[Rffective Date: Revision No. Pocument No. |Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 9 of 61

In this section, a brief summary of the issues are presented, followed by a summary of the
primary findings. (Primary Findings, along with Secondary Findings, are further detailed in
Section 3 of this report), SC&A then provides a discussion of the strengths of the TBDs,
followed by recommendations for improvement at the end of this section, which are listed as
Observations.

Summary of Issues

SC&A found that detailed documentation of radiation hazards, surveys, and potential exposures
were not readily available or do not exist for the WS site, especially for the operational period of
1957-1966 or the maintenance period of 1967-1984. Therefore, the underlying problem with
the TBDs for the WS site is that they rely on recent WS site data (1985-2002), recent and some
previous era environmental data, and very limited operational-period onsite data. Because of the
limited WS site data and documentation, NIOSH also relied heavily on the Fernald site data and
extrapolated it to the WS site TBDs. Unfortunately, the data/assumptions used for the Fernald
site TBD are frequently estimates, instead of the results of measurements or documented
information. Additionally, relatively recent data for the Fernald site was sometimes extrapolated
to earlier time periods when sufficient data did not exist. The SC&A review of the Fernald site
profile (SC&A 2006) points out the shortcoming of using these assumptions/data at the Fernald
site. Understandably, SC&A has reservations concerning applying these questionable
concepts/data from the Fernald site to the WS site profile.

During the operational period, the WS site had a basic uranium bioassay and beta/photon
badging program in place, and a limited site-parameter environmental monitoring program.
However, the lack of routine personnel/egress contamination monitoring, consistent and
documented badging policy (with geometry correction factors), comprehensive bioassay program
that encompassed all the major radioisotopes brought on site, and an onsite environmental
monitoring program for unmonitored workers leads to gaps in some of the information and data.
NIOSH attempted to fill in some of these gaps with extrapolated operating conditions and data
from other DOE sites. SC&A found some of these recommended methods to be uncertain, not
sufficiently supported, or in some cases, poteritially not claimant favorable. Additionally, a site
profile should evaluate the accuracy, adequacy, and representativeness of the workers’ recorded
internal and external dose data. SC&A could not find that NIOSH had performed a sufficient
analysis of this type.

The majority of material handled at the WS site was natural uranium. In addition, some RU, EU,
and DU were also handled at the WS site, along with natural thorium. NIOSH acknowledges

this in the WS site TBDs and makes some provisions for it, but concludes in general that because
uranium is the most prevalent, it will dominate dose reconstruction. However, it cannot be
assumed that because the majority of the material handled was nati
radionuclides are of a minor issue. Some workers invoived in spe:
these other radionuclides (and workers in the vicinity) had the potential of recei
doses trom these other radionuclides.

ig subsiaritial

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisiona} and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Lack oF
mon doris

Effective Date: ~~ fRevision No, [Document No, — rage No.
February 10, 2009 0 SCA-TR-TASK1-0028 30 of 61 |

received two sets of chest x-rays in a period of 9 months or less (excluding x-rays for termination
of employment);the files do not provide reasons for this.” (This would equate to an overall
average of 1.25 x-ray exams per worker per year.) In the last paragraph of Section 3.1.2

(page 7), it suggest an x-ray exam was conducted every 2 or 5 years for post-1985 workers. And
in the next to the last paragraph on page 13 of the TBD, it recommends annual chest x-rays for
1958-1964.

While the frequency of x-ray exams are discussed in Section 3.1.2 of TBD-3 (ORAUT 2005c),
no mention is made of the frequency of retake exams (because of technical or medical
complications) that might add to the total number of x-ray exams performed. ORAUT-OTIB-
0006 (ORAUT 2005g, page 14) states, “Retakes should serve as a signal to give special
consideration to the evaluation of technique factors, and hence the resultant dose calculations.”
This indicates that retakes were not an uncommon event.

TBD-3 (ORAUT 2005c) should recommend a defined set of claimant-favorable x-ray exam
schedules, so that dose reconstructions can be performed in a consistent manner. It should also
be determined if some workers or groups of workers [such as those that wore respirators, were
food handlers (tested for tuberculosis), etc.] may have had more frequent x-rays exams; perhaps
this was the reason for the increase in frequency as noted in Section 3.1.2 of the TBD.

Finding #7: Photofluorography Exams Not Adequately Addressed

TBD-3 (ORAUT 2005c) mentions photofluorography (PFG) exams on page 7. However, no
recommendations to the dose reconstructor are made concerning this type of exam, other than
that there had not been any indications that PFG exams were conducted at the WSCP. ORAUT-
OTIB-0006 (ORAUT 2005g, page 21) states, “It is reasonable to presume that at least some of

7 the occupational medical diagnostic chest x-rays with the DOE and its predecessor organizations

“ were accomplished by PFG and, in the absence of data to the contrary, the use of PFG should be
assumed to ensure claimant-favorable dose reconstructions.” Table 7-6 of ORAUT-OTIB-0006
(page 24) also indicates that DOE/AEC facilities used PFG equipment from 1953~1968, which
would encompass the 1957-1966 operating period at WSCP. If PGF equipment was not located
at the WSCP site, workers may have had occupational PFG exams performed at offsite locations,
such as Barnes Hospital Labs, which serviced MCW workers in the earlier years. TBD-3
(ORAUT 2005¢c) does not show evidence of investigating this subject sufficiently (such as
checking Missouri state records, etc.) to justify discounting the possibility that some WS site
workers received PGF exams.

Finding #8: Lumbar Spine Exams Not Addressed

TBD-3 (ORAUT 2005c) makes no mention of lumbar spine x-rays and states on page 7 that,
“Therefore, the analysis for this TBD assumed annual PA and LAT chest x-ray examinations for
all employees, and considered no other view.” This excludes both PFG and lumbar spine exams.
Lumbar spine exams were sometimes performed for workers that performed heavy and strenuous
work, such as laborers and construction workers, or those with back problems. ORAUT-OTIB-
0006 (ORAUT 2005g, page 21) states, “However, the possibility of periodic lumbar spine
examinations, including an exit employment physical examination should not be precluded.”
Therefore, TBD-3 should address the issue of lumbar spine exams for WS site workers,

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requitements of 42 CFR 82.


Effective Date: [Revision No. |Document No. age No.
|_ February 10, 2009 0 SCA-TR-TASK3-0028 26 of 61

Sections 4.2.2.2 and 4.2.32 of TBD-4 (ORAUT 2005d); Sections 5.3.2, 5.4.2, 5.5.2, 5.5.3, and
5.6.2 of TBD-5 (ORAUT 2005¢); and Sections 6.1.3.2 and 6.1.3.3 of TBD-6 (ORAUT 2005f) do
not contain sufficient information for the dose reconstructor to be able to assess dose to
claimants who may have worked for DOE or its contractors at the WS site during 1967-1984. If
DOE contract personnel were present at the WS site soon after the shutdown in December 1966,
they could have been exposed to numerous radionuclides during decommissioning, clean out,
and revamping the facility for a completely different use. Because uranium was viewed as a
chemical rather than a radiological hazard at that time, sufficient controls and monitoring
practices may have not have been in place. This was more likely to occur during the time period
immediately following plant closure, because the MCW health and safety infrastructure at the
WS site was no longer in place. Plant operating protocol would not have been in enforced;
buildings and equipment were considered surplus, and supplies/materials (including leftover
radioactive material or contaminated material) would have been considered a nuisance and
disposable. Working under these conditions could have created a mindset that radiological
safety was not an issue (for both the contractor and the workers). This could have lead to
incidences of skin contamination, inhalation, and ingestion of radioactive materials (including
uranium and thorium, as well as radionuclides contained in the raffinate concentrates and its
scale/soil that had been resuspension) that were not monitored or recorded, or grossly
underestimated.

It should be determined if there were DOE or DOE contractor shutdown personnel,
decontamination and decommissioning workers, or clean-up crews during the years immediately
following the 1966 closure, and if there were guards and security staff during the period 1967—
1984. If DOE employees and DOE contractors were present at any of DOE’s WS facilities
during the period 1967-1984, the TBDs need to be revised to include this period of dose
evaluation for the site. Therefore, the issue of Jegal ownership of the property (and Jiability) as a
function of time needs to be determine through federal/state/local records to determine if the
TBDs should be revised to include additional periods.

Finding 43: Individual Exposures versus Average Exposures

Ina number of places (ORAUT 2005d, page 11~12, and ORAUT 2005f, page 23), the TBDs rely
on the fact that mostly natural uranium (>97%) was processed at the WS Chemical Plant;
therefore, the contributions from other forms of uranium ( DU, EU, or RU) and other
radionuclides (thorium, radium, etc.) are small compared to natural uranium. Whereas the most
likely exposures (internal and external) may have been from natural uranium, this does not
negate the fact that individuals or certain groups of workers may have been exposed to materials
that contained greater concentrations of other forms of uranium and radionuclides, especially in
or near plant locations dedicated to the other forms of radioactive material processing and in
discharge streams, waste, and raffinate pits.

Calcutating the dose from the radioisotopes that produce 95% or 99% of the dose, as was done in
TBD-4 (ORAUT 20054, pages 11-12), to arrive at the conclusion that natural uranium over-rode
all the other radionuclides is not claimant favorable to some workers monitored for only natural
uranium who may have received a significant fraction of their internal and/or external doses
(either chronic or acute) from other radionuclides. Additionally, non-bioassayed and unbadged

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: Revision No. [Document No. oo [Page No.
February 10, 2009 0 __ SCA-TR-TASK1-0028 __ 350f61

(ORAUT 2005¢, page 14). For example, a 1967 WS site document (WS 1983, page 2) lists the
thorium/uranium (no isotopic information provided) concentrations as 63,600/27,600 = 2.3;
much greater than the 0.05 assumed. Another example is a 1983 WS document (Eberline 1983,
page 10), which shows that the raffinate pits contained much higher concentrations of Th-230 as
compared to U-238. The ratios for sludge samples from the pits were as follows:

Pit #1: (Th-230/U-238) = 33.8
Pit #2: (Th-230/U-238) = 51.1
Pit #3: (Th-230/U-238) = 26.9
Pit #4: (Th-230/U-238) = 2.6

eeee

These samples were analyzed on August 18, 1983; therefore, there was decay product in-growth
during the period from the end of operations to the sampling date (approximately 18 years
compared to 11 years of plant operations). However, the Th-230/U-238 ratios were so much
greater than 0.05, that even a small in-growth, or residual thorium, would exceed the 5% level.
Therefore, the TBD stated value for Th-230 as 5% of the U-238 concentration should be used
with caution as it may not apply to all situations of potential exposure at the WS site during the
operational period.

Finding #15: Natural Thorium-232 Not Always Negligible

TBD-4 (ORAUT 20054, page 9) assumes that because the amounts of natural thorium handled/
processed at the WS site were a small fraction of the total uranium materials handled and
processed, natural thorium is probably not a significant contributor to environmental inhalation
doses during the operational period. This may be true on average, but this assumption does not
consider the fact that some workers or certain groups of workers may have received a substantial
portion of their inhalation dose from thorium and it decay products for a significant amount of
time near a thorium handling process, or from operations that concentrated thorium, such as the
raffinate pits. A 1983 WS document (Eberline 1983, page 10) shows that the raffinate pits
contained significant concentrations of Th-232 as compared to U-238; approximately 20% on
average. A 1965 WS site document (MCW 1965a) concerned with thorium operations states the
following:

It is observed that the pot denitration operations are of marginal adequacy.
Procedures in use for handling the “light” thorium oxide produced visible air
concentrations in open operating areas.... and, ...Control of this situation when
thorium is involved is complicated further due to the unreliability of conventional
bio-assay methods in documenting internal exposures.

This latter statement is supported by an article concerned with the problems of thorium bioassays
even today (Stradling et al. 2004).

Therefore, assuming that Th-232 was insignificant as compared to uranium should be used with
caution as it may not apply to all situations of potential exposure at the WS site during the
operational period.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: [Revision No. Pocunent No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 | 3 of 61

TABLE OF CONTENTS

Acronyms and Abbreviations

1.0 Executive Summary...

1.1 Summary of Primary Findings.
1.1.4 Findings Common to Several TBD:
1.1.2 Findings Specific to a TBD.
1.2 Summary of Strengths............
1.3. Opportunities for Improvement
1.3.1 Observations — General
1.3.2 Observations — Occupational Medical Dose
1.3.3 Observations — Environmental Dose ..
1.3.4 Observations — Internal Dose...
13.5 Observations — External Dose.

2.0 Scope and Introduction

2.1 Review Scop
2.2 Asscessment Criteria and Method:
2.2.1 Objective 1: Completeness of Data Sources.
2.2.2 Objective 2: Technical Accuracy.
2.2.3 Objective 3: Adequacy of Data...
2.2.4 Objective 4: Consistency among Site Profiles
2.2.5 Objective 5: Regulatory Compliance
2.3. Dose Reconstruction under EEIOCPA
2.4 Report Organization

3.0 Vertical Issues........ ssasequeesacresanecesaceennessanecnneessusessees ssueecosessnscsranccanecanecessnerstsusessseresrsssesasersee 24
3.1. Common Issues... 24

3.1.1 Primary Findings 24

3.1.2 Secondary Findings 7

3.2 Specific Issues........... 9

3.2.1 Oceupational Medical Dose ORAUT-TKBS-0028-3 29

3.2.2 Occupational Environmental Dose ORAUT-TKBS-0028-4 . ]

3.2.3 Internal Dose ORAUT-TKBS-0028-5 7

3.2.4 External Dose ORAUT-TKBS-0028-6.. 5

4.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction 0

w
i

4.1 Satisfying the Five Objectives
4.1.1 Objective 1: Completeness of Data Sources
4.1.2. Objective 2: Technical Accuracy
4.1.3 Objective 3: Adequacy of Data...
4.1.4 Objective 4: Consistency among Site Profiles
4.1.5 Objective 5: Regulatory Compliance

4.2 Usability of Site Profile for Intended Purposes .

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


[Sffective Date: ‘(Revision No. [Document No. _ Page No. |
February 10, 2009 0 SCA-TR-TASK1-0028 45 of 61

« There is no supporting evidence that the EU received at the WS site was never >1%, A
WS document (MCW 1966, page 4) states up to 1.5% enrichment.

« Ifthe EU was received from Fernald, there is no guarantee that it was always <1%
enrichment. Fernald’s TBD-5 (ORAUT 2004b, page 9) states the following:

Late in 1964 the Fernald site provided the first production of 1.95% 7*U
billets for the Hanford Site. During the following production years uraniun
was processed in a variety of enrichments ranging from depleted to as high as
20%. The quantities of enriched material above 2% was not documented, but
was qualitatively reported to be small and/or insignificant in total mass. The
reported highest enrichment level processed in quantity was 2%.

