SEC-00090 for the
Mound Site.

The petitioner provided four affidavits, one from herself and three from former EEs. Two of
the affidavits describe contamination in Building 61, a non-radiologically controlled building.

The other two affidavits do not provide any supporting information regarding the petition. One
affidavit is a work summary and the other is a copy of a letter sent to the petitioner from the
U.S. Department of Labor in regard to her personal dose reconstruction.

The petitioner provided an affidavit contending that contaminated items were moved to areas
of Building 61, a non-radiological controlled area, for disposition to other government agencies
and eventually to public sale and/or auction, and that the workers in Building 6] had no
follow-up monitoring when the contaminated equipment was found. In addition, concern was
raised about other incidents of radiological contamination continuing throughout the plant and
that as many as one incident per week occurred after serious decommissioning work began.
The petitioner contends that most of the incident critiques found violations of radiological
procedures or lack of radiological control.

SEC-00090: The last item in the petitioner affidavit states that many Mound records were -
shipped to Nevada for burial because it was decided that the monitoring and
decontamination processes “were too costly to pursue”. The contents of the “records
would provide-valuable data regarding the change in Mound culture from Safety First t
Cut Costs and Get Out”. .

A second affidavit provided by a former employee lists several points of concern, including a
change in policy regarding the use of dosimeters and whole-body count requirement, incidents
of contaminated material outside of radiological controlled areas, an employee with a full body
burden as a result of an accident, reports of exposure to radioactive material and documents
taken from Mound by an employee and the retrieval of these documents by Babcock and
Wilcox.

The petitioner also included a letter sent to the U.S. Department of Labor in response to the
denial of her claim. Three discussion points, as paraphrased by NIOSH, included:

1. Monitoring of potentially-radioactive material was done in a haphazard way and eventually
monitoring of personnel via dosimeter, urinalysis, etc., was even more sporadic and
eventually administratively denied to all except those employees chosen by Rad Control;

2. Mound Plant Employee Health Records are not available. The records were removed from
the Mound Plant in 2005 and buried at LANL without the knowledge and permission of the
DOL due to radioactive contamination;

3. Mound Plant Employee Health Records were removed from their storage site and kept in
Building 61 prior to shipment.

73 of 95


|

SEC-00090 12-19-07 _| - Mound Plant

5.4.4. Photons
Photon sources were:present in almost al] Mound facilities. Most Mound facilities had mixed fields of
neutrons, beta, and photons. The beta fidld is a lesser concern for many Mound workplaces with
respect to external radiation protection because the shielding around the glovebox or process shielding
is thicker than the maximum beta range. |The energy spectrum was dependent on-the particular on-
going operation. Table 5-6 summarizes the respective IREP input photon energy category by facility
and operation (ORAUT-TKBS-0016-6). fo F :

Table 5-6: Photon Energy by Facility and Operation
Facility Operation |Perioa Energy (keV) Percentage ~
HH Building: . .
HH 3, 4, 5,8 "_| Separation of He-3; Kr-85 1960-1995 30-250 50 |
HH 5,6 Pa-23 1/sludge separation 1955-1956 >250 50 > |
HH 8, 10-12 : | Hydrolysis of Al and|Bi chlorides | 1949-1958
PP Building: | :
Waste Handling area Th-232 storage and re-drumming 1955-1975 30-250 75
* | >250 25
R Building: . : 4
R-lI7 : Storage Vault 1949-1990 30-250 50
: : . ‘ >250 _. 30
SW Building: vee
sws .| Xe isotope separation ~ 1957-1960 30-250 50
ESW 11-14. & 16 (area *| ‘Decontamination of BiSO, ‘ 1951-1953 >250 s* 50
.1B) + Pa-231 ‘purification 1956 wot .
‘SW_19 (Old Cave) Radium-actinium separation 1951-1953 st
. ‘SW 140 (New Cave), | Processing residue frbm 1970-1979 “
132, 136, 137 | pitchblende production .
SW 146-147 Metallurgy laborato: 1967-1985
SW 219 Neutron source prodyction 1962-1965
T Building: | :
All but T43, 44, 48, Po neutron source program 1949-1973 30-250 50
50-51, 57-59, 348-359 » i >250 50
H Building Hot laundry unknown 30-250 25
>250 75
WD Building: ' . | j
WD 1, 8, 101, 104 Wastewater treatment 1949-1990 30-250 50
“_WD 107 Ultra-filtration 4 1976-1981 >250 50
WD 112, 113 i| Analytical work 1966-1979
WD 113,118 A&B __| Storage, waste incinefation 1979-1994
WD Penthouse Filter banks 1949-1993
B Building ‘| Internal dose research 1950-1955 30-250 25
: | >250 15

32 of 95



|Special Exposure Cohort Petition
under the Energy Employees Occupational
IlIiness Compensation Act

ho!

041 Labor Organization Information|
1

N
U.S. Department of Health and Human Services!
Centers for Disease Control and Prevention
Natlonal Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Name of Organization

Position of Contact Person

smployers (if known):

0.2 Name of Petition Representative: !

D3 Address of Petition Representative: |
Street | Apt# P.O. Box
City State Zip Code

D.4 Telephone Number of Petition eet i a =

D.5 Email Address of Petition Representative: |

D.6 Period during which labor organization represented employees covered by this petition

a7 (please attach documentation): | Start End
D7 {dentity of other labor organizations that may represent or havé represented this Class of

1

Name or Soclal Security Number of First P}

4

__]

jetitioner:



Tab C —

SEC Petition


‘Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
ines Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Appendix — Cont

{The folliowing is ough transcript of a history from
+ was hired on at Mounds around the same dayas her sister in 9-25 1956- until 1986, 30
years. veloped CML and died around Christmas, 2006. They all worked in several
+puildings. A cousin ! so worked there and got breast cancer.1 ., said they wore robes,
special shoes, caps over hair, various types of gloves, rubber, plastic and cotton, occasionally a
_{mask for mixing MOCA. They always wore a picture identification badge but did not always
_{wear radiation badges. Sometimes you would wear a radiation badge almost ali day but usually
“Jonty short parts of the day. She would have to shower repeatedly. She worked with Beryllium oni
several occasions including various laboratories and in the early years production of parts. :
‘]They would travel from building to building as they bid for different jobs. i

A bldg was administration, B was biology, C was cafeteria, D was decontamination a hot bldg. |
“lots of water that they tried to wash the facility with and contaminated the regional aquifer, had |
~to remove tons of dirt. R building was radioactive and hot, A young man got so exposed to |
radiation in the T building that he died in the medical facility. The T building was far
_Junderground. After three years in the T building, sometime in the 1970's), she had to be taken
{out because of persistent contamination of her hair. Shc had to wear rubber gloves at home and i
_lcouldn't touch or sleep with her husband for about two or three weeks until the radiation cleared

from her right arm. The production areas appeared spotless, very little dust. The areas in which
metallurgy was done were the dirtiest ateas but these were mostly staffed by men.

{The chemical storage areas were some of the most dangerous areas.

“Made heads for the triggers or detonators of A bombs, soldered two little silver spots and took a
“microscopic gold wire on the detonators, and test fired these.

She worked with beryllium off and on but did not personally sand, grind or polish such parts.
AShe worked quite a bit with an explosive white powder which they would weigh out with
_istainless steel spoons. '
_|Some supervisors didn't tell workers what they worked with

| Workers had blue books and classified red books that told workers what they did
‘There were times when inot wearing a badge but her supervisor was
“|Also the men didn't seem to be as careful as the women were, they were braver.

a. . — a a

“Atach'to | Form Bi itm

‘Name or Social Security Number of First Petitioner.