« SC&A questioned the validity of the assumption that the Fernald site handled <2%
enrichment in their review of the Fernald site profile (SC&A 2006).

TBD-5 (ORAUT 200Se, page 35) recommends that the dose constructor use 1% EU for the
period 1963-1967. However, as outlined above, assuming a maximum enrichment of 1% is not
supported by the documentation presented.

3.2.4 External Dose ORAUT-TKBS-0028-6

Background and Introduction

The current version of TBD-6 (ORAUT 2005f) covers the operational period 1957-1966, and the
remediation period 1985-2000. The TBD provides some information concerning dosimetry
records, badge exchanges, missing entries, calibration, and workplace radiation fields as a
function of building. Basic coworker gamma and beta dose values as a function of job
description are provided, along with LOD/exchange tables for calculation of missed dose. As
with the other TBDs for the WS site, this TBD draws on information/data from other DOE sites,
such as Fernald, because of the lack of WS site documentation, especially in the area of neutron
exposure, dosimeter response, and radiation field characterization. Overall, the TBD addresses
external doses from gamma, neutron, and electron radiation, but SC&A has areas of concern as
detailed in the findings listed below.

Primary Findings
Finding #25; Shallow and Extremity Doses Not Sufficiently Characterized

Shallow (mainly beta) dose was briefly addressed in TBD-6 (ORAUT 2005f) on pages 12
(dosimeter quantities, OW, SW, etc.) and on pages 20-23 (compared beta dose from NU, EU,
and DU). Electron dose is listed as >15 keV in Table 6-10 concerning energy distribution by
building or area. Extremity monitoring is addressed briefly for the period 1992-1994 on

page 12.

As described in a previous finding, there appears that there was no personal contamination or
egress monitoring at WS during the operations period 1957-1966 to detect contamination on the
workers after they changed clothes and left the operation areas. Additionally, there is no

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Heatth for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: Revision No, [Document No. rage No,
February 10, 2009 0 SCA-TR-TASK1-0028 | AB of 61

may contain job titles, or work locations. Additionally, TBD-2 states the following (ORAUT
2005b, page 20):

“Beginning in 1954 the (cost center) codes changed about once every 6 months.
Documentation of changes was made only to the extent that was necessary to
obtain the money for the UD (Uranium Division) operations from the government
[Dupree 1983}.” Assuming that the practice continued into the WSCP operations
of 1956 and beyond, using cost center codes to help assess worker dose may not
be reliable.

Examples of more useful tables are those in TBD-6 (ORAUT 2005f, pages 17-18).

It is difficult to analyze or compare the excretion rates for the years 1959-1966 {Tables 5-10
through 5-17 of TBD-5 (ORAUT 2005¢)], because cost-center codes changed. Using cost-center
codes as this TBD has appears to be an ineffective way of organizing the data. Additionally,
using cost-center codes to group the data in these tables does not allow the dose reconstructor to
directly use the solubility information provided in Table 5-6, which is listed by area/building
numbers.

The internal dose assessment for WSCP is very complex, because the workers were exposed to
different uranium compounds (or different classes of solubility), as well as natural, recycled,
depleted, and EU, and thorium. Additionally, the measurement technique for urinalysis used at
the WSCP was mainly photofluorimetric, which did not provide sufficient information to have a
reliable dose assessment when there was a mixture of uranium compounds and uranium isotopes.
Based on these facts, it would be more appropriate to have the data grouped according to work
location or job title, such as in TBD-6 (ORAUT 2005f, pages 17-18), to avoid confusion and
possible incorrect assignment of dose.

Finding #23: Negative In-vivo Results Do Not Necessarily Indicate Lack of Thorium
Uptake

TBD-5 (ORAUT 2005e, page 28) indicates that a portable whole-body counter was set up for in~
vivo thorium measurements in 1966. On page 29, it is states the following:

The overall results showed workers involved in areas 101, 103, 301, 403,
Maintenance, and Health and Safety, which were principal exposure positions,
had a more frequent occurrence of ‘trace’ detections. No workers monitored
showed a ‘positive’ designation. (Ingle 1991)

Because the LODs for this bioassay technique were generally very high during that period, the
results of these measurements should not be considered as indicative of a lack of internal
exposure. Hence, measurements recorded as “negative result” should not be interpreted as the
workers not being exposed to thorium. These in-vivo measurements were only performed once
in July 1966; the TBD does not address the issue of workers potentially exposed to thorium in
early periods and if the thorium and/or decay products would be sufficiently present in the
workers” lungs to be detected by this method. Additionally, the TBD did not provide

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: evision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 49 of 61

Additionally, the TBD needs to provide information to assist the dose reconstructor in
determining when to assign neutron dose to workers. Information such as job titles, where and
when UF, and UF, materials were present to create potential neutron exposures, etc., would
assist the dose reconstructor in determining when to assign neutron dose.

SC&A has not found any neutron doses recorded or columns labeled for entry of neutron doses
in the Center for Epidemiological Research (CER) or DOE databases for neutron doses in the
claimant files analyzed to date. From the information contained in the TBD, it cannot be
determined if the neutron film badges were issued or read, what the results were, and if they
were recorded in the workers’ files.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: “TRevision No. [Document No. Page No. 1
February 10, 2609 0 SCA-TR-TASK1-0028 53 of 61 |

TBD-6 (ORAUT 2005f) provides annual average gamma and beta exposures. However, the
‘TBD does not provide any information concerning the details/application of this information,
such as the number of data points for each entry, percent of workers badged, the range of
readings, if background was subtracted, if zeroes or outliers were included, if a threshold dose
was used, etc. The data presented is a good start in creating a coworker database, but in order to
determine its validity and Representativeness, there needs to be additional work performed on
the data, as mentioned above. Plus, as for internal coworker data, some guidance/limitations
concerning the data in a summary form would be appropriate.

The WS TBDs do not specifically address the issue of whether there are adequate dose records
available for WS site workers to perform reasonable dose reconstruction for individual workers,
or to create a technically sound coworker database for both external and internal dose for
unmonitored, or under-monitored, workers. One of the first areas that should be evaluated when
a site profile is being performed is to assess the adequacy, accuracy, and representativeness of
the recorded dose database for internal and external dose reconstruction. This is especially true
for a location such as the WS site because, by the nature of its operations, a significant portion of
the worker population were possibly not monitored. If there were large portions of the work
force that were not monitored, and/or there are excessive gaps or inconsistency in the recorded
data of individual workers, then this indicates a problem for individual dose reconstruction, as
well as difficulties in creating a reliable coworker database for unmonitored/under-monitored
workers. Ifa solid recorded dose database is found, then this is an indication that there is a basis
for technically sound dose reconstructions, subject to the verification of the accuracy of the
monitoring methods (external badging, internal bioassay techniques, ctc.).

SC&A’s preliminary review of several of the WS site workers’ dose records indicate that for the
workers that were monitored during a given time period, there is a reasonable amount of
recorded external dose data during that time period. However, this was a very limited
qualitative review of a few cases, and does not reflect if there were other periods of time when a
given worker should have been monitored and was not, or if there were other workers that should
have been monitored but were not. Internal dose records are more difficult to evaluate, because
it was not a policy at the WS site to continuously bioassay any worker; only periodically perform
a Monday-Friday-Monday (M-F-M) urinalyses for uranium by means of a grab sample (as
opposed to a complete 24-hour voiding) of a few workers. This sampling program was meant to
provide representative samples for each major group of workers, SC&A did find that for the
claims reviewed, generally individual samples and analysis dates were posted, not just weekly,
quarterly, or annual average values. However, there did not appear to be a constant M-F-M urine
sample collection sequence, or repeatable pattern in a given worker’s bioassay data in the
claimant records that SC&A reviewed. Additionally, there were no bioassay data for any
radioisotope other than the element uranium (and some inconclusive thorium in-vivo counts). It
should be emphasized that, because this was a site profile review and not an SEC evaluation
review, SC&A only performed a very limited qualitative review of the claimants’ DOE records
to obtain an indication of the contents of the files.

In summary, there has been insufficient analysis of the recorded internal and external dose data
to determine the percent of workers who were monitored annually and the representativeness of

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: IRevision No. [Document No. Page No.
February 10, 2009 0 a SCA-TR-TASK1-0028 41 of 61

same for all thorium isotopes. According to ICRP Publication 78 (ICRP 1997), the biokinetic
behavior is the same for U-234, U-235 and U-238 (see Tables A.10.6, A.10.7 and A.10.8,
page 127). The same applies for thorium Th-232 and Th-228 (see Tables A.9.8, A.9.9, and
A.9.10, page 107).

Although Table 5-6 of TBD-5 (ORAUT 2005e) was taken directly from the reference
DOE/OR/21548-241 (DOE 2001), it does not appear to be applicable here. In view of the
operations that took place at the WSCP, TBD-5 (ORAUT 2005e) should provide
justification/clarification concerning the use of Table 5-6 and the classes of solubility that should
be assumed in the different workplaces at the WS site.

Finding #21: Missed Dose and Coworker Data Not Adequately Addressed

Missed Dose

TBD-5 (ORAUT 2005e) does not address potential internal missed dose, which should be part of
the TBD for internal dose, especially considering the complexity of the workplace conditions and
the urinalysis techniques applied at the WS site. The urinalysis was based on a photofluorimetric
method and reported in units of mg U/liter urine; the isotopic composition of uranium in urine
samples was unknown. Additionally, the LOD was generally high in the earlier years, which
could result in significant missed doses. For the dose reconstructor to assign missed dose, the
TBD needs to provide some information concerning the MDA for given bioassay techniques for
the important radionuclides of concern at the WS site as a function of time, and specific
radionuclides to assume, or a claimant-favorable default radionuclide. Ifthe MDA values are
unknown, the worst-case scenario for a combination of MDA/radionuclide should be provided.

Coworker Dose

If the dose reconstructor needs to apply internal coworker dose, TBD-5 (ORAUT 2005e) does
not provide sufficient instructions for the use of Tables 5-8 through Table 5-17, especially in
view of the problem with cost-center code listings, as described in a previous finding. Most
internal dose TBDs provide a summary section in the main text or as an appendix with
recommendations and procedural steps for using coworker data.

An item of importance that applies to both missed and coworker dose data is the fact that in the
everyday operations at the WS site, urine samples were not necessarily collected, as stated in
some of the documents, For example, TBD-5 (ORAUT 2005e, page 17) quotes the following
from MCW 1965b:

The routine sampling program seeks to have one or more persons from each
operational group in the plant sample(d) each week. When a person represents
his group in the sample, he is asked to give samples on (1) Monday a.m.,

(2) Friday p.m., and (3) Monday a.m. The Monday sample tends to show the
amount semi-fixed in the body, the Friday sample reflects the daily uptake. The
sample from each person is analyzed separately and entered in his summary.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Iffective Date: Revision No. [Document No. (Page No,
February 10, 2009 oO SCA-TR-TASK 1-0028 13 of 61

Different Solubility Classes Listed for the Same Element

The TBD provides a list of solubility classes for uranium and thorium compounds in some of the
buildings at the WSCP; however, the TBD lists different solubility classes for the same element.
Because there were no means of separating isotopes of a given element at the WSCP, the
chemical properties were the same for all uranium isotopes, as well as for all thorium isotopes.
According to ICRP Publication 78 (ICRP 1997) the biokinetic behavior is the same for U-234,
U-235, and U-238. The same applies for thorium Th-232 and Th-228.

In view of the operations that took place at the WSCP, the TBD should provide
justification/clarification concerning the use of different classes of solubility for the same
element at the WS site.

Missed Dose and Coworker Data Not Adequately Addressed

The TBD does not address potentially missed internal doses, which should be part of a TBD for
internal dose. The limits of detection (LODs) were generally high in the earlier years, which
could result in significant missed doses. For the dose reconstructor to assign missed dose, the
TBD needs to provide some information concerning the minimum detectable activity (MDA) for
given bioassay techniques for the important radionuclides of concern at the WS site as a function
of time, Additionally, the TBD provides some coworker internal dose information, but does not
provide sufficient instructions for its use or the details of the data, such as the percent of workers
bioassayed or the representativeness of the data (especially important at the WS site, because not
all workers were bioassayed and none continuously). Also, most internal dose TBDs provide a
summary section in the main text or as an appendix with recommendations and procedural steps
for using coworker data,

11.2.3 External Dose ORAUT-TKBS-0028-6
Shallow and Extremity Doses Not Sufficiently Characterized

The TBD briefly addresses dosimeter quantities, open window (OW), shielded window (SW),
etc., and compares beta dose from NU, EU, and DU for shallow doses; additionally, electron
dose is listed as >15 keV. But the TBD does not address geometry factors, total shallow dose, or
extremity monitoring during the operational period. A geometry factor is needed for adequate
dose assessment, because a film badge does not register the same dose as the worker’s
tissue/organ is receiving from the betas and low-energy photons when handling, machining,
scooping, etc., uranium containing materials. No WS site documents have been located that
sufficiently address the change in film badge response as a function of radionuclide exposure,
especially to low-energy photons and changes in beta energies. Additionally, there is no
indication that routine extremity monitoring was performed at WS during the operational period.

Badging Policy Not Consistent
The TBD does not provide sufficient and/or consistent information concerning the badging

policies at the WS site. This raises the question of what badging criteria were actually used in

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: (Revision No. Pocament No. PageNo.
February 10, 2009 0 SCA-TR-TASK1-0028 31 of 61

Finding #9: Use of ICRP-34 Instead of ICRP-74

TBD-3 (ORAUT 2005c) utilizes ICRP 34 (ICRP 1982) instead of ICRP 74 (ICRP 1996), which
was used in NIOSH’s OCAS-IG-001 (NIOSH 2002) to determine absorbed dose from kerma
values. Preliminary studies by SC&A indicate that the use of ICRP 34 may tend to
underestimate the absorbed dose. ICRP 34 does not have 10 organs that are now in ICRP 74.
The use of ICRP 74 is particularly important when the medical examinations included PFG chest
x-ray exams, where doses can double or triple based on the differences between ICRP 34 and
ICRP 74; for PA and lateral x-rays, the underestimations are not as significant. This issue
amplifies the need to ascertain whether WS site workers received PFG exams, as outlined in the
previous finding.

3.2.2 Occupational Environmental Dose ORAUT-TKBS-0028-4

Background and Introduction

In TBD-4 (ORAUT 2005d), most of the environmental dose to WSCP workers is attributed to
uranium and thorium. Internal dose from exposure outside the process areas is assumed to be
due mainly to facility releases and resuspension from contaminated soils, or from waste storage
and holding areas (WSQ and WSRP). Source terms are derived mainly from limited process
knowledge and calculated or estimated maximum releases from stacks and vents. Because
uranium was viewed mainly as a chemical hazard tather than a radiological hazard, little actual
onsite environmental measurement data exist for the early years of operations, especially for
unmonitored workers on the site premises, but outside the immediate operating areas. Most
effluent data utilized in the TBD were derived from several annual environmental reports for the
years 1981 to 2002, inclusive. Most releases and subsequent doses were presumed to be
primarily from natural uranium (mostly U-238); lesser contributors to environmental dose were
Th-232 and Th-230. Notably, the Th-232 was not monitored routinely, as it was believed to be a
minor contributor to dose. The TBD concludes that estimates of environmental dose can be
derived strictly from uranium air monitoring data, as it should account for resuspension of other
radionuclides in soil. Because of the lack of environmental monitoring for unmonitored workers
during the operational period, this TBD relies heavily on data obtained during the remedial
period, environmental parameter measurements, and the air concentration measurements during a
hopper cleaning event,

The current version of TBD-4 (ORAUT 2005d) was published with significant data gaps in the
environmental data before 1985. Therefore, the current TBD version already warrants a future
revision due to these existing data gaps, especially because of the need for historical data during
the operational period (1957-1967). Any revisions should include additional information
pertinent to onsite environmental monitoring and effluent data collected, and any applicable
information that comes from NIOSH responses to SC&A’s site profile review that have occurred
since the publication of this TBD.

SC&A has reviewed the TBD, as written, and has identified the following findings.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


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 Heaith

eee OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Page 5 of 7

F 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 ea nean related to the selection. You are not required to complete more than one entry.

Ft We have attached either documents or statements provided by affidavit that indicate that
radiation 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

monitoring.
(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.

Emplouee Statements by ape davits
are Lerth coming begerdi ng” “nu le ple.
unretorded incidents [Cacetdents

F.2 i I/We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been fost, 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 lost, alfered illegally, or destroyed.

Part F is continued on the following page.

Name or Social Security Number of First Petitioner:



IEffective Date: Revision No. {Document No. _ age No.
February 10, 2009 0 SCA-TR-TASK1-0028 24 of 61

3.0 VERTICAL ISSUES

SC&A developed the issues for the six WS site profile documents using the five objectives
defined in SC&A’s review procedures (SC&A 2004). Some issues were related to more than
one TBD and are covered under Section 3.1, Common Issues, and some are related to a specific
TBD and are covered under Section 3.2, Specific Issues. The issues were identified,
consolidated, and grouped into findings. Findings that could substantially impact the results of
dose reconstruction for some workers are listed as Primary Findings, and those that are
important, but may have less impact on the results of dose reconstruction, are listed as Secondary
Findings. SC&A has also identified some areas where changes in the TBDs would be beneficial
to the claimant by preventing possible mistakes during dose reconstruction, or where
clarification of items would make them less ambiguous. These were listed as Observations.

3.1. COMMON ISSUES

In reviewing the six WS site TBDs, SC&A found several issues that were common to more than
one of the documents. Therefore, to eliminate repetition, SC&A has consolidated these issues.
The following are five areas that SC&A has identified where the present TBDs lacks sufficient
information/data that may impact NIOSH’s ability to perform claimant-favorable dose
reconstructions,

3.1.1 Primary Findings
Finding #1: Lack of Personsel Contamination and Egress Monitoring

The WS site TBDs do not mention the lack of monitoring equipment and procedures to check
workers for contamination in the work places and upon leaving the controlled areas. SC&A.
could not locate any documentation to verify if such procedures and equipment were used at the
WS site during the operating period of 1957-1966, At that time, uranium was considered to be
mostly a chemical hazard and control measures were mainly based on chemical toxicity limits,
not radiological limits (ORAUT 2005e, page 11). During recent worker interviews, SC&A did
not find that the workers recalled any regular egress monitoring, either between the operations
areas to the non-operations areas (cafeteria, administration offices, labs, maintenance facilities,
sidewalks, storage yards, grounds, etc.) or when leaving the plant site (guard shack, parking lots).
Workers did indicate, and documents support, that they were required to change clothing when
entering and leaving the operations areas (some workers showered, but this policy does not
appear to have been strictly enforced); however, there is no evidence that the workers were
checked for contamination before leaving the controlled areas to ascertain that they were not
contaminated. Documents indicate that some area monitoring (i.e., with portable survey
instruments and swipes) and cleanups were performed to keep some surfaces below certain limits
(MCW 1965b, page 20), but there is no indication that survey instruments or hand/foot
monitoring stations were available and routinely used to monitor workers as they left the
operational areas or the WS site. Contamination was apparently commonplace inside the process
areas as evident by a statement in MCW Uranium Division (MCWUD) Summary of Health
Protection Practices MCW 1965b, page 20), which states that “Inside the process locations,
surface contamination measurements have little significance.” Contamination was apparently
common on workers, as described in a 1960 WS site document (Burr 1960):

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


[Effective Date: Revision No. {Document No. Page No.
February 10, 2009 0 Ll SCA-TR-TASK 1-0028 10 of 61

1.1. SUMMARY OF PRIMARY FINDINGS

1.1.1 Findings Common to Several TBDs

In reviewing the six site profile documents for the WS site, SC&A found several issues that were
common to more than one of the documents. The following is a brief summary of the primary
findings that reflect these issues.

Lack of Personnel Contamination and Egress Monitoring

The WS site TBDs do not mention the lack of monitoring equipment and procedures to check
workers for contamination in the work places and upon leaving the controlled areas. During
recent worker interviews, SC&A did not find that the workers recalled any regular egress
monitoring, either between the operations areas to the non-operations areas (cafeteria,
administration offices, labs, maintenance facilities, sidewalks, storage yards, grounds, etc.), or
when leaving the plant site (guard shack, parking lots), Workers were apparently allowed to
leave the controlled areas and the WS site without confirmation that they were not contaminated.
This could have spread contamination to non-controlled areas at the site, creating chronic
exposure (internal and external) to unmonitored workers, as well as leaving contamination on the
workers that could lead to chronic beta exposure to the skin (especially in the folds of the skin)
and internal exposure through ingestion and resuspension/inhalation.

Inadequate Information Concerning Workers Status/Exposures for 1967-1984

The WS site TBDs do not explicitly state when DOE employees and/or DOE contractors were no
longer at the WS site after it stopped operations in December of 1966. It has not been
determined if DOE employees and/or contractors were present or involved during 1967-1969
when the U.S. Army was attempting to decontaminate and renovate buildings located at the
WSCP; during the 1970-1984 monitoring and maintenance period; or during 1983-1984 when
there were efforts to remediate leaks at the WSRP. If DOE contract personnel were present at
the WS site soon after the shutdown in December 1966, they could have been exposed to
numerous radionuclides during decommissioning, clean out, and revamping the facility for a
completely different use. This could have lead to incidences of skin contamination, inhalation,
and ingestion of radioactive materials (including uranium and thorium, as well as radionuclides
contained in the raffinate concentrates and its scale/soil that had been resuspension) that were not
monitored and/or recorded or grossly underestimated.

If DOE employees and/or contractors were present at any of DOE’s WS facilities during the
period 1967-1984, the TBDs need to be revised to include this period of dose evaluation for the
site. Therefore, the issue of legal ownership of the property (and liability) as a function of time
needs to be determined through federal/state/local records to determine if the TBDs should be
revised to include additional time periods.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: Revision No. [Pocument No. Page No,
February 10, 2009 0 SCA-TR-TASK1-0028 16 of 6h

units of special uranium microcuries, defined as the sum of 3.7 x 10* dps from 7°U, 3.7 *

104 dps from 24, and 9 x 10? dps from 23515.” However, it goes on to state, “Converting to
units of Bq, the special uranium pCi is multiplied by 3.7 10° Bq/yCi and by a factor of 2.024
to report total uranium activity” (emphasis added). The factor of 3.7 x 10* Bq/pCi is correct, but
the factor of 2.024 should be omitted, because the Special uranium pCi already includes the
2.024 factor [which consist of the sum of (3.7 x 10° dps from 238), 3.7 x 10° dps from ?*U, and
9 x 10? dps from *>U)/( 3.7 x 10° dps from ?¥U) = 2.024}.

Observation #3 ~ Corrections to Text of TBD-4

«The equation on page 5 should read, “WL Working Level = 1.3 x 10° MeV of alpha
energy in { liter of air;” not “105 MeV.”

¢ The equation on page 5 should read, “WLM Working Level Month = Exposure from
1 WL of radon daughters for 170 working hours;” not “...or radon...”

1.3.4 Observations — Internal Dose

Observation #1 — Years of Thorium Use

Table 5-2 (ORAUT 2005e, page 10) lists the starting date for potential Th-232 exposure as 1963,
1965, and 1966 depending on the building. This should be verified, as it would seem that WS
would have processed thorium fairly uniformly throughout the different buildings, at least on a
yearly basis.

Observation #2 — Changes in Text of TBD-5

e The second paragraph on page 12 appears to be out of place in this location; it may be
more applicable to the contents of page 9.

« The last paragraph on page 12 contains an incorrect table and document reference; it
should read, “Table 2-7 in ORAU (2005b) gives the annual (fiscal year) mass receipts of
each of these feed materials;” not “Table 2-4 in ORAU (2005a)...”

¢ The second patagraph on page 36 states that “Under these assumptions, the claimant-
favorable assumption results in an annual exposure of 735 MAC-hr (in comparison to
1,050 MAC-hr for Fernald)...” when actually it is 1,050 MAC-hr for the WS site, based
on the definition of the MAC for the WS facility. Considering that the MAC for the WS
facility was set at 70 dpm/m? compared to 100 dpm/m? for the Fernald facility, it would
be equivalent to 735 MAC-br as defined for the Fernald facility.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: Revision No, cument No. Page No.
February 10, 2009 O SCA-TR-TASK 1-0028 12 of 61_

Lack of Validation for Maximum Environmental Dose

The TBD fails to validate the adequacy of estimating the maximum environmental dose due to
source terms at differing locations at the Weldon Spring Plant. In the current TBD, NIOSH has
offered that existing air monitoring data do not distinguish the source of emissions; therefore, to
some measure, it only allows evaluation of cumulative emissions and dose. The estimation of
dose methodology currently being applied by NIOSH does not reasonably address maximum
dose to workers who are not routinely monitored across the site, which could have been 50% of
the site workers.

SC&A believes that the lack of air monitoring stations in general and the overall lack of stations
within a particular geographic location at the WSCP (of known higher releases of uranium and
thorium) does not readily enable one to accurately estimate environmental dose using only the
very limited existing air monitoring data.

1.1.2.2 Internal Dose ORAUT-TRKBS-0028-5
Incomplete Assessment of Uranium Decay Products

The TBD recommendations for dose estimate from decay products of U-238 are incomplete, and
not always claimant favorable. The dose from inhaled Th-234 is not included along with the
dose from inhaled U-238 in the dose calculations. What is included is the dose from Th-234 that
builds up inside the body after an intake of U-238 takes place. Additionally, the dose
contribution due to Pa-234m from the decay of Th-234 in the body also needs to be included in
the internal dose calculations. While it is true that the Pa-234m outside the body only
contributes to the external dose, the Pa-234m originating inside the body from Th-234 decay
must be included in the internal dose calculations.

Incomplete Assessment of Radon Exposure

The TBD describes the potential radionuclide exposure in the different buildings of the WSCP.
Radon is listed as a source of exposure inside buildings 101, 103, 105, 403 and 407. However,
the recommended approach used in the TBD to estimate radon doses is based on environmental
radon concentrations for the areas within 100 meters of the assumed release point, which is the
acid recovery plant stack. Using this approach requires that several assumptions be made, which
results in large uncertainties in the dose estimates for workers located in indoor workplaces. For
example, documentation shows that indoor radon concentrations averaged four times that of
outside radon concentrations.

Therefore, the approach recommend in TBD-5 is not always claimant favorable. NIOSH should
propose a more reliable and claimant-favorable approach to the assess radon exposure for WSCP
workers.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


ffective Date: Revision No. {Document No. age No.
|_February 10, 2009 0 SCA-TR-TASK1-0028 25 of 61

His shoes and his gloves were especially loaded with green salt. The packing was
done by foot...He had a respirator around his neck but was not using it... it was
suspected that the ventilation was inadequate...the operator distributed additional
green salt in the bomb by hand and visible clouds of dust could be seen around
the shell top and in the working area.

It would not be difficult to create contamination in the work areas, considering that the beta
exposure rates of some operations were in the 10-35 rep/hr (rep ~ rem) range, as stated in Table I
of a WS site document (MCW 1959b). A little scale, cuttings, or dust from these operations
would quickly contaminate the work area.

Workers also indicated that they were allowed to smoke and drink liquids in the break rooms
Jocated inside the controlled areas without washing of hands, changing of clothes, or
contamination checks. This practice could lead to undetected intakes in some individuals who
were not monitored on a regular basis, especially those who were present in the work areas, but
not considered as at-risk workers, such as supervisors, clerks, and security personnel.

Workers were apparently allowed to leave the controlled areas and the WS site without
confirmation that they were not contaminated. This could have spread contamination to non-
controlled areas at the site, creating chronic exposure (internal and external) to unmonitored
workers, as well as leaving contamination on the workers that could lead to chronic beta
exposure to the skin (especially in the folds of the skin) and internal exposure through ingestion
and resuspension/inhalation. Because workers only periodically submitted urine samples, as
described in TBD-5 (ORAUT 2005e), some of these individual internal exposures could have
been missed. Additionally, personnel badges worn during working hours would not have picked
up this offsite external dose on the workers.

Finding #2: Inadequate Information Concerning Workers Status/Exposures for 1967-1984

It is not explicitly stated in the TBDs when DOE employees and DOE contractors were no longer
working at the WS site after operations ceased in December of 1966. In Section 2.2.2.4 of
TBD-2 (ORAUT 2005b, page 22), it is indicated that no AEC contractors were present until
August 1975 (this is reiterated on page 30 of TBD-2); however, Section 6.13.2, page 12 of
TBD-6 (ORAUT 2005), states that:

“There is some anecdotal information to indicate that some former WSCP
workers continued their employment during this period.” and “We do not feel
such a contractor will need film badge services.” However, it is not clear if this
statement refers to a continued presence by MCW staff,

This is referring to the 1967 to 1969 time period.

The WS site TBDs do not state if DOE employees and contractors were present or involved
during 1967-1969 when the U.S. Army was attempting to decontaminate and renovate buildings
located at the WS Chemical Plant, during the 1970-1984 monitoring and maintenance period, or
during 1983-1984 when there were efforis to remediate leaks at the WS Raffinate pit.

NOTICE: This report bas been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: |Revision No. [Document No. Page Ni
February 10, 2009 0 SCA-TR-TASK1-0028 7 of 61

1.0 EXECUTIVE SUMMARY

This report provides the results of a review conducted by S. Cohen and Associates (SC&A) of
the site profile for the Weldon Spring Plant, Weldon Spring, Missouri, developed by the National
Institute for Occupational Safety and Health (NIOSH). This review was conducted during the
period from January 2008~September 2008, in support of the Advisory Board on Radiation and
Worker Heaith (Advisory Board) in the latter’s statutory responsibility under the Energy
Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA) to conduct
such reviews and advise the Secretary of Health and Human Services on the “completeness and
adequacy” of the EEOICPA program.