SEC-00090 12-19-07 Mound Plant

Very small doses compared with the primary dose radionuclide. For example, a spectrum of beta-
and gamma-emitters associated with the irradiated bismuth feed product for the polonium
refinement process is listed in King with the statement that “Polonium-210 is the major
radionuclide of concern, with Zinc-65 a distant second” (King, 1995)

Insignificant dose commitment due to a short effective half-life. An example of this would be
La-140, used as a radiotracer

For Mound chemical research operations, descriptions of the process and results exist in Mound
progress reports, technical reports, and in peer-reviewed journals. From these documents, the
proportions and amounts of radionuclides can be determined with sufficient accuracy to estimate a
maximum dose. Another source of information is air monitoring results available for some buildings
and time periods.

Examples of other radionuclides for which doses will be calculated based on data other than bioassay
results are listed below.

Fission product dose from ‘reactor waste’ research (1949-1953. A project was conducted in the R
Building to research the feasibility of removing fission products from waste streams, including the
bismuth phosphate, tributyl phosphate, and the solvent extraction (Purex) plutonium separation
processes. Progress reports, such as Decontamination of Process Waste Solutions Containing
Fission Products by Adsorption and Coprecipitation Methods (Information Report) (Decon,
1951), contain detailed descriptions of the process, along with chemical composition and
radioassay results. Additionally, bioassay was performed for individuals with plutonium as the
indicator element. From these, maximum exposures may be determined with sufficient accuracy
to determine a maximum dose.

Separation of yttrium from strontium (1952-1954). A small research project was conducted to
separate Sr-90 from its progeny Y-90 (in secular equilibrium in material aged more than 30 days).
No bioassay data exist for this operation; however, a description of the chemical process exists in
the document Preparation of Carrier-Free Yttrium-90 (Yt-90).

Radiotracers (1949-1954). The literature suggests that there was some potential for exposure to
La-140 and Ba-140 (in secular equilibrium), which was used as a radiotracer to determine the
efficiency of the separation process with lanthanum and barium modeling the chemical behavior
of radium and actinium. The proportions of the radionuclides in the process material are listed in
the progress reports such as Report for Research on Substitute Materials, October 1, 1951 to
December 31, 1951 (Actinium-227) (Ac-227, 1952). A maximum dose may be estimated for
potential exposure to these radionuclides during this activity.

61 of 95


., Pre-l 989 Dose’Reconstruction Project re}

SEC-00090

12-19-07 _| Mound Plant

Mound DOE and LANL DOE to retrieve

a selected number of Mound logbooks. ‘A total of .

approximately 1500 logbooks were returned to Mound following declassification. A complete review

of these declassified records was perform

ed and the results of this additional -work showed that only

about 5% of these logbooks contained human bioassay results for Po with some additional animal

data.

After the polonium logbook material from LANL had been declassified and reviewed by MJW staff,

Mound staff discovered that not all pertin
additional logbooks located on site were

ent Po records had been sent to LANL. Several thousand
identified as potentially containing project-relevant material.

Once the scope of the project was ecfnet and funded, a teview of the classified records in the

logbooks was begun.’ Five Q-cleared ind|

viduals working part-time reviewed approximately 5,300

logbooks. Again, approximately 5% of the logbooks provided information relevant to human Po

bioassay data while an additional 5% of
various Po compounds.

It was discovered during MJW’s review
Mound logbooks retrieved from LANL

reviewing all of the microfilm at Mound
reviewed regardless of the location of the

Tritium Bloassay Data
' :

Mound tritium: data: réside i in the MESH d

1982 only listed the year, the person's so
information from 1982 to the present con]
sample dates, in addition to the informati
given in any post-1981 records. No docu
algorithm used to calculate the dose repor
bioassay methods uséd throughout the tri
limits and accuracy, are known (Meyer, |
tritium has been automated since the earl
been handled by computer for many man:
routine procedure in tritium dosimetry.”

information retrieved related to animal studies using
!

f logbooks and 'microfiche that all of the data found in the
as recorded on the microfiche. It is likely, therefore, that in
elated to Po bigassay data, all available data have been
hardcopy information.

* ! can . vet
jatabase. Initial/review of the data by MJW during the.
ealed that records entered into:the system from 1957 until’:
ial security number (SSN), anda dose in rem. Database. .
sisted of the original tritium bioassay analytical data with
n listed above, with the exception that no annual dose-is
mentation was Idcated in the historical files that described the
Hted in the database for the earlier years. However, the

ium monitoring period, as welll as the associated detection
992). As noted! !by Meyer, “urine sampling counting for
days of tritium work and the processing of the data has
years... The calculation of whole body exposure has been a

Except for the years 1976 and 1977, primary data for tritium bioassay results are available. Workers

involved with the Pre-1989 Dose Recons
data for the highest- -exposed employees (,

ruction Project located and used original logbook bioassay
re-1982) for tritium dose algorithm development. The

format used for recording primary (and s¢condary) tritium records has changed many times through
the years of tritium bioassay. The tritium) dose records available to the dose reconstructor consist,

with rare exceptions, of information in th
annual totals through:1981, and actual bi
based on the ‘recording level’ of 6 wCi/L
(zero or non-zero) aré provided. Positive

MESH database. Tritium dose records in MESH contain
assay results for 1982 and after. Dose reconstruction is
through the year 1995 unless individual bioassay results
recorded annual doses are modified with the correction

factor in accordance with Equation 5-4 in}the Mound Occupational Internal Dosimetry TBD

(ORAUT-TKBS-0016-5). If the modifie

dose is greater|than the missed dose, based on the recording

level, modified dose i is assigned. If the mlissed dose is greater, then missed dose is assigned.

54 of 95



SECO0O4O

Special Exposure Cohort Petition U.S. Department of Heatth and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Iliness Compensation Act National Institute for Ocoupational Safety and Health

OMB Number, 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 1 of 7

Use of this form and disclosure of Social Security Number are voluntary. Failure to use this form or disclose
this number will not result In the denial of any right, benefit, or privilege to which you may be entitied.

General Instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT ail information clearly and neatly on the form.

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there ts more
than one petitioner, then each petitioner should complete those sections of parts A — C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-
pose. A maximum of three petitioners Is is allowed.

to provide al infor . use the continuation page provided at the end of
the ‘fom and sttach the completed continuation omnatio to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
fequest to speak to someone in the Office of Compensation Analysis and Support about an SEC petition:
1-800-356-4674,

QO A Labor Organization, Start atD on Page3

you aan Energy Employee (current or former), Start atC on Page 2
are: Q A Survivor (of a former Energy Employee), StartatB on Page2
QO A Representative (of a current or former Energy Employee), StartatA on Page 1

A. Are you a contact person for an organization? O Yes (Go to A.2) OQ No (Goto A.3)
A.2 Organization Information:

Name of Organization

Position of Contact Person
A3 Name of Petition Representative:

‘Mr/Mrs./Ms. First Name Middle Initial Last Name

A4 Address:
Street Apt# P.O. Box
City State Zip Code

A. Telephone Number: L
A6 = Email Address:

A7 ~~ Q Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

if you are representing a Survivor, go to Part 8; if you are representing an Employee, go to Part C.