The site profile for the Weldon Spring (WS) site consists of six documents created in 2005:

« ORAUT-TKBS-0028-1 (Little and Meyer), Revision 0, June 28, 2005, and
Revision 00 PC-1, June 30, 2008

* ORAUT-TKBS-0028-2 (Little and Boyer), Revision 00, June 24 2005

* ORAUT-TKBS-0028-3 (Lopez and Furman), Revision 00, June 24 2005
« ORAUT-TKBS-0028-4 (Boyer and Little), Revision 00, June 28 2005

* ORAUT-TKBS-0028-5 (Johnson and Falk), Revision 00, June 28 2005

¢ ORAUT-TKBS-0028-6 (Langsted and Little), Revision 00, June 24 2005

The Technical Basis Document (TBD) ORAUT-TKBS-0028-1, Weldon Spring Plant —
Introduction, was reissued with some minor changes on June 30, 2008; however, the changes in
that document did not have an impact on this review. In this review, unless specified otherwise,
the term “WS site” will be used to refer to the Weldon Spring site in general, to include the WS
Chemical Plant (WSCP), the WS Raffinate Pits (WSRP), the WS Quarry (WSQ), and any
surrounding areas encompassing the Mallinckrodt Chemical Works (MCW)/Department of
Energy (DOE) operations.

The WS site was constructed in the mid-1950s by the Mallinckrodt Chemical Works Nuclear
Division (MCWND) to process uranium ore and other uranium materials for the Atomic Energy
Commission (AEC). It was located on a 205-acre section of the Department of the Army’s
17,232-acre Ordnance Works. According to TBD-2 (ORAUT 2005b), the WSCP was operated
for AEC by the Uranium Division of MCW from 1957 to 1966. The WSCP processed materials
from June 1957 to December 1966. Shutdown procedures were completed in 1967. It is
estimated that there were approximately 600 employees at the site during peak production, of
which about 300 would have handled uranium-containing materials. Four types of nuclear
material were processed in the DOE-owned WSCP; natural uranium, depleted uranium (DU),
slightly enriched uranium (EU) [some of these materials contained recycled uranium (RU)], and
natural thorium.

The WSCP sampled the incoming uranium-bearing ore for uranium content (usually contained in
metal drums with approximately 70% uranium content), processed some of the ore, and shipped
some of the ore to other facilities for processing. The chemical processing consisted of changing

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: Revision No. [Document No. age No.
February 10, 2009 0 SCA-TR-TASK1-0028 Si of 61

not be complete if workers were exposed after the operational period and not properly
monitored. The issue of legal ownership of the property (and liability) as a function of time
needs to be determine through federal/state/local records to determine if there should be dose
records available and dose reconstruction performed for any workers during the time period
1967-1984.

The WS TBDs do not sufficiently address accidents or incidents at the WS site, or the apparent
lack of their documentation being readily available. Accidents and incidents that could
potentially release material to the operational areas and to unmonitored workers onsite are
important at WS, because the radiological hazards may not have been fully recognized,
investigated, or documented at the time of occurrence. This could have Sead to exposures that
were not monitored and do not appear in the energy employee’s records.

The WS TBDs do not address the issue of whether the dose records for the WS workers contain
the complete dose records for the workers to allow for reasonable dose reconstructions without
excessive extrapolation or use of other data. SC&A could not find that an analysis of the
completeness of the dose records and their representativeness of the worker population has been
performed.

4.1.2 Objective 2: Technical Accuracy

SC&A finds that the existing TBDs do not sufficiently address the accuracy of the dose records
for the WS site workers. For example, the accuracy of shallow dose measurements are very
much affected by geometry factors (any material/distance between the beta source and the badge
on the worker’s chest that is not between the beta source and the worker’s trunk area will cause
an under-response in the recorded dose). The external dose TBD (ORAUT 20056) did not
address these geometry factors for the WS site, nor did it include extremity monitoring or the
lack of it during the operational period. Total shallow dose consists of low-energy photons plus
beta radiation; the film badge response changes (and therefore, its accuracy) when the energies
or ratios of the photons to betas changes. The ability of the film badges used at the WS site to
accurately record the total shallow dose was not addressed in the TBDs. The accuracy of
neutron dose assignment (TBD-6 recommended using an n/p value of 0.1, derived from the
Fernald site, to assign neutron dose to workers who may have been exposed to EU) was not
verified or sufficiently substantiated in the TBD.

The internal dose TBD (ORAUT 2005e) does not fully address the problem of radioisotopes
other than uranium that may have been present in the workers’ intake, but not analyzed for in the
urinalysis. According to the workers’ dose records reviewed to date, there were no analyses
performed for any element beside uranium, except some workers had an inconclusive one-time
thorium chest count in July 1966. These other radioisotopes were addressed in the WS site
profile by extrapolation from other DOE sites; the accuracy of this method has not been verified.

The WS TBDs do not address the issue of whether the dose records for the WS workers are
sufficiently accurate to perform dose reconstructions. SC&A’s preliminary review of the WS.
site worker claim files indicate that the summary sheets and later data sheets generally agree with
the dose values listed on the copies of the original data card, worksheets, etc. (some of the

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Upon of 2669



SCA-TR-TASK1-0028 22 of 61 |

fective Date: IRevision No. ‘Ponmen No. [Page No.

February 10, 2009 0

Category 3: The most complex and challenging dose reconstructions consist of claims where
the case cannot be dealt with in one of the two categories above. For instance, when a minimum
dose estimate does not result in compensation, a next step is required to make a more complete
estimate. Or when a worst-case dose estimate that has assumptions that may be physically
implausible results in a POC greater than 50%, a more refined analysis is required. A more
refined estimate may be required either to deny or to compensate. In such dose reconstructions,
which may be represented as a “reasonable” or “best-case” estimate, NIOSH has committed to
resolve uncertainties in favor of the claimant. According to 42 CFR 82, NIOSH interprets
“reasonable estimates” of radiation dose to mean the following:

.. estimates calculated using a substantial basis of fact and the application of
science-based, logical assumptions to supplement or interpret the factual basis.
Claimants will in no case be harmed by any level of uncertainty involved in
their claims, since assumptions applied by NIOSH will consistently give the
benefit of the doubt to claimants. (Emphasis added.)

SC&A’s draft report and preliminary findings will subsequently undergo a multi-step resolution
process. Prior to and during the resolution process, the draft report is reviewed by the DOE
Office of Health, Safety, and Security, to confirm that no classified documents or information
have been incorporated into the report. Resolution includes a transparent review and discussion
of draft findings with members of the Advisory Board Working Group, petitioners, claimants,
and interested members of the public. This resolution process is intended to ensure that each
finding is evaluated on its technical basis in a fair and impartial basis. A final report will then be
issued to the full Advisory Board for deliberation and a final recommendation.

All review comments apply to Rev. 00 of the WS site TBDs, which are the most recently
published versions, SC&A is aware of some minor revisions made to TBD-1 (ORAUT 2005a)
in June 2008; however, this revised edition was not yet available on the Center for Disease
Control (CDC) website at the time of the writing of this report. SC&A does not anticipate that
these minor revisions will impact this review.

Site expert interviews were conducted with former WS site workers to help SC&A obtain a
comprehensive understanding of the radiation protection program, site operations, and historic
exposure experience.

Attachment 2 provides summaries of the interviews conducted by SC&A during the course of
this review. The interviewees included a good cross-section of former WS site workers,
including production, maintenance, safety, office, and radiological safety personnel that worked
at the WS site at some point during the production period of 1957-1966. The interviews were
conducted at the Weldon Spring Site Interpretive Center located at 7295 Highway 94 South, St.
Charles, Missouri, and also with a former WS site worker in the St. Louis, Missouri, area. A
telephone interview was conducted with a medical doctor closely associated with the WS site
and its former workers, The interviews were conducted by Ron Buchanan (SC&A/Saliant Inc.)
and Kathy Robertson-DeMers (SC&A/Saliant Inc.), from April 28-30, 2008, and on

September 8, 2008.

NOTICE: This report has been reviewed for Privacy Act information and fas been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


\Effective Date: [Revision No. |Document No. ‘Page No.
February 10, 2009 ] SCA-TR-TASK1-0028 58 of 61

ORAUT (Oak Ridge Associated Universities Team) 2005a. Weldon Spring Plant — Introduction,
ORAUT-TKBS-0028-1, C. Little and R. Meyer, Rev. 00, 28 June 2005a.

ORAUT (Oak Ridge Associated Universities Team) 2005b. Weldon Spring Plant ~ Site
Description, ORAUT-TKBS-0028-2, C. Little and L. McDowell-Boyer, Rev. 00, 24 June 2005.

ORAUT (Oak Ridge Associated Universities Team) 2005c. Weldon Spring Plant ~
Occupational Medical Dose, ORAUT-TKBS-0028-3, T. Lopez and J. Furman, Rev. 00, 24 June
2005¢.

ORAUT (Oak Ridge Associated Universities Team) 2005d. Weldon Spring Plant ~
Occupational Environmental Dose, ORAUT-TKBS-0028-4, L. McDowell-Boyer and C, Little,
Rev. 00, 28 June 2005.

ORAUT (Oak Ridge Associated Universities Team) 2005e. Weldon Spring Plant —
Occupational Internal Dose, ORAUT-TKBS-0028-5, Janet A. Johnson and Roger B. Falk, Rev.

00, 28 June 2005.

ORAUT (Oak Ridge Associated Universities Team) 2005f. Weldon Spring Plant —
Occupational External Dosimetry, ORAUT-TKBS-0028-6, J. Langsted and C. Little, Rev. 00, 24
June 2005.

ORAUT (Oak Ridge Associated Universities), 2005g, Technical Information Bulletin: Dose
Reconstruction from Occupationally Related Diagnostic X-ray Procedures, ORAUT-OTIB-
0006, Rev. 03, Oak Ridge, Tennessee. 19 April 2005.

ORAUT (Oak Ridge Associated Universities Team) 2005h. Basis for Development of an
Exposure Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St
Louis Airport Site, St. Louis, Missouri, Period of Operation: 1942-1958, ORAUT-TKBS-0005,
Rev. 01, March 2005.

ORAUT (Oak Ridge Associated Universities Team) 2008. Weldon Spring Plant ~ Introduction,
ORAUT-TKBS-0028-1, C. Little and R. Meyer, Rev. 00 PC-1, 20 June 2008.

SC&A 2006. Review of the NIOSH Site Profile for the Fernald Environmental Management
Project (Feed Materials Production Center), SCA-TR-TASK1-0010, November 2006.

Stradling G., Hodgson A., Fell T., Phipps A., and Etherington G. Thorium Nitrate and Dioxide:
Exposure Limits and Assessment of Intake and Dose after Inhalation, National Radiological
Protection Board, Oxon OX11 ORQ, NRPB-W57, May 2004.

Weldon Spring Site, 1983, Table 2-8, Radioactive Wastes in Pits 1, 2, 3, & 4, page 26, 1317B,
unknown author, January 21, 1983. Ref ID #14777.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


‘Effective Date: ision No. PPocument No. Page No.
February 10, 2009 0 _ SCA-TR-TASK1-0028 | 60 of 61

Technical Support Documents

National Institutes of Occupational Safety and Health (NIOSH) Office of Compensation
Analysis and Support, External Dose Reconstruction Implementation Guideline, OCAS-IG-001,

Rev. 1, August 2002.

National Institutes of Occupational Safety and Health (NIOSH) - Advisory Board on Dose
Reconstruction, Task 1 - Site Profile Reviews, Subtask 1 - Site Profile Review Procedures,

May 13, 2004.

National Institutes of Occupational Safety and Health (NIOSH) Office of Compensation
Analysis and Support, Special External Dose Reconstruction Considerations for Mallinckrodt
Workers, OCAS-TIB-013, Rev. 0, October 26, 2005.

ORAU (Oak Ridge Associated Universities), 2005, Technical Information Bulletin: Dose
Reconstruction from Occupationally Related Diagnostic X-ray Procedures, ORAUT-OTIB-
0006, Rev. 03, Oak Ridge, Tennessee. April 19, 2005.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


{Effective Date: Revision No. [Document No, Pee No.
| February 10, 2009 0 L SCA-TR-TASK1-0028 61 of 61

ATTACHMENT 2: SITE EXPERT INTERVIEW SUMMARY

(To be provided at a later date.)

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



lEffective Date: Revision No. {Document No. ~— Page No. |
February 10, 2009 0 SCA-TR-TASK1-0028 19 of 61

« Determine the compieteness of the information gathered by NIOSH in behalf of the site
profile, with a view to assessing its adequacy and accuracy in supporting individual dose
reconstructions

© Assess the technical merit of the data/information
e Assess NIOSH’s use of the data in dose reconstructions

SC&A’s review of this site profile document focuses on the quality and completeness of the data
that characterized the facility and its operations, and the use of these data in dose reconstruction.
The review was conducted in accordance with Standard Operating Procedure for Performing
Site Profile Reviews (SC&A 2004) which was approved by the Advisory Board.

The review is directed at “sampling” the site profile analyses and data for validation purposes.
The review does not provide a rigorous quality control process, whereby actual analyses and
calculations are duplicated or verified. The scope and depth of the review are focused on aspects
or parameters of the site profile that would be particularly influential in deriving dose
reconstructions, bridging uncertainties, or correcting technical inaccuracies.

The WS site TBDs serve as site-specific guidance documents used in support of dose
reconstructions. These site profiles provide the health physicist who conducts dose
reconstructions on behalf of NIOSH with consistent general information and specifications to
support their individual dose reconstructions. This report was prepared by SC&A to provide the
Advisory Board with an evaluation of whether and how the TBDs can support dose
reconstruction decisions. The criteria for evaluation include whether the TBDs provide a basis
for scientifically supportable dose reconstruction in a manner that is adequate, complete,
efficient, and claimant favorable. Specifically, this review was conducted using the criterion of
whether dose reconstructions based on the TBDs would provide for robust compensation
decisions.

The basic principle of dose reconstruction is to characterize the radiation environments to which
workers were exposed and determine the level of exposure the worker received in that
environment through time. The hierarchy of data used for developing dose reconstruction
methodologies is dosimeter readings and bioassay data, coworker data and workplace monitoring
data, and process description information or source term data.

2.2 ASSEESSMENT CRITERIA AND METHODS

SC&A is charged with evaluating the approach set forth in the site profiles that is used in the
individual dose reconstruction process. These documents are reviewed for their completeness,
technical accuracy, adequacy of data, consistency with other site profiles, and compliance with
the stated objectives, as defined in SC&A Standard Operating Procedure for Performing Site
Profile Reviews (SC&A 2004), This review is specific to the WS site profile, and supporting
TIBs; however, items identified in this report may be applied to other facilities, especially
facilities with similar source terms and exposure conditions. The review identifies a number of
issues and discusses the degree to which the site profile fulfills the review objectives delineated
in SC&A’s site profile review procedure.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
fliness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition ‘orm B Appen Continuation Page
Con Photocopy and complete as necessar'’

Wat. hate Ylstua? Af [GEE Pd

VA

Attach to Form B if necessary.

Name or Social Security Number of First Petitioner: _|



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

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

. OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3. © 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
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 petition form.)

F.4 @ IWehave attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (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.)
Go to Part G.

omplete Section

imum of three persons may sign the petition.

04-27-04
Date

64-2 7-d?

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 Analysis and Support
NIOSH
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.

Name or Social Security Number of First Petitioner: _|



Effective Date: Revision No. Pooument No. ~— Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 8 of 6}

the incoming material (mainly U3Og, called yellow cake) to UO3, UO», and UF, (green salt). The
green salt was then converted to uranium metal ingots through a process of heating magnesium
and the green salt in a steel “bomb” shell in a furnace. The uranium metal was then extruded
into rods of various shapes and sizes for machining, cutting, descaling, cleaning, etc., for
shipment to other facilities for further processing for use in nuclear reactors. Additionally, some
of the uranium processed at the WSCP contained RU during 1961-1966 and EU at <1%
enrichment during 1963-1966, with some DU used as a substitute for natural uranium, mainly at
the pilot plant to study process flow. The WSCP also processed natural thorium at various times
throughout its period of operations.

The AEC turned over control of the WSCP to the Department of Defense (DOD) in 1967, when
the U.S. Army was to convert some of the buildings for the production of Herbicide Orange.
This project was cancelled in early 1969 and no production of the herbicide took place at the
WSCP. Following this activity, no major work took place during the period 1969-1984.

In 1985, assessment and monitoring began in preparation for remediation of the WS site for both
chemical hazards and radiological hazards from the ordnance and uranium operations under the
auspices of the Weldon Spring Site Remedial Action Project. The clean-up effort was essentially
completed by 2002 with the removal or disposal of all buildings, foundations, pits, quarry, and
related material. Some of this material was shipped offsite, but the majority of it was entombed
in an above-ground disposal cell located on the original WSCP site. The WS site is currently
under a monitoring and surveillance program.

Scope and Approach

SC&A reviewed the WS site profile documents for the following attributes, in accordance with
TASK 1 - Site Profile Reviews, Subtask 1 - Site Profile Review Procedures (NIOSH 2004):

Completeness of Data Sources
Technical Accuracy

Adequacy of Data

Consistency among Site Profiles
Regulatory Compliance

coeceee

In preparation for this report, SC&A reviewed the six WS site TBDs in detail, along with many
WS site-related documents located at the WS site Interpretive Center, at the various DOE/federal
record centers, and on the O-Drive. SC&A also conducted onsite interviews with former WS
site workers. From these reviews, SC&A developed a number of issues regarding the WS site
profile. These issues were identified, consolidated, and grouped into findings. Findings that
have the potential to significantly impact the results of at least some dose reconstructions are
listed as Primary Findings, and those that are important, but may have less impact on the results
of dose reconstruction, are listed as Secondary Findings. Additionally, items that could
potentially lead to incorrect dose assignments because of errors, lack of clarity, inconsistencies,
omissions, etc., in the TBDs are listed as Observations.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Heath for factual accuracy or applicability within the requirements of 42 CFR 82.



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

under the Energy Employees Occupational Canters for Disease Control and Prevention
Iiness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Petitioner Authorization Form Page 2 of 2

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 3 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.

Use of this form is voluntary. Failure to use this form will not result in the denial of any right, benefit, or
privilege to which you may be entitled.

Name or Social Security Number of First Petitioner:



[Effective Date: Revision No. Document No. [Page No.
February 10, 2009 a SCA-TR-TASK1-0028 14 of 61

practice and if workers not considered at the time to be exposed to radiation were potentially
exposed but not monitored because of being in a pre-defined category. The lack of a consistent
and documented badging policy may negatively impact dose reconstruction, because the dose
reconstructor could assign an unbadged worker only external environmental dose when the
worker should have been assigned coworker external dose. Additionally, badging policies could
impact the validity of the coworker dose database.

Lack of Sufficient Coworker Data Development for External Dose

The TBD provides annual average gamma and beta exposures, However, the TBD does not
provide any information concerning the details of this information, such as the number of data
points for each entry, the percent of workers badged, the range of readings, if background was
subtracted, if zeroes or outliers were included, if'a threshold dose was used, etc. The data
presented is a good start in creating a coworker database; however, in order to determine its
validity and representativeness, there needs to be additional work performed on the data, as
mentioned above. Plus, for internal coworker data, some guidance for use of the data in a
summary form would be appropriate.

1.2 SUMMARY OF STRENGTHS

The WS site TBDs were written in six volumes, which assist the reader in accessing and
analyzing the information in an orderly fashion. The TBDs addressed the different time periods
(operational, shutdown, maintenance, and remediation) relevant to the WS site in a consistent
manner, TBD-2 (ORAUT 2005b) provided a sufficient description of the site’s history from its
origin in 1941 as an ordnance plant to its final state containing the above-ground disposal cell.
References were well documented and editorial errors were kept to a minimum. (See

Section 1.3, entitled Observations, for some of the errors that were located during this review.)

The various authors were fairly consistent in the information they presented across the six TBDs,
and made reasonable attempts to locate substitute data when it was missing for the WS site, This
data was sometimes extrapolated from later WS site data, the Fernald site TBDs, or generic DOE
documents, and these methods may be appropriate in some situations. However, because of the
frequent lack of WS site-specific data/information, SC&A has concerns with using this approach.
These concerms are expressed as findings in this report.

NIOSH analyzed some of the environmental, internal (in-vitro bioassays), and external (gamma
and beta) dose data and provided summary tables of this information in the appropriate TBDs.
Some of this data will be heipful for use by the dose reconstructor for cases where there are gaps
in the workers’ dose records, or for workers who were unmonitored. SC&A has reviewed this
information and included their evaluation in the findings of this report.

With the information available at the time of the writing of the first version of the WS site
profile, the TBDs were reasonably weil written. However, SC&A suggest that the TBD be
revised with any new information NIOSH has acquired since 2005 and address SC&A’s
concerns expressed in this report.

NOTICE: This report has been reviewed for Privacy Act information and has bees cleared for distribution,
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


O4-Zy¥ruy re:

Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
ness Compensation Act National institute for Occupational Safety and Health

OMB Number: 6920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 1 of7

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 entitled.

General Instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT all 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 is 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 allowed.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach the completed continuation page(s) to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
request to speak to someone in the Office of Compensation Analysis and Support about an SEC petition:
1-877-222-8570.

A Labor Organization, Start atD on Page 3
if you Q An Energy Employee (current or former), StartatC on Page2
are: mA Survivor (of a former Energy Employee), StartatB on Page 2
PA Representative (of a current or former Energy Employee), StartatA on Page 1

Representative information — Complete Section A if you are authorized by an Employee or

Survivor(s) to petition on behalf of a class.

A. Are you a contact person for an organization? O Yes (Go to A.2) No (Go to A.3)
A2 Organization Information:

Name of Organization

Position of Contact Person

Mr/Mrs/Ms. First Name Middle initial Last Name

AS

A4

A5 Telephone Number:
A6 Email Address:

AT 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 B; if you are representing an Employee, go to Part C.

Name or Social Security Number of First Petitioner:



IEffective Date: Revision No. [Document No. OO [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 37 of 61.

not to provide estimates of dose, but rather to offer estimates of source terms to be used by dose
assessors to estimate the dose to the individual claimant. Effluent data used by dose assessors
would often include quantities for both routine and episodic releases; however, NIOSH
recognizes that significant current gaps exist in this information.

Episodic releases detailed in the TBD are limited to two events. The most significant event was
a spill of uranyl nitrate. Estimated doses to the immediately impacted workers were made;
however, no dose to the nearest public member and unmonitored onsite workers are estimated.
Because there were no apparent environmental measurements performed during or after the
event, it is not possible to validate the level of environmental exposure from the incident. The
other event described is the exposure of a worker to soluble uranium in a dust enclosure. This
event was also not monitored, and reportedly no environmental samples were taken. SC&A
believes this, as well as statements in the TBD, do not seem to support the idea that
environmental exposures were necessarily negligible and resulted mostly from incident exposure
to resuspended uranium compounds. To the contrary, the lack of sufficient environmental data
would suggest the need to develop a maximum exposure scenario for numerous events.
Although not all events were recorded, knowledge of potential releases and events at this site
could be used to better estimate maximum exposures that are claimant favorable.

3.2.3 Internal Dose ORAUT-TKBS-0028-5

Background and Introduction

TBD-5 (ORAUT 2005e) was written to provide the dose reconstructor with recommendations
concerning internal dose reconstruction at the WS site during the operational period of 1957—
1966, the monitoring period 1975-1984, and the remediation period 1985~2001 (it does not
include the period 1967-1974). The TBD covers the major areas of concern, such as radioactive
material source terms, air concentrations, the assessments of intakes, and the in-vitro and in-vivo
measurements. During the operational period, 1957-1966, the workers at WS were periodically
monitored by urinalysis for uranium, but were not bioassayed for other radionuclides. Some
one-time qualitative in-vivo bioassays for thorium were conducted in July 1966. Because there
was limited onsite uranium and no thorium or radon air sampling up until 1985, the authors of
this TBD relied heavily on the Fernald site internal dose TBD-5 (ORAU 2004b) and WS site
environmental and remediation monitoring data, and then applied this data to the WS site during
the operating period. Natural, enriched, depleted, and recycled uranium and natural thorium
were included as potential internal dose contributors. SC&A reviewed the TBD according to
Site Profile Reviews Procedures (NIOSH 2004) and has the following findings.

Primary Findings
Finding #18: Incomplete Assessment of Uranium Decay Products

TBD-5 (ORAUT 2005e) recommendations for dose estimates from decay products of U-238 are
incomplete, and not always claimant favorable. For example, the following is stated on page 13
of the TBD:

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Draft

ADVISORY BOARD ON
RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

Review of the NIOSH Site Profile for the Weldon Spring Site
in Weldon Spring, Missouri

Contract No. 200-2009-28555
Task Order No. 1
SCA-TR-TASK1-0028

Prepared by

S. Cohen & Associates
1608 Spring Hill Road, Suite 400
Vienna, Virginia 22182

Saliant, Inc.
5579 Catholic Church Road
Jefferson, Maryland 21755

February 2009

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board on
Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However,
the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is pre-
decisional and has not been reviewed by the Board for factual accuracy or applicability within the
requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may
differ from the report's conclusions. Thus, the reader should be cautioned that this report is for
information only and that premature interpretations regarding its conclusions are unwarranted.



An EMPLoYEE-OwNeD COMPANY

SC&

March 5, 2009

Mr. David Staudt

Center for Disease Control and Prevention
Acquisition and Assistance Field Branch
Post Office Box 18070

626 Cochrans Mill Road — B-140
Pittsburgh, PA 15236-0295

_S. Conen & ASSOCIATES:

Re: Contract No. 200-2009-28555, SCA-TR-TASK1-0028: Review of the NIOSH Site Profile for
the Weldon Spring Site in Weldon Spring, Missouri

Dear Mr. Staudt:

SC&A is please to submit to NIOSH and the Advisory Board our report titled, Review of the NIOSH
Site Profile for the Weldon Spring Site in Weldon Spring, Missouri. This report has been reviewed
for Privacy Act-restricted information and edited accordingly, and has been cleared by DOE for release to

interested members of the public.

Should you have any questions, please contact me at 732-530-0104.

LL

J Lh jauro, iD, CHP

‘roject Manager
ce: P. Ziemer, Board Chairperson
Advisory Board Members
T. Katz, NIOSH

L. Elliott, NIOSH

J. Neton, NIOSH

S. Hinnefeld, NIOSH

L. Homoki-Titus, NIOSH
A. Brand, NIOSH

J, Broehm, NIOSH

C. Ellison, NIOSH

L. Shields, NIOSH

D. Sundin, NIOSH

L. Breyer, NIOSH

A. Makhijani, SC&A

H. Behling, SC&A

S. Ostrow, SC&A

H. Chmelynski, SC&A.

J, Fitzgerald, Saliant

J. Lipsztein, SC&A

K. Robertson-DeMers, Saliant
S. Marschke, SC&A

K. Behling, SC&A

T. Bell, Saliant

D. Farver, SC&A

Project File (ANIO2/001/28)

1608 SPRING HILL ROAD, SUITE 400 * VIENNA, VIRGINIA * 22182 * 703.893.6600 * FAX 703.821.8236



Effective Date: evision No. |Document No. Page No.
February 10,2009 | 0 ____SCA-TR-TASK1-0028 50 of 61

4.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR
DOSE RECONSTRUCTION

The SC&A procedures call for both a “vertical” assessment of a site profile for purposes of
evaluating specific issues of adequacy and completeness, as well as a “horizontal” assessment
pertaining to how the profile satisfies its intended purpose and scope. This section addresses the
latter objective in a summary manner by evaluation of (1) how, and to what extent, the site
profile satisfies the five objectives defined by the Advisory Board for ascertaining adequacy;

(2) the usability of the site profile for its intended purpose (i.e., to provide a generalized technical
resource for the dose reconstructor when individual dose records are unavailable); and

(3) generic technical or policy issues that transcend any single site profile that need to be
addressed by the Advisory Board and NIOSH.

4.1 SATISFYING THE FIVE OBJECTIVES

The completeness, accuracy, and adequacy of data (to include data to be used for monitored
workers’ individual dose reconstructions and data to be used in deriving coworker database for
unmonitored workers) should be validated to demonstrate its usefulness. SC&A has performed
extensive document searches and found over 300 MCW/WS site documents available on the
O-Drive plus many other documents located at the various DOE document storage/retrieval
centers, as well as information available at the Weldon Spring Interpretive Center, located on the
original WSCP site. SC&A also reviewed approximately 30 of the WS site claims to assess the
information available in the individual energy employee’s dose records and their applicability to
dose reconstruction and coworker databases. SC&A also conducted several days of onsite
interviews with former WS site workers to obtain information concerning working conditions
and exposure potentials that may impact the completeness and usefulness of dose records. The
following is a summary of SC&A’s evaluation of the present resources available (TBDs, dose
records, site documents, etc.) to the dose reconstructor for reconstruction of dose to WS site
workers with reasonable completeness and accuracy.