A=

Name or Social Security Number of First Petitioner:

ReTiTies Keren o7fic|201 -



SEC-00090

12-19-07 Mound Plant

T
radionuclide, and'this value is used ta
implied by positive results. Air activ’

reports specific to the ionium program.

data available from 1956 onward, ma}
more precisely than a bounding dose

Thorium-232, 1954-1956 (Research);

horium-230, 1954-1956: Programs thvolving Th-23

featured bioassay data for the primary
assign missed dose as well as potential dose from intakes
ity measurements are available in periodic health physics
Along with available process information and bioassay
imum doses can be estimated, or doses can be estimated
estimate.

bioassay data for the primary radionu|
potential dose from intakes implied b
available from 1951 to 1954, with lar;
bioassay data associated with the peri
the time the material was in the Build)
available process information to esti

Radium-226, Ac-227, and Th-228, 19

1956-1975 (Storage): Programs involving Th-232 featured
tlide, and this value is used to assign missed dose as well as
positive results. Small numbers of bioassay results are

ger numbers available from 1955 through 1959. Additional
ibdic re- -drumming of material is available prior to and after
ing 21 storage basins. These data may be supplemented with
ate a reasonable bounding dose.

49-1954 cesenlh and production); 1955-1959

(decontamination“and decommissionii

hg): These radionuclides were part of.research on production

for use of Ac-227.as a substitute for pi
decommissioning of the building whe)

(Meyer, 1992, p.38). NIOSH has ace}

radionuclides; however, interpretation
for the time period October 1, 1949 th

‘
Uraniuim: Processes with uranium wei
results‘are used td assign missed dose
results: Along with available process'
estimated or doses can be estimated nj

Americium-241 and Cm-244: Limited
bioassay results. These are used to as}
implied by positive results. These dat;

to estimate a reasonable bounding dog

7.2.1.5__Other Radionuclides with No B

jolonium in neutron initiators. The decontamination and
re the work was) done was completed in February 1959
ess to a limited number of bioassay results for these

of the results ig uncertain. NIOSH cannot bound the dose
rough Februaty'28, 1959, .

e associated with reactor fuels research. Existing bioassay
as well as potential dose from intakes implied by positive
information and bioassay data, maximum doses can be*

ore precisely than a bounding dose estimate.

programs with these materials resulted in a small number of
ign missed dost as well as potential dose from intakes

ia may be supplemented with available process information
ie.

ioassay Data

A number of radionuclides are described
research activities, or as part of the waste
radionuclides associated with research-sc:
years to decontamination and decommiss
Like most radiation protection programs,

the potential to produce the majority of the

significant for several.reasons, including:

* Limited amounts of material and limi

in the literature as available through direct exposure during
iisposal system; Small quantities of a variety of

le activities and their progeny are available in subsequent
ning workers, as listed in the King document (King, 1995).
he Mound program sampled for those radionuclides having
e internal dose. Radionuclides were considered less

ed number of personnel exposed

60 of 95



SEC-00090 12-19-07 Mound Plant

7.2.3, Internal Dose Reconstruction

For the period October 1, 1949 through February 28, 1959, NIOSH has determined that internal doses
from Ra”, Ac”, and Th” associated with the separation operation in SW-19 cannot be determined
with sufficient accuracy. This is based on the following factors:

1. NIOSH has access to a limited number of bioassay results for these radionuclides; however,
interpretation of the results is uncertain (MJW, 2002).

2. While it is likely that the bioassay results relate to the workers directly involved in this operation,
it is not known what fraction of those workers was sampled.

3, There is strong evidence that airborne contamination was produced by this operation, and that this
contamination was spread beyond SW-19 to other areas in R and SW Buildings. This situation
créated significant exposure potential among R and SW Building workers for these radionuclides.
The limited number of individuals for whom Ra-Ac-Th bioassay results are available suggests that
the larger population in the R and SW Buildings were unmonitored for potential intakes.

4. The reported airborne contamination concentrations throughout R and SW Buildings are relatively
high in some cases, suggesting the potential for non-trivial intakes and consequent internal doses.

While it is likely that significant exposure potential resulting from this operation was limited to the R
and SW Buildings, it is not clear as of this writing whether access to these buildings was strictly
limited to the personnel regularly working in them.

7.2.4 Internal Dose Reconstruction Feasibility Conclusion

Potential for radionuclide intakes existed at Mound. Mound sought to limit internal exposures:and
maintained a progressive bioassay program throughout its operational history. NIOSH has both
demonstrated that employees with the greatest potential for internal intake were monitored, and
determined that the available bioassay data can be used to reconstruct or bound potential internal
radiation doses for those employees, with the exception of those workers who may have been exposed
to Ac-227, Th-228, and Ra-226 from October 1, 1949 through February 28, 1959.

NIOSH can bound the doses arising from exposure to polonium, tritium, plutonium, radon,

protactinium, Th-230, and Th-232, uranium, and stable metal tritides using the scenarios described in
the previous sections.

65 of 95



SEC-00090 12-19-07 Mound Plant

issue, NIOSH believes that this issue does not have SEC implications. NIOSH does not consider this
exposure scenario an example of a maximum or bounding-exposure scenario. In the case of an
unmonitored worker who had the potential for radiation exposure, NIOSH could provide a bounding
dose estimate (i.e., assign dose based on the air sample data or based on the maximally-exposed,
monitored worker groups) for the proposed worker class definition.

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00090

This subsection presents specific affidavit statements made by workers on behalf of petition
SEC-00090. The italicized statements are from the petition; the comments that follow are from
NIOSH.

7.4.2.1__Employee badges

SEC-00090: 7) When I joined Mound in 198]all employees were give [sic] dosimeter badges. The
badges were read on a periodic basis and all employees were also given a periodic whole body count.
2) Shortly after Babcok [sic] and Wilcox assumed control of Mound they, as a cost savings effort,
removed dosimeters from all personnel who did not immediately work in radiological areas. As an
attempt to provide some minimal of [sic] radiological monitoring dosimeters were hung around the
plant, but no effort was made to track or monitor the movement of individuals into those various
areas, so any attempt to tie those reading to individuals was impossible. 3) If an employee made a
special request for a dosimeter badge, it was denied out of hand, as an unnecessary expense.
Historical documents exhibit an on-going program of evaluation and modification of the internal and
external monitoring programs. Changes were made to the program based on changing workplace
conditions and resulting changes in the character of the potential exposures. Changes were also made
to take advantage of new technology in order to obtain more accurate measurements. Finally, changes
were required over the years to ensure compliance with contractual radiation safety requirements and,
later, with federal radiation safety regulations. Data are available in archived records and, in most
cases, electronic databases containing transcription of the archived records. Information sources
include film badge and TLD readings, air monitoring data, and results of bioassay programs, nose
swipes, fecal analyses, whole-body counts, and chest counts.

7.4.2.2__ Contamination Incidents

SEC-00090: J have specific recollection of several instances of radiological materials moving outside
of the controlled areas. In one instance contaminated computers were moved through Building 61
and actually sold on the public market only to have Mound personnel have to go into the buyer's
warehouse and recover those computers after they had left the Mound site. In addition, I have a
specific recollection of handling an incident report where a worker in the dosimeter processing lab
was contaminated by radiological material that accidentally got into her lab.