4.1.1 Objective 1: Completeness of Data Sources

During its review of the WS site TBDs, SC&A’s found that NIOSH did not sufficiently address
the completeness of the dose records for the workers at the WS site for both internal and external
doses. For example, the WS site TBDs do not explicitly state when DOE employees and/or DOE
contractors were no longer at the WS site after it stopped operations in December of 1966. It has
not been determined if DOE employees and/or contractors were present or involved during
1967-1969 when the U.S. Army was attempting to decontaminate and renovate buildings located
at the WSCP, during the 1970-1984 monitoring and maintenance period, or during 1983-1984
when there were efforts to remediate leaks at the WSRP. If DOE contract personnel were
present at the WS site soon after the shutdown in December 1966, they could have been exposed
to numerous radionuclides during decommissioning, clean-out, and revamping the facility for a
completely different use. This could have lead to incidences of skin contamination, inhalation,
and ingestion of radioactive materials (including uranium and thorium, as well as radionuclides
contained in the raffinate concentrates and its scale/soil that had been resuspension) that were not
monitored and/or recorded, or grossly underestimated. Therefore, the present dose records may

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


‘ffective Date: Revision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK 1-0028 ____33 of 61

e There are no indications if this operation (cleaning the hopper) would have constituted a
representative source term for all operations over the entire 11-year period.

« There are no other WS site operational measurements to compare these result to in order
to assess if they might be at the high, average, or low end of the air concentration range.

« The WS facility was a relatively large complex. Air concentration in one location on a
given day most certainly would not be representative of all locations on all days.

¢ The site environmental parameter measurements had very Jittle influence on the resulting
average value (Table 4-5, max = 1.7E-2/4.4 Bag/m’ = = 0.4%; hence, the final values for
1957-1967 were essentially derived from the one hopper monitoring experiment).

« Validating the results of this measurement by comparing it to the average estimated
value for Fernald (see ORAUT 2005d, page 16) is not supported, because conditions/
operations at the two facilities would not be sufficiently identical on a daily basis; plus
the Fernald value was based on an estimated value, not a measured value.

This limited (in space, opetations, and time) airborne/intake data is not sufficient to construct an
adequate intake database for unmonitored workers at the WS complex; especially considering
that a sizable fraction of the work force was not bioassayed on a routine basis during this period.

Finding #12: Lack of Validation for Maximam Environmental Dose

The TBD (ORAUT 20054) fails to validate the adequacy of estimating the maximum
environmental dose due to source terms at differing locations at the WS site. In the current TBD,
NIOSH has offered that existing air monitoring data do not distinguish the source of emissions;
therefore, to some measure, it only allows evaluation of cumulative emissions and dose. The
estimation of dose methodology currently being applied by NIOSH does not reasonably address
maximum dose to workers who are not routinely monitored across the site. At WSCP, as many
as 50% of the site workers were not routinely monitored.

SC&A believes that the lack of air monitoring stations in general and the overall lack of stations
within a particular geographic location at the WSCP (of known higher releases of uranium and
thorium) do not readily enable one to accurately estimate environmental dose. It will be difficult
for the dose assessor to accurately estimate environmental dose to an individual without more
comprehensive air monitoring data, environmental surveys, and substantial knowledge of where
workers were located during such episodic and acute releases.

The TBD also does not attribute any significant environmental dose to pre-existing
contamination of the environment from plant operations. Very limited environmental analyses
of soils are used to suggest that nearly all uranium contamination is attributable to natural causes.
The aerial radiological survey referred to in TBD-4 (ORAUT 2005d, page 25) was performed
after the WSCP ceased operation by approximately a decade. There is no supporting evidence
presented to indicate that the resulting exposure rate (61~88 mrem per year) resulting from this
later measurement would have been applicable during the operational period, given the plant has
operated for 10 years, had a reasonably high throughput (14,000 tons per year), and experienced
numerous incidents and episodes of environmental releases. For monitored workers (nearly

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: JRevision No. [Document No. —_
February 10, 2009 | 0 SCA-TR-TASK1-0028 21 of 61

2.3 DOSE RECONSTRUCTION UNDER EEIOCPA

In order to piace the above objectives into the proper context as they pertain to the site profile, it
is important to briefly review key elements of the dose reconstruction process, as specified in
42 CFR Part 82. Federal regulations specify that a dose reconstruction can be broadly placed
into one of three discrete categories. These three categories differ greatly in terms of their
dependence on and the completeness of available dose data, as well as on the
accuracy/uncertainty of data.

Category 1: Least challenged by any deficiencies in available dose/monitoring data are dose
reconstructions for which even a partial assessment {r minimized dose(s)] corresponds to a
probability of causation (POC) value in excess of 50%, assuring compensability to the claimant.
In some cases, such partial/incomplete dose reconstructions with a POC greater than 50% may
involve only a limited amount of external or internal data. In extreme cases, even a total absence
of a positive measurement may suffice for an assigned organ dose (based on the LOD) that
results in a POC greater than 50%, For this reason, dose reconstructions in this category may
only be marginally affected by incomplete/missing data or uncertainty of the measurements. In
fact, regulatory guidelines recommend the use of a partial/incomplete dose reconstruction, the
minimization of dose, and the exclusion of uncertainty for reasons of process efficiency, as long
as this limited effort produces a POC equal to or greater than 50%.

Category 2: A second category of dose reconstruction defined by federal guidance recommends
the use of “worst-case” assumptions. The purpose of worst-case assumptions in dose
reconstruction is to derive maximal or highly improbable dose assignments. For example, a
worst-case assumption may place a worker at a given work location 24 hours per day and

365 days per year. The use of such maximized (or upper bound) values, however, is limited to
those instances where the resultant maximized doses yield POC values below 50%, which are
not compensated. For this second category, the dose reconstructor needs only to ensure that all
potential internal and external exposure pathways have been considered, and that the approach is
scientifically supportable.

The obvious benefit of worst-case assumptions and the use of maximized doses in dose
reconstruction is efficiency. Efficiency is achieved by the fact that maximized doses avoid the
need for precise data and eliminates consideration for the uncertainty of the dose. Lastly, the use
of bounding values in dose reconstruction minimizes any controversy regarding the decision not
to compensate a claim.

Although simplistic in design, the TBD must, at a minimum, provide information and data that
clearly identify (1) all potential radionuclides, (2) all potential modes of exposure, and (3) upper
limits for each contaminant and mode of exposure to satisfy this type of a dose reconstruction.
Thus, for external exposures, maximum dose rates must be identified in time and space that
correspond to a worker’s employment period, work locations, and job assignment. Similarly, in
order to maximize internal exposures, highest air concentrations and surface contaminations
must be identified.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


(Effective Date: evision No. [Document No. age No. |
February 10, 2009 o SCA-TR-TASK1-0028 38 of 61

The materials handled at WSCP were uranium concentrates and, to some extent,
natural thorium. The short-lived decay products of ?°U, which are ** “Th (24-d
half-life) and>""Pa (1.175-min half-life), would have built into equilibrium
before the material was handled. Thorium-234 and*TMPa emit beta particles.
The dose from inhaled 234TH is included in the dose from?" U as it builds into
equilibrium in the body in a relatively short period of time (less than eight
months). The >" Pa beta is a high-energy beta and contributes to the external
dose but, due to its short half-life, does not in itself contribute to internal dose.

SC&A does not agree with this analysis for the following reasons.

Inhaled Th-234

The dose from inhaled Th-234 is not included when the dose from inhaled U-238 is calculated.
What is included is the dose from Th-234 that builds up inside the body after an intake of U-238
takes place. Th-234, with its 24-day half-life, and Pa-234, with its 6.7 hour half-life, would be
present along with, and in about equal concentrations as, U-238 in the yellowcake, and hence in
the workplace air. The same analysis applies to Ra-228 and Ac-228 from natural thorium. The
radionuclides from the uranium and thorium decay series present in the workplace needs to be
considered as an additional source of exposure, independent of the U-238, U-235, or Th-232
inside the body. ICRP Publication 78 (ICRP 1997) points out that if there is a mixture of
radionuclides in the workplace, those radiologically significant ones need to be taken into
consideration in the dose estimate (ICRP 1997, page 33):

Workers may be exposed to a mixture of radionuclides and this must be taken into
account in calculating pre-determined derived investigation levels. It will often
be the case that only a few radionuclides in the mixture make a significant
contribution to the committed effective dose. In principle, the radiologically
significant radionuclides should be identified and monitoring programmes should
be designed to assess intake and committed effective dose for these radionuclides.
However, there may circumstances where it is easier to measure one of the other,
less radiologically significant, radionuclides and to use this as a “tracer” for the
mixture, This is feasible when the composition of the mixture is well-known and
constant. A common example is the use of” 24 4m as a tracer for plutonium
isotopes.

Table 1. Dose Coefficients for the GI Organs due to Inhalation of U-238 and Th-234

Dose coefficients for inhalation (AMAD= Sum) (Sv/Bq)
Type M Type S
Organs U-238 Th-234 U-238 Th-234
Stomach Wall 5.15E-09 4.56E-10 6,55E-10 4.42E-10
Small Intestine Wall 5.77E-09 L.07E-09 1.348-09 1,10E-09
Upper Large Intestine Wall | L.12E-08 6.17E-09 7.36E-09 6.49E-09
Lower Large Intestine Wall 2,A1E-08 1,.75E-08 2.18E-08 1.85E-08
Colon 1.67E-08 1.10E-08 1.36E-08 1168-08

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: evision No. {Document No. (Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 20 of 61

2.2.1 Objective 1: Completeness of Data Sources

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify
principal sources of data and information that are applicable to the development of the site
profile. The two elements examined under this objective are (1) determining ifthe site profile
made use of available data considered relevant and significant to the dose reconstruction, and

(2) investigating whether other relevant/significant sources are available, but were not used in the
development of the site profile.

2.2.2. Objective 2: Technical Accuracy

Objective 2 requires SC&A to perform a critical assessment of the methods used in the site
profile to develop technically defensible guidance or instructions, including evaluating field
characterization data, source term data, technical reports, standards and guidance documents, and
literature related to processes that occurred at the WS site. The goal of this objective is to
analyze the data according to sound scientific principles, and then evaluate this information in
the context of dose reconstruction.

2.2.3 Objective 3: Adequacy of Data

Objective 3 requires SC&A to determine whether the data and guidance presented in the site
profile are sufficiently detailed and complete to conduct dose reconstruction, and whether a
defensible approach has been developed in the absence of data. In addition, this objective
requires SC&A to assess the credibility of the data used for dose reconstruction. The adequacy
of the data identifies gaps in the facility data that may influence the outcome of the dose
reconstruction process. For example, ifa site did not monitor all workers exposed to neutrons
who should have been monitored, this would be considered a gap, and therefore an inadequacy in
the data. An important consideration in this aspect of our review of the site profile is the
scientific validity and claimant favorability of the data, methods, and assumptions employed in
the site profile to fill in data gaps.

2.2.4 Objective 4: Consistency among Site Profiles

Objective 4 requires SC&A to identify common elements within site profiles completed or
reviewed to date, as appropriate. In order to accomplish this objective, the WS site TBDs were
compared to other TBDs previously reviewed. This assessment was conducted to identify areas
of inconsistencies and determine the potential significance of any inconsistencies with regard to
the dose reconstruction process.

2.2.5 Objective 5: Regulatory Compliance

Objective 5 requires SC&A to evaluate the degree to which the site profile complies with stated
policy and directives contained in 42 CFR Part 82. In addition, SC&A evaluated the TBDs for
adherence to general quality assurance policies and procedures utilized for the performance of
dose reconstructions.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: IRevision No. [Document No. [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028' 57 of 61

MCW (Mallinckrodt Chemical Works) 1960. Office letter, Urinary Uranium Program, Health
and Safety Department, Uranium Division, Weldon Spring, Missouri, January 1, 1960. Ref ID
14964.

MCW (Mallinckrodt Chemical Works) 1961. Summary Report: Chemical Operator Burned
With Molten Uranium Salt Solution, Health and Safety Department, Uranium Division, Weldon
Spring, Missouri, June 1, 1961.

MCW (Mallinckrodt Chemical Works) 1965a. Office letter, Thorium Operations at MCW,
Health and Safety Department, Uranium Division, Weldon Spring, Missouri, November 2, 1965.
(Ref ID #11799).

MCW (Mallinckrodt Chemical Works) 1965b. Summary of Health Protection Practices, Health
and Safety Department, Uranium Division, Weldon Spring, Missouri, Revised 1965. Ref ID

14998.

MCW (Mallinckrodt Chemical Works) 1983. Radioactive Wastes in Pits 1, 2, 3, & 4, Health and
Safety Department, Uranium Division, Weldon Spring, Missouri, Revised 1965. Ref 1D 14998.

MCW (Mallinckrodt Chemical Works) 1966. Summaries of Dust Concentrations at Production
Jobs, Health and Safety Department, Uranium Division, Weldon Spring, Missouri. Ref ID
15000.

NIOSH (National Institutes for Occupational Safety and Health) 2002. External Dose
Reconstruction Implementation Guideline, OCAS-IG-001, NIOSH Office of Compensation

Analysis and Support, Rev. 1, August, 2002.

NIOSH (National Institutes for Occupational Safety and Health) 2004, Advisory Board on Dose
Reconstruction, Task 1 ~ Site Profile Reviews, Subtask 1 - Site Profile Review Procedures, May

13, 2004.

NIOSH (National Institutes for Occupational Safety and Health) 2005. Special External Dose
Reconstruction Considerations for Mallinckrodt Workers, OCAS-TIB-013, Rev. 0, Office of
Compensation Analysis and Support. October 26, 2005.

ORAUT (Oak Ridge Associated Universities Team) 2004a. Technical Basis Document for the
Fernald Environmental Management Project - Occupational Environmental Dose, ORAUT-
TKBS-0017-4, Rev. 00, April 2004.

ORAUT (Oak Ridge Associated Universities Team) 2004b. Technical Basis Document for the
Fernald Environmental Management Project - Occupational Internal Dose, ORAUT-TKBS-
0017-5, Rev. 00, May 2004.

ORAUT (Oak Ridge Associated Universities Team) 2004c. Technical Basis Document for the
Fernald Environmental Management Project ~ Occupational External Dose, ORAUT-TKBS-
0017-6, Rev. 00, April 2004.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Heaith for factual accuracy or applicability within the requirements of 42 CFR 82.


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Contro! and Prevention

MIness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010
Petitioner Authorization Form Page 1 of 2

Use of this form is voluntary. Failure to use this form will not result in the denial of any right, benefit,

Instructions:

If you wish to petition HHS to consider adding a class of employees to the Special Exposure Cohort and you
are NOT either a member of that class, a survivor of a member of that class, or a labor organization
representing or having represented members of that class, then 42 CFR Part 83, Section 83.7(c) requires
that you obtain written authorization. You can obtain such authorization from either an employee who is a
member of the class or a survivor of such an employee. You may use this form to obtain such authorization
and submit the completed form to NIOSH with the related petition. Please print legibly.

For Further information: If you have questions about these instructions, please call the following NIOSH
toll-free phone number and request to speak to someone in the Office of Compensation Analysis and
Support about an SEC petition: 1-800-356-4674.

HHS on Behalf of a Class of Employees for
Addition to the Special Exposure Cohort

P.O. Box

a
City, State and Zip Code of Petitioner
to petition the Department of Health and Human Services on behalf of a class of employees

tl

Name of Class Member (employee, not the employee's survivor)

for the addition of the class to the Special Exposure Cohort, under the Energy Employee's
Occupational Iliness Compensation Program Act (42 U.S.C. §§ 7384-7385).

In providing this authorization, | recognize that the petitioner named above will have all the rights

3.
23-30-09
Date

Name or Social Security Number of First Petitioner:


|Effective Date: Revision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 _ 11 of 61

Individual Exposures versus Average Exposures

The TBDs rely heavily on the fact that mostly natural uranium (>97%) was processed at the
WSCP; therefore, the contributions from other forms of uranium (DU, EU, or RU) and other
radionuclides (thorium, radium, etc.) are small compared to natural uranium. Whereas the most
likely exposures (internal and external) may have been from natural uranium, this does not
negate the fact that individuals or certain groups of workers may have been exposed to materials
that contained greater concentrations of other forms of uranium and radionuclides, especially in
or near plant locations dedicated to the other forms of radioactive material processing and in
areas around discharge streams, waste, and raffinate pits.

Assuming that natural uranium predominates as the source of a worker’s dose could lead to an
underestimate of the worker’s correct dose if the worker was exposed to radioactive materials
other than natural uranium.

1.1.2 Findings Specific toa TBD

SC&A reviewed the six TBDs for the WS site and has identified a number of issues that may
impact the outcome of dose reconstruction for the WS site workers. The following is a brief
summary of the primary findings that reflect these issues pertinent to each TBD.

1.1.2.1 Occupational Environmental Dose ORAUT-TKBS-0028-4
Lack of Atmospheric Monitoring Data for Operational Period

There is no substantial site-wide atmospheric monitoring data available for the operational period
to assure an accurate and integrated onsite environmental dose assessment. The TBD recognizes
this lack and relied upon the use of dose estimates for the public derived from its reviews of the
Fernald plant data to estimate the onsite environmental dose for the WSCP workers. This is
problematic, in that raw emissions data from Fernald is not easily converted to environmental
dose for the WS site workers when several emission points of varying geographic locations have
to be considered, as well as the lack of knowledge that could place workers at specific locations
during exposure events. SC&A believes that the limited environmental data presented in the
TBD and the lack of environmental surveys of onsite locations over time does not support the
supposition and/or conclusion of negligible dose to onsite personnel.

Insufficient Data for Unmonitored Workers’ Internal Environmental Dose

The TBD used one series of measurements (decontaminating 5-ton hoppers) and site parameter
measurements to determine contributing intakes to non-bioassayed workers during 1957-1967.
The hopper dust monitoring experiment consisted of measurements performed on one day under
one particular condition, and the parameter measurements contributed very little (<1%) to the
final results. This limited (in space, operations, and time) airborne/intake data is not sufficient to
construct an adequate intake dose database for unmonitored workers at the WS complex,
especially considering that a sizable fraction of the work force was not bioassayed on a routine
basis during this period.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: Revision No. [Document No. Page No.
February 10, 2009 o { SCA-TR-TASK1-0028 _ 48 of 61

© It should be stated if any unusual outliers were excluded/included in the data

The data presented is a good start in creating a coworker database, but in order to determine its
validity and Representativeness, there needs to be additional work performed on the data as
outlined above. Additionally, to be useful to the dose reconstructor, there needs to be
recommendations for use of the data, such as a summary appendix with specific dose assignment
recommendations, numerical values, and tables, as contained in many other site profiles.

Secondary Finding
Finding #28: Lack of Documentation and Details for Neutron Doses

Table 6-3 of TBD-6 (ORAUT 2005f, page 13) states, “Estimate neutron dose as 10% of the
reported gamma dose in facilities containing UF, and UF.” Table 6-4 on page 14 states that
“All MCW Uranium Division personnel who work directly with enriched uranium materials are
assigned special neutron dosimeter badges, which are worn in conjunction with the regular film
badges.” However, the results of this badging (presumable NTA film) were not discussed and no
data is presented, except to mention in Section 6.2.4.2 (page 19) that no neutrons were
anticipated or measured with the WSCP film badge. TBD-6 then switches to the use of
Fernald’s TBD-6 (ORAU 2004c) neutron-to-photon ratio (n/p) value of 0.1, with the statement
that the use of the Fernald analysis:is appropriate and will be used in this TBD. The Fernald
TBD-6 (ORAU 2004c, pages 18-20) describes the process of deriving the n/p value of 0.10; this
consisted of measuring the neutron doses from UF, (green salt) canisters in 1995 and then
measuring the photon dose from 56 drums of UF, in 2001. The n/p geometric mean value was
0.10, with an upper 95" percentile of 0.23, and with a geometric standard deviation of 1.71.
There are a number of problems with assuming that the n/p value of 0.1 from the Fernald site can
be used at the WS site:

« There are no indications that the “containers” used in 1995 and the “drums” used in 2001
are the same geometry.

« There are no indications that the UF, in the containers used in the 1995 measurements
and the UF, in the drums used in the 2001 measurements are of the same radioisotope
composition and concentrations to create similar radiation fields for measurements taken
6 years apart.

« There is no indication that the matrix material, which would affect the self-shielding of
the emitted radiation, is the same in both the 1995 and the 2001 measurements.

« There is no analysis to demonstrate that the radiation fields created by the materials in the
containers or drums used at the Fernald site reasonably duplicate the radiation fields at
the WS site, to include such variables as radioisotope composition, concentrations, matrix
materials, and geometry.

The methodology to derive the n/p value of 0.1 at Fernald is questionable, and the application of
this n/p value to the WS site is not technically supported in the TBD.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: Revision No. {Document No. Page No,
February 10, 2009 it] SCA-TR-TASK1-0028 55 of 61

4.2.3 Incomplete Dose Reconstruction Recommendations

TBD-5 (ORAUT 2005e) provides some coworker internal dose information, but does not
provide sufficient instructions for its use. Most internal dose TBDs provide a summary section
in the main text or as an appendix with recommendations and procedural steps for using
coworker data. TBD-6 (ORAUR 2005f) provides annual average gamma and beta exposures.
However, the TBD does not provide any information concerning the details/application of this
information, such as the number of data points for each entry, percent of workers monitored, the
range of readings, if background was subtracted, if zeroes or outliers were included, ifa
threshold dose was used, etc. The data presented is a good start in creating a coworker database,
but in order to determine its validity, there needs to be additional work performed on the data (as
mentioned above), as well as determining the representativeness of the data for the entire worker
population. In addition, some guidance/limitations concerning the use of the data in a summary
form would be appropriate for both internal and external coworker data.

4.2.4 Wack of Defined Monitoring and X-ray Exam Criteria

The WS site TBDs does not inform the dose reconstructor of a documented badging/bioassay
policy and potential x-ray exam exposures in a consistence manner. The dose reconstructor
cannot be reasonably certain whether an unmonitored worker should have been badged and/or
bioassayed, and therefore, assigned a coworker dose, or if an environmental dose assignment is
more appropriate. Likewise, the frequency and types of x-ray exams are not sufficiently defined
to allow the dose reconstructors to assign consistence occupational medical doses.

4.3. UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES

A number of issues identified in the WS site TBD review represent potential generic policy
issues that transcend other individual site profiles. Issues raised in this review that are common
to other DOE/contractor site investigations include a lack of recorded data analysis for
adequacy/representativeness, inadequate documentation of badging policy, lack of sufficient
environmental data for onsite unmonitored workers, insufficient knowledge/documentation of
source terms and radiation fields, lack of geometry factors for beta and low-energy photon doses,
and lack af adequately developed (or insufficient data for) coworker internal and external dose
development. As with many other DOE sites, the WS site also lacks documentation concerning
accidents, incidence, and episodic releases that would have potential radiological consequences,
especially in the operational years. Additionally, the lack of information concerning
occupational medical procedures, equipment, types of exams (PA/LAT, PFG, lumbar), frequency
of exams for different job titles, etc., are prevalent for the WS site and obvious in TBD-3
(ORAUT 2005c), as it is for many of the earlier DOE sites. A common problem that the WS site
has with other uranium processing facilities in the early days is that uranium was mostly
controlled using chemical toxicity levels, rather than being viewed as a radiological hazard. This
lead to some working conditions and lack of monitoring that would not be acceptable by present
standards. These issues are discussed in detail as findings in Section 3 of this report.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: (Revision No. {Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 28 of 61

The reeycled uranium (RU) data are internally inconsistent and also inconsistent
with some available DOE documentation. They are incomplete and do not
appear to be claimant favorable for many workers and periods, though they are
likely to be claimant favorable for many others. The problem in regard to
adequacy of RU data is even more difficult for RU raffinate streams, in which the
trace radionuclides, notably plutonium-239, thorium-230, and neptunium-237,
became concentrated.

Therefore, basing the WS site dose reconstruction recommendations on the Fernald site profile
may lead to claimant-unfavorable assumptions and underestimated doses assigned to some
workers.

The statement on page 35 of TBD-5 (ORAUT 2005e) consists of the following:

If specific information is not available in the worker's file, the DR should
consider the following default uranium source terms:

- Natural uranium, before 1961
+ Natural uranium, recycled, 1961 to 1962
+ Enriched (1%) uranium, recycled, 1963 to 1967. (Emphasis added.)

This recommendation is not conducive to consistency in dose reconstruction and appears to be an
over simplification resulting from the lack of sufficient information/data or investigation of the
RU issue.

Although RU was a small fraction of the total uranium processed at the WS site, its contribution
to external and internal doses, especially to the workers associated with processing it and
exposed to it by products, could be of significance in dose reconstruction. Therefore, RU should
play a more predominate role in the TBDs and in dose reconstruction.

Finding #5: Lack of Accident/Incident Documentation Not Sufficiently Addressed

The WS site TBDs do not address accidents or incidents at the WS site (or the apparent lack of
their documentation being readily available), except for the brief mention of two accidents on
page 27 of TBD-2 (ORAUT 2005b). Accidents and incidents that could potentially release
material to the operations area and to unmonitored workers onsite are important at the WS site,
because the radiological hazards may not have been fully recognized, investigated, or
documented at the time of its occurrence. During onsite interviews with former WS site
workers, the subject of accidents/incidents was mentioned with the concern that MCW did not
identify and document radiological events sufficiently, either through lack of knowledge of the
radiological hazards, or as a manner of policy at that time. SC&A’s preliminary investigation of
several cases indicates that the accidents described by former workers were not evident or were
not recorded sufficiently in the workers DOE files. For example, a serious furnace accident
occurred in 1960; however, the only mention of it in the worker’s DOE records was a couple of
brief sentences describing the medical aspect of the worker’s complaints; no investigation into
the radiological aspect of the accident was evident. There was no other documentation of the
accident in the worker’s files that SC&A could locate. Another serious accident apparently

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


iBtfective Date: (Revision No, [Document No. Page No.
February 10, 2009 __o _ SCA-TR-TASK1-0028 29 of 61

occurred in 1961; the only reference in the worker’s DOE file was an entry in the “PERSONAL
MONITORING SUMMARY RECORD,” which stated that “Data included in Feb. Accident
File.” There was no other record of it in the worker’s DOE records, Fortunately, this accident
was written up in a MCW report (MCW 1961) and the dose reconstructor evaluated the dose
received from the accident during the dose reconstruction process. However, this may not
always be the case.

Accounting for accidents and incidents that have the potential to lead to radiation exposures are
problematic at a number of DOE and DOE contractor sites. The WS site is no exception; it is
especially prone to this problem, because uranium was treated mostly as a chemical rather than a
radiological hazard during the plant’s operational period. Therefore, occurrences may not have
been documented sufficiently or be readily available to the dose reconstructor to allow dose
reconstruction by today’s standards. Although NIOSH’s WS site profile cannot correct the lack
of documentation in the workers’ DOE files, it can provide information concerning where the
dase reconstructor might search to locate any accident or incident files, and outline some of the
major occurrences that the dose reconstructor should be aware of to match them to possible
exposures for a given case. By the nature of the operations at the WS site, most doses came from
chronic low-level exposures; however, unusual occurrences, accidents, and incidents could lead
to acute intakes and/or contamination that greatly exceed the normal levels.

3.2 SPECIFIC ISSUES

SC&A reviewed the six TBDs for the WS site and has identified a number of issues that may
impact the outcome of dose reconstruction for the WS site workers; these are listed in the
following section as findings associated with each specific TBD.

3.2.1 Occupational Medical Dose ORAUT-TKBS-0028-3

Background and Introduction

The current version of the WS site TBD for occupational medical dose (ORAUT 2005c) is a
relatively short TBD, and contains some general information and data gathered from DOE site
profiles and technical documents. There is very Jittle information available concerning the WS
site occupational medical procedures, equipment, x-ray exam frequency, etc. Some references
are made to MCW documents associated with the Destrahan Street location. The TBD does
present dose conversion factors (DCFs) and organ dose estimates for a number of organs/tissues
for the periods prior to 1970 and after 1985 taken from ORAUT-OTIB-0006 (ORAUT 2005g).
Because of the lack of WS site documentation in the occupational medical area, this TBD is by
nature mostly a genetic document. SC&A has reviewed this TBD and has the following
Secondary Findings pertinent to the WS site.

Finding #6: Inconsistence in Frequency of X-ray Exams

TBD-3 (ORAUT 2005c, page 8) assumes annual x-rays for all perieds, and in Section 3.1.2
(page 7), it recommends annually from 1955 through 1966. However, in the same paragraph it
states, “A review of pre-1970 files indicates that, approximately 30% of the time, workers

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution,
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy ot applicability within the requirements of 42 CFR 82.



Effective Date: [Revision No. Document No. Page No,
February 10, 2009 9 _______ SCA-TR-TASK1-0028 44 of 61

information concerning the MDA for these in-vivo measurements for use in dose reconstruction
to address missed thorium doses, as well as recommendations for dose reconstruction for
workers who may have been exposed to thorium, but did not have in-vivo measurements
performed. Further analysis of these bioassay results may provide upper bounds for thorium
intake, but most iikely they would not provide definite quantitative values.