Although no specifics are given in this example, it is clear that contamination incidents occurred
throughout the operating history of Mound. It has been demonstrated that the doses resulting from
such incidents can be estimated. Doses from internally-deposited radionuclides are estimated from
bioassay results, and external doses are measured using film badges or TLDs. While this is an
important issue, NIOSH believes that such issues do not have SEC implications. In the case of an

81 of 95



SEC-00090

12-19-07 Mound Plant

5.3.1 Mound Site Decommissioning

Throughout the operating lifetime of the

operations were removed from service and isolated, dec

appropriate. After weapons component
shifted to decommissioning facilities. TI

ound Plant, facilities that no longer were necessary to site
dntaminated, and/or demolished as
roduction ceased in 1995, the emphasis of site activities

e decommissioning and eventual closure of the Mound Site

is being conducted under the Compreherjsive Environmental Response, Compensation, and Liability

Act (CERCLA) and a Federal Facilities

Agreement among DOE, USEPA, and Ohio EPA in

accordance with a process known as MOUND 2000. Following clean-up, properties at the former

Mound Site are conveyed to the Miamis|

(MMCIC). Land-use restrictions are conveyed with the

urg Mound Community Improvement Corporation

property, if necessary, to ensure future

protection of human health and the environment. Decommissioning management is the responsibility

of the DOE Office of Environmental Management (EM):

transferred to the DOE Office of Legacy)
(Mound Site, Miamisburg, Ohio Fact Sh|
Closure Project, DOE, March 2005).
Since the termination of Mound product}
involved with site closure and decommi

© EG&G Applied Technologies Pror to 1995 — September 1997

Og
Jan

BWXTO, Inc. ?
© -CH2M:HILL Mound
“In early 2003, S. M.-Stoller Corporation
Accelerated Remediation Company (aR
Landfill and PRS-441 Rail Yard areas u
remain in effect as oF this evaluation rep

A site assessment in 1995 identified app
sites with potential radioactive and/or h:
divided into discrete land parcels: Phase
7, 8, and 9; and Parcels D and H. As of|
and conveyed to MMCIC; the Phase | p
and Parcels 6, 7, and 8 have been remed
OU-1 Landfill and the Rail-Yard area ir
information on the decommissioning act
following DOE/LM web site: http:ww

Responsibility for site management will be
Management (LM) following completion of clean-up.
ret, DOE, October 2007) (Transition Plan for the Mound

lon activities, the major DOE/EM contractors primarily
sioning have been:

tober 1997 —December 2002
uary 2003 — July 2006 (decommissioning declared soimplete)

Re

was designated the major site contractor for DOE/LM.
) was selected in October 2006 to further remediate the OU-1
der a congressionally- funded project. These two contracts

ort. (Personal communication, 2007)

roximately 116 remaining buildings and 400 remaining land
zardous material contamination. The 306-acre site was

1 (consisting of subparcels A, B, and C); Parcels 3, 4, 6, 6A,
October 2007, Farcels D, H, 3, and 4 have been completed
arcel has been completed, but not yet conveyed to MMCIC;
iated and are undergoing the CERCLA review process. The
Parcel 9 are still in the process of remediation. Further
ivities for specific Mound Site facilities is available at the
.Im.doe.gov/land/sites/oh/mound/mound.htm.

28 of 95)



SEC-00090

Mound Plant

12-19-07 _ |

concentrations in specific rooms, and ove
values when individual bioassay data are
summarized in periodic health physics re|
doses, they do allow estimation of maxiny

Some qualitative information in the repo
modified to take changing source terms ii
Quantitative data on the number of wipe
and room, support the correlation of air s

6.1 Mound Internal Monitorin

Summaries of the available in vitro and i
analytical protocols, are provided in the ff
analytical methods, detectable activities,
Occupational Internal Dosimetry TBD (
Bioassay Programs (Meyer, 1992).

As noted in ORAUT-TKBS-0016-5, radi

estimated inter
unavailable or Unusable. Air concentration data are also
ports. Though these are not useful for assigning individual

b Data

inal doses may be calculated from these

um doses.

its is useful to ensure that health physics practices are

idents and activities are also described.
ed, the number of air samples taken, by area

to account. Ini
surveys perform

ample results with specific potential source terms.

vivo data, as well as general overviews of sampling and

bllowing subsections. Additional details, including

ind reporting protocols can be found in the Mound
RAUT-TKBS-0016-5) and in the History of Mound

nuclides were categorized by Mound staff as either primary

or secondary based on the potential extent of use and the amount of bioassay data available. Primary

radionuclides of concern are discussed in|
Mound Bioassay:Programs (Meyer, 1992

: Primary radionuclides assessed for occup,
© § Po-210

Plutonium Isotopes: Pu-238, Pu-239*|
Tritium

* Because Pu-240, Pu-241, and Pu-242 di
major plutonium source terms, NIOSH

The above radionuclides were identified
were more widespread at the site, often in

ational internal

Mound internal dosimetry documentation, the History of

), and Mound Site Radionuclides by Location (King, 1995):
h E .

exposure included:

i

not comprise 4 dosimetrically-significant proportion of the
has chosen not to include these in its discussion.

s primary becatise they were present in larger quantities and

multiple buildings and facility processes. Correspondingly,

more monitoring data and site documentation are available (than for secondary radionuclides) to

evaluate internal doses associated with th
these radionuclides.in conducting key mi:

Secondary radionuclides include those th:
exposures. Often referred to as “other” r4
programs involving relatively few people

ese radionuclides. Primary on-site operations used all of

sion activities.

t were of limited use at the site or involved limited worker
dionuclides in Mound documents, they were part of smaller
Many of the programs were relatively short-term research

projects and brief production runs, and source material was received intermittently (MJW, 2002,

Phase I], Appendix C). Fewer internal. d
the primary radionuclides. Available data
sources during the Pre-1989 Dose Assess|

simetry data are available for these radionuclides than for
for secondary radionuclides were collected from several
ment Project and combined into two Excel spreadsheets:

Database of Ra-Ac-Th Excretion Data (ORAU 2003d) and the Database for Other Radionuclides

34 of 95



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational | Centers for Disease Control and Prevention
illness Compensation Act National institute for Occupational Safety and Health

. OMB Number: 0820-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form|B | Page 6 of 7

F.3 Q iWe have attached a report from p health physicist'or other individual with expertise in

radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility,|as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation
guidelines. *

(Attach report to the back of the pptition form.)

F.4 OQ IWe have attached a scientific or|technical report, issued by a government agency of the
Executive Branch of Government jor the Genera! Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
Joumal, that identifies dosimetry ahd related information that are unavailable (due to either a lack
of monitoring or the destruction orloss of records) for estimating the radiation doses of
employees covered by the petition. |

(Attach report to the back of the petition form.)

Go to Part G.

Signature of Person(s) Submitting this Petition — Complete Section G

All Petitioners should sign and date the petition. A maximum of three persons may sign the petition.

= | Bl Qos 7
Siyrause ne 1 D:
Signature , t : : ; R Date
Signature . Date.
Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of
. fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true. |
Send this form to: SEC Petition
Office of Compensation Analysisjand Support
NIOSH H

4676 Columbia|Parkway, MS-C-47
Cincinnati, OH 45226

If there are additional petitioners, they must complete the ‘Appendix Forms for additional petitioners.
The Appendix forms are located at the end of this document.

1

erie Casal Thelaw’ |

Name or Social Security Number of First Petitioner:



SEC-00090

12-19-07

7.2.1.6 Radon

Beginning in 1952, sources of radon (Rn
Mound due to radium and thorium proce:
from Th-232 extraction and purification
1966, drummed thorium sludge was tran

222), thoron (Rn-220), and actinon (Rn-219) were present at
sing and separation of Pa-231 and Ac-227. Thorium sludge
perations was stored outside in drums from 1954-66. In
ferred to Building 21.

Mound Plant

‘Table 7-1: Radon Isotope Survey Data by Building and Time Period
2 Gas concentration (pCi/I) -1
t Survey Radon Thoron Actinon ‘WLM yr’
Building i dates (Rn-222) (Rn-220) (Rn-219) WL &
SW Tunnel ” 10/12/79 88,000 28,000 640,000 na n/a
SW-19 before vent a 6/79-10/79 67-160 :
SW-19 after vent 3/80-4/80 7.7-13.4 i . 0.03 0.4
12/89 26 | Not
i Detected
12/99 1.0-5.8°
4/00 0.7-7.2
: b 1998-2000 5.8-12 .
SW-21 5/83 17.5-52.8 {nla nla n/a n/a
. t 12/89 34-118 | 0.3-0.7 0.4-1.3 4.7-15.3
yey “| 4/90-6/90 117-161 : 0.85 10.0 median
: {oe 125 : : os median | 4
SW-22 : 6/90 125 nla n/a n/a n/a
SW-48. . : 12/89 3.2 | nla n/a” nla n/a
Old SD ‘ 12/89 + 1.5-2.4 (nla n/a nla nla
Fire station ‘ 12/89 nla nia" nla na
Paint shop z 12/89 nla nla nla nla
A ‘ 10/88-2/89 nla nla nla nla
All other buildings —_é 12/89 5 nla nla nla nla
Outside facilities q 5/83 ' nla nla n/a n/a
Reported background , nla nla nla nla
i Al

a. Working level months per year (WLM yr") were
b. Bolded concentrations were derived from charcoal

1

4
The SW-19 Building had elevated radon
processing wastes. On October 12, 1979,
tunnel were measured‘at 88,000 pCi/I Rn.
Rn-222 concentration of 88,000pCi/I wou

ae .
Jetermined as WL (2000 hr yr ') 0/170 br WLM"),

canister measurements.

oncentrations emanating from radium and thorium

inert gas concentrations in the SW Building underground
222, 28,000 pCi/I Rn-220, and 640,000 pCi/l Rn-219. A
id correspond to 352 WL, assuming an ICRP 50 indoor

mean radon daughter ‘equilibrium factor of 0.45 (ICRP, 1987). The tunnel was not an occupied work

area; however, elevated.concentrations of|

areas. Measurementsiof Rn-222 near an
. t

A ventilation system was installed in earl

system reduced Rn-222 concentrations in

with continuous measurements from 7.7 p

radon were transported from the tunnel into SW-19 work
mployee’s desk ranged from 67 to’160 pCi/I in 1979.

1980 to vent S'W Building tunnel air (Meyer, 1992). This

SW-19 by a factor of 10 or more. This result was confirmed
Ci/I to 13.4 pCi/l. A working level (WL) measurement by

62 of 95



June 7,2007

Mr. Larry Elliott

Director, Office of Compensation Safety and Health
4676 Columbia Parkway, MS C-46

Cincinnati, Ohio 45226

Dear Mr. Elliott:
Subject:  Speciat Exposure Cohort Petition

Please find enclosed my petition along with former employees, petitioner #2 _ and
petitioner #3 designate a class of employees of the Mound Plant in
Miamisburg, Ohio to be included in the Special Exposure Cohort (SEC) under the EEOICPA of
2000. The period of activities covered by this is 1943 to 1970.

The work at Mound was performed in one of the earliest environments where nuclear materials
were processed, with exposure controls that, although normal at that time, would be deemed
unsuitable by today’s standards. Very limited, if any monitoring and exposure data are available
for the time period involved, and there are significant uncertainties regarding the monitoring
techniques in place at that time. It is likely that radiation and chemical exposure doses during
this period could have endangered the health of members of this class of employees and it is not
feasible to estimate exposures with reasonable accuracy.

I appreciate your efforts to assist the former employees and their surviors through the
SEC process.

Thank You

Sincerely,



SEC-00090 12-19-07 Mound Plant

¢ PROC: Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC-0060,
Rev. 01; June 28, 2006; SRDB Ref ID: 29986

¢ PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, Rev. 01;
July 21, 2006; SRDB Ref ID: 29987

4.3 Facility Employees and Experts

To obtain additional information, NIOSH interviewed 21 former Mound employees. In-person or
telephone conversations were held with 20 of the former employees. Questions were developed and
refined for each conversation to correspond to the former employee’s job title and work experience.
For one interviewee, a questionnaire was sent and returned by e-mail.

Interviewee selection was based on individual availability, information regarding job description, and
potential knowledge of Mound working conditions during the period of the proposed class. The
interviews ultimately included employees representing a wide range of Mound experiences, including
records management, health physics, internal and external dosimetry, knowledge of site operations,
and radiological incidents. Information obtained during the interviews contributed to the general
knowledge of Mound conditions and monitoring practices and included information regarding records
from the T building that were buried at the Los Alamos National Laboratory.

Several interviews were conducted'in August 2007, but the majority was conducted during late
October and early November 2007. In general, the information obtained was consistent with that
found in NIOSH documents regarding the Mound Site.

¢ SEC ER-related Interview by ORAU Team with Chief Counsel; October 30, 2007; SRDB Ref ID:
36860

e SEC ER-related Interview by ORAU Team with Assistant HP; October 29, 2007; SRDB Ref ID:
36862 . .

¢ SEC ER-related Interview by ORAU Team with Records Manager; August 9, 2007; SRDB Ref
ID: 35950

e SEC ER-related Interview by ORAU Team with Records Manager November 8, 2007; SRDB Ref
ID: 36867

¢ SEC ER-related Interview by ORAU Team with Research Chemist; October 30, 2007; SRDB Ref.
ID: 36866

e SEC ER-related Interview by ORAU Team with Custodian, RCT; October 29, 2007; SRDB Ref
1D: 36869

e SEC ER-related Interview by ORAU Team with Research Chemist, Group Leader; November 6,
2007; SRDB Ref ID: 36870

13 of 95



SEC-00090

Mound Plant

7.2.1 Process-Related Internal Doses

The following subsections summarize th
reconstructing the process-related interna
information on the individual topics can
and (King, 1995).

7.2.1.1 Tritium

Extensive use of tritium began at Mound
possible prior to that.time. Most of the tr
uptake of tritiated water (HTO), which is,
assessments at Mound were reliably mea
1957. Measured doses are modified to re
the Mound Occupational Internal Dosime
unmonitored exposures are also provided
available tritium urinalysis results are sufi
doses.

7.2.1.2 Polonium-210 Operations

Full-scale separation of Po-210 from irra
Building from 1949 to 1971. Facilities a
decontamination laboratories, a storage pt
and analytical laboratories. Po-210 was 4
sludge materials with 0.02 Ci/I total alph

and electrodeposition studies from 1948 t

from 1956 to 1961. Po-Be sources were
support various weapons programs. Polo}
generators (King, 1995). Intakes of polo:
data that existed as early as 1944.

The SW Building was used for counting
verification, and Po-209 and Po-210 retri
Po-210 were present in the WD and WD.
polonium nitrate and polonium chloride

As discussed in Section 6.0 of this report,

database during the Pre-1989 Dose Asses|
from original logbooks and data cards. P'
spanning from 1944-1973.
These data may be supplemented with av:
bounding dose. .

i

12-19-07

lat Mound

extent and limitations of information available for *
| doses of members of the proposed class. More detailed
e found in Section 6.1 of this report and in (Meyer, 1992)

i

in the mid-1950s, and some limited exposure may have been
itium exposure at Mound was assumed to be related to the
effectively monitored using urine bioassay. Tritium dose
sured using standard assessment methodologies starting in
iflect current dose models as discussed in Section 5.3.1.1 in
try TBD (ORAUT-TKBS-00] 6-5). Recommended doses for
in the referenced section. The quantity and quality of

ficient for estimating maximum doses or precisely estimating

. . : : iF
diated bismuth took place on the second floor of the.T: *
d activities included neutron source calibration,

ol for.irradiated bismuth slugs, neutron source processing,
Iso present in Building HH from 1949 to 1959; generating »
activity. Use of Po-210 in the R Building involved research
10 1951, and the manufacturing of Po-Be neutron sources

first manufactured at Mound as neutron source initiators to
hium was later used to produce Po-210 heat source

ium and the resulting dose may be calculated using bioassay

aa

0-210 sources, neutron source measurement, source strength
val. Aqueous wastes containing Po-208, Po-209, and

\ Buildings beginning in 1949. Chemical forms included
eyer, 1992). |

MIW placed Po-210 bioassay data in the PORECON
ment Project after evaluating individual dosimetry files
ORECON contains over 207,750 individual sample results

ilable process information to estimate a reasonable

58 of 95



Special Exposure Cohort Petition U.S. Department of Health and Human Services

unoer the Ercgy Empoyees Cxe.o2t 701 Centers for Disease Control and Prevention
ass Compensation Ac National Institute for Occupational Safety and Health

. . OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Appendix — Petitioner 3

COTS

Use this Appendix for Petitioner 3.

This appendix form is to be used as needed. Petitioner 3, or his or her representative, should complete the
parts applicable to him or her.

Refer to the General Instructions on completing petitioner Information for Parts A, B, or C.

f you need more space to i ditional information, use the continuation page provided at the end of
tne form and attach tne completed cont nsation page(s) to Form B.

Except for signatures, please PRINT all information clearly and neatly on the form.

An Energy Employee (current or former), Start at C
if you are: |G A Survivor (of a former Energy Employee), Start at B
O A Representative (of a current or former Energy Employee), Start atA .

epresentative: informatio omplete: Section A if you are authorized:-by a pio

§):to,petition.
ft aati

AA Are you a contact person for an organization? O Yes (Go io A.2) Q No (Go to A.3)

A.2 Organization Information:

Name of Organization

Position of Contact Person
A3 Name of Petition Representative:

Mr/Mrs/Ms, First Name Middle Initial Last Name
A4_ Address:

Street Apt # P.O. Box
City State Zip Code
A.5 Telephone Number: d

A6 — Email Address:

A? OQ Check the box at left to Indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization
form for this purpose is provided.

: Ifyou are representing a Survivor, go to Part B; if you are representing an Employee, go to Part Cc.

Name or Social Security Number of First Petitioner:



Tab E

Board Recommendation Letter to Secretary Leavitt



Special Exposure Cohort Petition U.S. Department of Heatth and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention

(llhess Compensation Act . National Institute for Occupational Safety and Heath
OMB Number: 0920-0838 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 7 of 7

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Emptoyees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an institute of the Centers for Disease
Control and Prevention. information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 08-20-147 “Occupational Health Epidemiotogical Studies and EEOICPA Program Records.
HHS/COC/NIOSH.” These records are treated in a confidential manner, untess otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
Tetrieve records required by NIOSH; (b) Kfentified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressionai staff member in response to a verified inquiry.

This notice applies to all forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these

forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Patitions that fail to
provide required information may not be considered by HHS.

Viton Rersey oie

Name or Social Security Number of First Petitioner.



SEC-00090

Mound Plant

Later efforts to recover Pa-231 used a la
refining process called Cotter Cake. Thi
radionuclides during :research associated
hundred-fifty-one drums of this material
built in the SW building. This plant ran
recover 339 g. of Th-230 and 890 mg of

5.2.7 Rare Isotopé Programs

The Rare Isotope Programs were original
Heavy Element Isotopes. They began in|

|
12-19-07 |

ge amount of another type of residue from the uranium
material.had been identified as a useful source of

ith the Ionium| (Th-230) Program. One thousand, two

ere received during 1975 for processing in the pilot plant
rom 1974 to 1979, during which 22 drums were processed to
protactinium.

ly known as the Separation and Purification of Special
the mid-1950s and lasted through 1985. Numerous projects

were developed during that 30-year peridd. A variety ofiradionuclides and separation processes were

generally carried out in the SW, SM, and R buildings. Principal processes included:

Extraction of Pa-231 and Th-230 fro
Extraction of Th-229 from U-233 (fr
Extraction of Pa-231 from irradiated

5.2.8 Uranium-234 from Plutonium-

. About ten grams per. year of U-234 were|
1970s. The U-234 oxide was shipped to
measurements. U-234 was produced wi
solvent extraction system was in Room

Most of the Pu-238 was initially precipit

'

Extraction of U-234 from aged Pu-238 from 1962-1972

uranium ore “tailings” from 1954-1957
m irradiated Th-232) from 1966-mid 1970s
[Th-230

38

extracted from base from the mid-1950s through 'the earl

Oak Ridge for use with U-235 to make neutron flux °

hin 13 alpha glove boxes in the R Building. An associated |
of the SM Building. pee

ly
aT

ited as the oxalate. Pu-238 from returned heat sources was

dissolved in nitric acid and then precipitated with dimetHyloxalate. The filtrate contained the U-234.

The Pu oxalate was calcined at 450° C ai
processing. Following evaporation and
uranyl nitrate. After pH adjustment, the
adsorbed the U-234.. Uranium was elutes
nitric acid eluted plutonium. Urany] nit
exchange column. Uranium, plutonium
concentrations of hydrochloric acid. Ur:
ammonium hydroxide. The filtered pre

In SM-1, U-234.was recovered from ion|
octylphosphine oxide (TOPO). The aqui
TOPO was stripped by a carbonate solu
recycled through thé process.

id returned to storage to permit in-growth of U-234 for future
addition of nitrid acid, aluminum nitrate was added to the
solution passed ‘through an ion exchange column that

id from the columns with 7N nitric acid while 0.35 molar

fate was converted to the chloride and passed into an anion
and neptunium were distinctly eluted with varying

nium chloride was precipitated with the addition of

ipitate was washed, dried, and converted to uranium oxalate.

exchange raffinate solutions by extraction with tri-n-
eous phase was {sent to plutonium recovery. Plutonium in the
ion and also sent for recovery. The remaining TOPO was

24 of 95:



SEC-00090 12-19-07. Mound Plant

Meyer, 1994, History of Personnel External Dosimetry Program at the Dayton Project and Mound
Laboratory 1946-1993; H. E. Meyer; Mound Laboratory; SRDB Ref IDs: 3268, 3276, 3281, 3297,
3299, 3303, 3315

Meyer and Reeder, 1992, Plutonium Historical Dose Reconstruction Program, Herbert E. Meyer and
Dianne L. Reeder; Mound Laboratory; July 31, 1992; SRDB Ref ID: Not currently in SRDB

Meyer, date unknown, Enclosure #6: Thorium 232 - Mound Facility, by H. E. Meyer; Mound
Laboratory; historical overview; date unknown; SRDB Ref ID: 12700

MJIW, 1998, Pre-1989 Dose Assessment Project, Phase I Interim Report, Volume 1; MJW
Corporation, Inc.; June 15, 1998; SRDB Ref ID: 8667

MJW, 2002, Phase I, Pre-1989 Dose Assessment Project, Phase I Final Report, Volume 1; MJW
Corporation, Inc.; April 2002; SRDB Ref ID: 8745

MJW, 2002, Phase II, Pre-1989 Dose Assessment Project, Phase II Final Report, MJW Corporation,
Inc.; June, 2002; SRDB Ref ID: 8738

Monex, 1955, Development of the Monex Thorium Refining Process through the Pilot Plant Stage,
Final Report, by F. C. Mead, et al; MLN-1072; Mound Laboratory; December 31, 1955; SRDB Ref
ID: 12798

Mound, 1999, Work Plan for Environmental Restoration of the DOE Mound Site, The Mound 2000
Approach, Final, Rev. 0; Feb 1999; SRDB 12624

Mound, 2002, Mound External Dosimetry Data, Cincinnati Operations Center Terminal Server,
O:\DOE Site Jmages\Mound\07-25-03-Data Capture\010000993.pdf, downloaded September 9, 2003,
ORAU Cincinnati Operations Center, Cincinnati, Ohio.

Mound Laboratory, 1968, Bioassay Group Analytical Procedures, Technical Manual MD, Issue |
(TM-20736); Miamisburg, Ohio; 1968; SRDB Ref ID: 4097

Mound Laboratory, 1981, Tritium in Water, Technical Manual PD-80030, Issue 1 (TM-80030),
Environmental Analytical Procedures; Miamisburg, Ohio; 1981; SRDB Ref ID: 1962, page 688

Mound Laboratory, 1996, /nternal Dosimetry Technical Basis Manual-Appendix D, Technical Manual
MD-10435, Issue 4, (TM-10435), Miamisburg, Ohio; 1996; SRDB Ref ID: 2537

Mound Po, various dates, Information File #2: Misc. Po-210 Documents; various authors; various
dates; Mound Laboratory; SRDB Ref ID: 8746

NBS, 1953, Maximum Permissible Amounts of Radioisotopes in the Human Body and Maximum

Permissible Concentrations in Air and Water, Handbook 52; National Bureau of Standards; U.S.
Department of Commerce, Washington, D.C.; SRDB Ref ID: 12332

93 of 95



SEC-00090 12-19-07 Mound Plant

several days, he had not done this. At this time, the Records Manager reported the event to the
company attorney who called Security and requested the dispatch of security personnel to the
employee’s home to retrieve the records. This is not an SEC issue.

77 of 95



SEC-00090 12-19-07 Mound Plant

From 1992-1995, as part of the Non-Nuclear Reconfiguration Project, all types of records were
identified and shipped to six different DOE facilities/ Federal Records Centers. These records
included classified, unclassified, active, and inactive records. In 1994, in preparation for the transfer
of records, random sample radiation contamination surveys were performed on the inactive classified
record collection located in the vault of the T-building at Mound. Some of these records were found
to be contaminated with several different radionuclides. As a result, the entire collection in the T
Building vault was declared contaminated and the vault subsequently designated as a Radiological
Control Area. LANL ultimately agreed to accept the classified, contaminated records with the intent
to image them, destroy the originals, and administer access to the imaged data. DOE Weapons
Quality Division agreed and directed Mound to transfer the collection to LANL. Shipment occurred
in 1995. LANL had planned to inventory the records upon their arrival because many of the boxes
contained records supporting DOE nuclear production and would likely have been classified as DOE
Schedule 3 (Nuclear Records). Based on the available information, NIOSH has found no evidence
indicating that the collection contained primary, employee-specific dosimetry records. The original
employee- specific health physics records were filed by employee name within the Mound
Occupational Radiological Exposure (MORE) Records Center.

In preparation for shipment, boxes from the T Building were brought to the entrance of the classified
vault. The Records Manager at Mound identified the box contents from the affixed label and
documented the contents on the Reconfiguration Records Transfer sheet. Each sheet represented a
box and a copy of all completed Reconfiguration Records Transfer sheets were sent to LANL. i
Approximately 458 cubic feet of classified, contaminated records were shipped to LANL. -Items in
the boxes included production records for classified programs, industrial X-rays, classified material
accounting, health physics log books and a substantial number of uniquely numbered research log
books. The researcher’s laboratory notebooks were primarily filled in during the 1950s and 1960s.
They are not believed to be the kind of files that would have recorded radiation exposure information
in them, but instead, dealt with the details of their particular research project’s progress. (Long, 2007
p. 164, 168) The Classified Document Control function maintained a file index that cross-referenced
the employee name who received the log notebook. This file index was eventually scanned and is
retrievable at OSTI.

On May 13, 2003, LANL requested and received approval from NNSA/AL to destroy and dispose of
(i.e., bury) the T Building collection.

Laboratory notebooks were part of the burial that may have included information on personal
dosimetry or bioassay results. The information in the notebooks is not believed to be the primary
dosimetry information because all health physics-related information was kept in the MORE records
database. Therefore, any included information would not be considered primary data. The buried
data are not crucial to complete a dose reconstruction with sufficient accuracy. Bioassay and
dosimetry records are routinely in the individual’s personal dosimetry file. MORE (established in the
late 1980s) kept all employee-specific exposure records, radiological incident reports, and visitor
exposure records.

Approximately two years after the T Building collection was shipped to LANL (~1998), Mound

contracted with MJW Corporation to perform a Pre-1989 Dose Reconstruction Project. A scientist
from MJW Corporation went to LANL and reviewed a selection of the T Building records. The

79 of 95



THE SECRETARY OF HEALTH AND HUMAN SERVICES
WASHINGTON, 0.C. 20201

MAR - 3 2008

The Honorable John A. Boehner
Minority Leader

United States House of Representatives
Washington, D.C. 20515

Dear Congressman Boehner:

Pursuant to the Energy Employees Occupational Illness Compensation Program Act of
2000 (EEOICPA) and 42 C.F.R. pt. 83, a petition was filed on behalf of workers from the Mound
Plant near Dayton, Ohio, to be added to the Special Exposure Cohort (SEC).

The Centers for Disease Control and Prevention’s (CDC) National Institute for
Occupational Safety and Health (NIOSH) evaluated the petition and presented its findings to the
Advisory Board on Radiation and Worker Health (Board) on January 8, 2008. The Board
considered the petition, and on February 1, 2008, I received the Board’s recommendation
concerning this petition. I have also received the deliberations, findings, and recommendations
of the Director of NIOSH and the Director of CDC. I have designated the following class for
addition to the SEC:

Employees of the Department of Energy (DOE), its predecessor agencies, and
DOE contractors or subcontractors who worked in any areas at the Mound Plant
site from October 1, 1949, through February 28, 1959, for a number of work days
aggregating at least 250 work days or in combination with work days within the
parameters established for one or more other classes of employees in the Special
Exposure Cohort.

The criteria and findings upon which this designation is based are provided in the enclosed
report.

Please call me if you have any further questions regarding this matter.

Sincerely,

Michael O. Leavitt

Enclosure



SEC-00090

12-19-07 Mound Plant

file cards. The file cards were used from
Volume I, 1963 Appendix III, p. 263).
entered on Form 1333. This form, whic!
handling of daily records, remained in ug

The External Radiation Analysis Data (E
Environmental Safety and Health (MES
The MESH database'contains all measur
annual summary dose is available for ye
overestimation of employee doses; howe}
claimant-favorable assumptions to calcu
potential dose received by an individual
(called the limit of detection, or LOD).

Early neutron dose measurements were
These film dosimeters likely responded ij

March 25, 1963, until December 27, 1963 (Meyer 1994,
eginning on December 30, 1963, pocket dosimeter data were
permitted the use of a Rolodex V-File for more efficient

ic through May 1966. 1
IRAD) program replaced EXAS in 1978, and the Mound
1) program replaced ERAD in September 1989. 1
\ - :

ed employee radiation doses since 1947, although only the
is before 1977.: Annual doses are sufficient for |

er, the lack of individual dosimeter cycle data requires
late missed external doses. Missed external dose is the
below the technological limit of the dosimeter to detect

nade using neutron track emulsion, Type A (NTA) film.
a manner proportional to the doses received for early

Operations at Mound, resulting in neutron doses due to the relatively high-energy spectrum associated

with neutrons from Po-Be sources. Othe}
"

Obviously, many changes have occurred
record-keeping practices. As described }
for total program reconstruction was not
operation (Meyer, 1994). In practice, m4
than developing the records themselves.
program and dosimetry performance are
significant administrative practice that wI
Many of these documents are referenced
Personnel External Dosimetry Program
(Meyer, 1994), and in the SRDB. Progrd
available in the SRDB.

i
7.2. Internal Radiation Doses a

we dps wae
The principal source:of internal radiation

inhalation and ingestion of radiological contamination during the following operations:

.
and neutron sources for other uses

j

Research for altetnatives to Po-210 fi

Po-210 required the frequent re-many

used on a variety of missions to provi
j :

Research and development (R&D) off fabrication of neutron sources for nuclear weapons’

Radioisotope thetmoelectric generata

Tritium-handling technologies that su

r Operations had lower average-energy neutron spectra.

over time with regard to Mound’s dosimetry program and
y Meyer, the need for a “some day in the future” capability
a well-defined “need,” especially in the early decades of «
intaining controlled record storage was more of a challenge
[Nevertheless, a large number-of documents describing the
available. After evaluating these, NIOSH identified no
puld jeopardize the integrity of the recorded external dose.
in ORAUT-TKBS-0016-6, incorporated into the History of
at the Dayton Project and Mound Laboratory 1946-1993

im descriptions and assessments for later years are also

t Mound

dose for members of the proposed class would have been

itiators

r Use in weapons initiators (because the short half- life of
facture of the initiators)

irs (RTGs) and radioisotope heat sources, which have been
de heat and electric power

jpported weapons and non-weapons programs

56 of 95 |



SEC Petition Evaluation Report
Petition SEC-00090

Report Rev #:_0 Report Submittal Date: December 19, 2007
Subject Expert(s): Karin Jessen, Tim Adler, James Berger, Don Stewart
Site Expert(s): Elizabeth Brackett‘

wit oo Petition Under Evaluation

ees Petition # = .| Petition - Petition B DOE/AWE Facility Name
roktied Type Qualification Date a
SEC-00090 83.13 August 17, 2007 Mound Plant

Petitioner Class Definition

All employees who worked in all areas within the boundaries at the Mound Plant from February 1949 —
present.

Proposed Class Definition

All employees of the Department of Energy (DOE), its predecessor agencies, and DOE contractors and
subcontractors, who were monitored or should have been monitored, for internal Ra-Ac-Th exposures while
working in all areas of the Mound site for a number of work days aggregating at least 250 work days from
October 1, 1949 through February 28, 1959, or in combination with work days within the parameters
established for one or more other classes of employees in the SEC.

Related Petition Summary Information

SEC Petition Tracking #(s) | Petition Type DOE/AWE Facility Name Petition Status
SEC-00091 83.13 Mound Plant Merged with SEC-00090
Related Evaluation Report Information : :
Report Title : |__DOE/AWE Facility Name
None

ORAU Lead Technical Evaluator: Karin Jessen ORAU Review Completed By: Daniel H. Stempfley

Peer Review Completed By: [Signature on file] 12/19/2007
Brant Ulsh Date

SEC Petition Evaluation Reviewed By: [Signature on file] 12/19/2007
‘Stuart Hinnefeld for J. W_Neton ~ Date

SEC Evaluation Approved By: [Signature on file] 12/20/2007

Larry Elliott Date



SEC-00090

12-19-07 Mound Plant

{

These actions are based on existing, app:
claims under EEOICPA. NIOSH’s guid
ensure that the assumptions used are fair,
Simultaneously, uncértainties in the scie
the detriment, of the ‘petitioners. When a
available, or is very limited, NIOSH ma:

reliable science, documented experience.
reconstructing the dose of an SEC petitiq
performance in determining that it would
this petition. .

ioved NIOSH processes used in dose reconstruction for

ng principle in conducting these dose reconstructions is to
consistent, and well-grounded in the best available science.
ce and data must be handled to the advantage, rather than to
idequate personal dose monitoring information is not

use the highest reasonably possible radiation dose, based on
and relevant data to determine the feasibility of

n class. NIOSH has complied with these standards of

be feasible to reconstruct the dose for the class proposed in

88 of 95 |



SEC-00090 12-19-07 Mound Plant

the employee’s desk following ventilation system installation was 0.03 WL or 0.03 (12 mo/yr) = 0.4
working level month (WLM) compared with an occupational limit of 4 WLM/yr (King, 1995).

A DOE radon study was conducted from December 12-15, 1989, to measure radon in various Mound
buildings (UNC Geotech, 1990). The majority of buildings had radon concentrations below 1.0 pCi/I
Rn-222, except SW and Old SD buildings. In June 2000, a radon study summary report was issued
based on 1990 and 1999 measurements (BWXT, 2000). Mound site radon background was reported
to be 0.5 pCi/l with a range of 0.1 to 2.1 pCi/I.

SW-19 was the only building at Mound identified as an area of potential occupational exposure to Rn-
222 and Rn-220 (King, 1995). Rn-220 and Rn-219 measurement results were very limited despite the
high concentrations observed in the underground tunnel. The only Rn-219 measurements were made
in Building 21 at 0.3 to 0.7 pCi/l, but the holding time before analysis was excessive compared to the
four-second half-life of Rn-219. The only Rn-220 measurement in SW-19 was below detection. Rn-
220 and Rn-219 exposures would not be detectable in excreta by bioassay due to very short half-lives.
(ORAUT-TKBS-0016-5).

The WLM values in Table 7-2 have been used to reconstruct doses for EEOICPA claimants suspected
of having been exposed to radon in air. All WLMs have been assumed to be median values of
lognormal distributions with a geometric standard deviation (GSD) of 3.0.

To reconstruct missed doses, a background radon concentration of 0.5 pCi/I can be used, which
converts to 0.03 WLM indoors assuming 100% occupancy and 0.45 (ICRP, 1987).

Table 7-2: Radon-222 WLM Assumptions for Dose Reconstruction

Radon Radon Radon

Building conditions Period (pCi/L) (WL) (WLM)

[SW Tunnel Prior to Ventilation 1949-1979 88,000 352 4,100
SW-19 Ra-Ac Pilot Project 1949-1952 160 0.72 8.5
SW-19 Ra-Ac Old Cave Production 1952-1960 160 0.72 8.5
SW-19 Post Production, Prior to Ventilation 1961-1979 160 0.72 8.5
SW-19 Post Production, Post to Ventilation 1980-1995 0.7-13.4 0.03 0.4
SW-21 1952-1995 17.5-125 0.85 10.0
SW-22 1966-1995 125 0.56 6.6
SW-48 1980-1995 3.2 0.01 0.2

Descriptions of radiation protection activities in periodic health physics report demonstrate that the
health physics program was considering short-lived air activity to the extent that this activity was
routinely reported through the era of radium and thorium processing, and Pa and Ac separation. For
periods outside these years, and for which air concentrations are not available, doses may be estimated
based on the measured air concentrations and scaled based on the available source term, as determined
in the available process information. Maximum exposures may be determined with sufficient
accuracy to determine a maximum bounding dose.

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SEC-00090 12-19-07 _. Mound Plant

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