A 1965 DOE Annual Health Protection Review of the MCWND, WS site (DOE 1965, pages 8
and 10 of Weldon Springs Health Protection memorandum) states the foliowing:

2. Internal Exposure: Bio-assay procedures and action criteria have been given
detailed consideration previously and no significant change has since
resulted. Note is made, however, that conventional bio-assay techniques are
not adequate for monitoring potential thorium exposures as result from
current MCW production operations,

E. Thorium pot denitration operations were observed to be poorly contained and
visibly dusty. Particularly was this noted during a hand scooping transfer
procedure which was being done outside the haod. Air movement in the
vicinity was vigorously adverse to contamination control due to a partially
open outside door. Air line respirators are required for this operation which,
due to a specification requirement of the “light” oxide material, will not
permit the use of a more desirable pneumatic transfer procedure. Air
sampling by the Health and Safety Department indicated average time
weighted concentrations to be slightly less than the thorium MPC; however,
the visible dusting observed would suggest that undue confidence may have
been placed in these data and the procedures requiring respirator use.

This indicates that thorium operations were of concern, and perhaps not as well
controtled/monitored as would be desired.

Finding #24: Enriched Uranium Not Sufficiently Addressed

TBD-5 (ORAUT 2005e) discusses EU on page 12, where it is stated, “WSCP also processed
depleted uranium and slightly enriched (up to 1%) uranium as well as natural thorium.” And on
page 13, where it states, “For slightly enriched uranium, it is reasonable to assume that the
composition of 1% enriched uranium in the Technical Basis Document for the Fernald
Environment Management Project — Occupational Internal Dosimetry (ORAU 2004a, Table 5-3)
is applicable to slightly enriched uranium at WSCP.” In addition, it states, “Although uranium
with enrichments of less than 1% might have been processed at WSCP, it is claimant-favorable
to assume 1% enrichment for all slightly enriched uranium at WSCP.” These statements imply
that if the dose reconstructor uses 1% EU with the composition as listed in the Fernald TBD (and
reproduced in Table 5-5 of WS site TBD-5 (ORAUT 2005e)], then this is likely an overestimate
and, therefore, claimant favorable. There are several problems with this assumption:

¢ There is no documentation presented that shows that the WS site only received EU from
Fernald.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factial accuracy or applicability within the requirements of 42 CFR 82.


ffective Date: IRevision No. [Document No. . (Page No.
_February 10, 2009 a SCA-TR-TASK1-0028 ____17 of 61

13.5 Observations — External Dose
Observation #1 — Changes in Text of TBD-6

© Table 6-6, page 15, contains “?” where the gamma symbol should be, which causes some
confusion while reading the contents of the table.

© In Table 6-6, page 15, under the Report column, the text in the first and second row both
refer to “Figures A-1 - A-6;” however, they describe different contents. Apparently,
each one of them should refer to only a few of the Figures, not all six of them.

Observation #2 - Missing Data in TBD-6

© Table 6-2 (Summary of historical recorded dose practices) on page 12 is not complete, in
that it does not contain any information (has blank spaces) for the time periods other than
1958-1966. No Dosimeter measured quantities or Compliance dose quantities are
provided for 1957, or the periods when EU and RU (Plant operations period Special case
for enriched uranium) were processed, or 1967-1984 (Maintenance period), or for
Landauer. This information is important during dose reconstruction to correctly interpret
the recorded data and to determine if adequate data exist to assign accurate doses,
especially for beta doses, which were prevalent at the WS site.

« For the period 1957-1969, Table 6-14 (page 25) provides data for potentially missed
gamma dose during 1957-1958 and 1959-1969; however, Table 6-16 only provides beta
missed dose data for 1957-1966 (does not include 1967, 1968, and 1969).

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: [Revision No. [Document No. “age No.
February 10, 2009 0 SCA-TR-TASK1-0028 47 of 61

Finding #26: Badging Policy not Consistent

TBD-6 (ORAUT 2005f) provides a reasonable amount of detail concerning the badge exchange
cycles, such as on page 11 and elsewhere in the TBD, However, insufficient information is
provided concerning the badging policies at the WS site. TBD-6 does not provide a consistent
outline of what workers were badged and when. Table 6-4, page 14, states “All MCW Uranium
Division wage (hourly) personnel are assigned permanent film badges.” (Emphasis added.)
However, on page 14 of Section 6.2.2.4, it states, “Office females’ were not routinely assigned
film badges,” and on page 13, it states that female workers were not routinely monitored,
especially in the early days. Table 6-5 of TBD-6 lists several facilities that were considered
“non-badged areas.” However, Section 2.5.1.1 of TBD-2 (ORAUT 2005b, page 29) states that
“According to Mason (1955) health protection program document, each employee except office
females wears (a) combination film badge-security badge” (emphasis added). This raises the
question of what badging criteria were actually used in practice, and if workers who were not
considered at the time to be exposed to radiation were potentially exposed, but not monitored
because of being in a pre-defined category. The lack of a consistent and documented badging
policy may negatively impact dose reconstruction, because the dose reconstructor could assign
an unbadged worker only external environmental dose, when the worker should have been
assigned coworker external dose. Additionally, the validity of a coworker database depends on
how weil it represents a cross-section of the workers; to determine this, a knowledge of why,
when, and where workers were badged at the WS site is necessary.

Finding #27: Lack of Sufficient Coworker Data Development for External Dose

Section 6.2.3 of TBD-6 (ORAUT 2005f, page 16) mentions that annual average gamma and beta
exposures were calculated. The information for 10 categories of worker is listed in Table 6-8
and graphically displayed in Figures 6-4 and 6-5 on pages 18 and 19. However, the TBD does
not provide any information concerning the details/application of this information, such as the
following:

« The number of data points for each of the dose entries; i.¢., how many readings were
used to calculate the dose value of 110 mrem for Engineers in 1957
« The percent of workers who were monitored

* The range of readings within a given data point; i.c., what were the minimum and
maximum values for Engineers for 1957

© The 50" and 95" percentile values for each entry.

« It should be stated whether the reading from an occupationally unexposed (background)
film was subtracted from the doses before the average values were calculated, or if it was
not

© It should be stated whether zeros were include in the dose readings used to calculate the
listed values

e Itshould be stated whether these values were derived from dose values greater than some
threshold (i.e., LOD, % LOD, 50 mrem, etc.)

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: sion No. [Document No. Page No.
February 10,2009 | o SCA-TR-TASK1-0028 36 of 61

5.0 REFERENCES

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction Under the Energy Employees
Occupational Iliness Compensation Program Act of 2000, Code of Federal Regulations, May 2,
2002.

Burr, R., 1960. MCW (Mallinckrodt Chemical Works) office letter, Uranium Dust Exposure of
Pilot Plant Operator, Health and Safety Department, Uranium Division, Weldon Spring,
Missouri, June 13, 1960. Ref ID 15001.

DOE (U.S. Department of Energy) 1965. Review of Mallinckrodt Chemical Works October
1965, Oak Ridge Operations Office, Oak Ridge, Tennessee, September. Ref ID #11806.

DOE (U.S. Department of Energy) 1985. The Report of the Joint Task Force on Uraniton
Recycle Materials Processing, Report No. DOE/OR-859, Oak Ridge Operations Office, Oak
Ridge, Tennessee, September. Ref ID #26854

DOE (U.S. Department of Energy) 2001. Jnternal Dosimetry Program Technical Basis Manual:
Weldon Spring Site Remedial Action Project, Rev. 7, DOE/OR/21548-241, Oak Ridge
Operations Office, Oak Ridge, Tennessee, December, 2001. Ref ID #32724.

Dupree, E.A., 1983. “Visit to MCW Corporate Headquarters,” memorandum to file, October 25,
Oak Ridge Associated Universities, Oak Ridge, Tennessee.

Eberline (Eberline, Inc.) 1983. Weldon Spring, E2457, Sludge Analysis, 18 August 1983.
Ref ID #14778.

Holt, D., 1960. MCW (Mallinckrodt Chemical Works) office letter, Decontamination of Five-
ton Portable Hoppers for Shipment, August 8, 1960, Health and Safety Department, Uranium
Division, Weldon Spring, Missouri. Ref ID 14974)

ICRP 1982. Protection of the Patient in Diagnostic Radiology, Aunals of the International
Commission on Radiological Protection, Publication 34, Vol. 9/2, Pergamon Press, Oxford,
England.

ICRP 1996. Conversion Coefficients for Use in Radiological Protection Against External
Radiation, international Commission on Radiological Protection Publication 74, Pergamon
Press, Oxford, England.

ICRP 1997. Individual Monitoring for Internal Exposure of Workers. international Commission
on Radiological Protection Publication 78. Pergamon Press, Oxford.

MCW (Mallinckrodt Chemical Works) 1959. Shielded and Unshielded Average Time Required
for Lathe Operations and Percent of Working Day To Establish Maximum Available Exposures
At Operator’s Position, Health and Safety Department, Uranium Division, Weldon Spring,
Missouri, (no author or date, date of 1959 taken from graph). Ref ID 14938.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


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 Nationa) Institute for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Page 4 of 7

Proposed Definition of Employee Class Covered by Petition — Complete Section E.

E.1 Name o(DoEjor AWE Facility: WUeldon P la
E.2 Locations at the Facility relevant to this petition:

Ql! locations, all buidings

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:

Gil job tithes, Gil _ employees

E.4 Employment Dates relevant to this petition:
Start ees End _/967
Stat oo End
Start End

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

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

Employee appidavits te follow

Go to Part F.

Name or Social Security Number of First Petitioner: _|



Effective Date: IRevision No. [Document No. [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 36 of 61

Finding #16: Use of External Environmental Dose from Protracted Fernald Estimated
Data

TBD-4 (ORAUT 20054, page 25) outlines the method used to determine the environmental
external dose values at the WS site for the time period of 1957-1967, The external dose of

383 mrem per 2000 hours (1 work~year) was derived from using the dose information from the
Fernald site TBD-4 (ORAUT 2004a) and is listed in Table 4-11 of TBD-4 (ORAUT 2005d,
page 27) for the WS site. The data from the Fernald site was not measured directly, but was
derived from measurements post-1976 and then projected back to the pre-1976 period by scaling
of production levels. This methodology is unreliable and may not result in appropriate external
environment dose assignments to WS site workers for several reasons:

¢ It would be questionable if the external environmental doses at the Fernald site would be
sufficiently similar during the post-1976 period when the dose measurements were
performed to make them applicable to most of the pre-1976 years, even at Fernald,

¢ Although the Fernaid and WS sites both processed uranium, their source terms and
physical site characteristics (types/amounts of material discharged to the air/soil/water,
the contour of the land, the soil/vegetations, the rainfalls/winds, etc.) would not be
sufficiently compatible to allow reasonable application of the Fernald site data to the WS
site, as was done in TBD-4.

« The external dose value of 1675 mrem/year represents a one-size fits all locations (at
WSCP and WSQ) for 11 years (1957-1967). This is a broad generalization that is not

supported.

TBD-4 (ORAUT 2005d) only lists the ore concentrate stored onsite, the raffinate pits, and the
quarry as sources of external environmental exposure during the operational period (1957—1967).
This omits any external radiation originating from discharges from the process buildings
(through the stacks or out of the openings in the buildings); as direct radiation, as particulates in
the air, or from the settling out of radioactive material on the soil/surfaces. These are source
terms that should be included in external environmental dose considerations.

In view of this information, it is concluded that TBD-4 does not provide sufficient data to allow
the construction of an adequate database for assigning external environmental doses to
unmonitored workers at the WS complex with reasonable confidence. Additionally, because a
considerable fraction of the workers at the WS site were not monitored, this could potentially
impact a significant number of workers.

Finding #17: Episodic Releases

TBD-4 (ORAUT 2005d) details some of the known episodic releases, but fails to give significant
estimates of environmental dose for those episodes or provide consideration for unknown

incidents.

The TBD also notes that there is a paucity of information regarding episodic releases, resulting in
potential environmental contamination of workers. NIOSH believes the purpose of the TBD is

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



(Effective Date: Revision No. {Document No. [Page No.
February 10, 2009. 9 SCA-TR-TASK1-6028 34 of 61

50%) of the population prior to 1992 when restoration commenced, it is assumed that the
dosimeters that were provided would reasonably include an environmental dose component.
This approach tends to discount any potential dose resulting from inhaled materials that would
not be assessed by dosimetry badges that monitored only ambient gamma radiation. Also, some
workers were not included in sufficient routine bioassay programs to assess internal dose. For
unmonitored workers (nearly 50% of the population), environmental dose is attributed to only
ambient (gamma) radiation levels. Similarly, this approach does not consider internal deposition
or variations due to spatial locations on the site or episodical releases.

To this extent, NIOSH has recently agreed for other sites that using emissions data alone to
estimate air concentrations may not be appropriate. There is a need for more historic
environmental data to fill the gaps for sampling and air monitoring for a larger group of
radionuclides, such as thorium that was disposed of in the WSQ.

Secondary Findings
Finding #13: The TBD Lacks Sufficient Effluent Data Prior to 1967

The TBD (ORAUT 2005d) has relied, to the extent possible, on data derived from known source
terms, yet the validation of that data remains in question. NIOSH/ORAUT should validate this
data against any remaining effluent data or reports for the period of 1992 through 2002, when
restoration took place and sufficient monitoring data exists.

NIOSH has indicated that an obstacle to its evaluation is that effluent data back to the 1950s has
not been found at the time this TBD was written and approved for dose assessor use. Another
source of ongoing controversy involves the development of coworker data that could possibly be
used int some instances to address unaccounted for doses from environmental releases. This is
particularly important, due to the very large numbers of unmonitored workers at WSCP.

Another significance of the lack of environmental data is the lack of any early thorium data as
there is no basis to estimate thorium releases prior to 1967, even though thorium was first stored
and used at WSCP as far back as 1958. Also, significant quantities of thorium in the WSQ were
not routinely sampled until after 1985. It would be important to locate any early (1950s and
1960s) air monitoring or soil analyses data to validate the presence or absence of these nuclides
in the environs at WSCP.

SC&A believes that the lack of substantial environmental data before 1967 warrants closer
scrutiny to effectively assess all doses from environmental sources to ensure claimant
favorability.

Finding #14: Stated Uranium/Thorium/Radium/Lead Ratios should be used with Caution

TBD-4 assumes that during the operations period, Th-230 was 5% of the U-238 activity, Ra-226
was 1% of the U-238 activity, and Pb-210 was 1% of the U-238 activity (ORAUT 2005d,

page 9). These values may have been applicable for some locations and time periods at the WS
site; however, this may not have been true for certain locations, as acknowledged in TBD-5

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[Effective Date: Revision No. [Document No. [Page No,
February 10, 2009 0 SCA-TR-TASK1-0028. 59 of 61

ATTACHMENT 1: NIOSH TECHNICAL DOCUMENTS CONSIDERED
DURING THE REVIEW PROCESS

Technical Basis Documents

Oak Ridge Associated Universities Team (ORAUT), Technical Basis Document for the Fernald
Environmental Management Project — Occupational Environmental Dose, ORAUT-TKBS-
0017-4, Rev, 00, April 2004.

Oak Ridge Associated Universities Team (ORAUT), Technical Basis Document for the Fernald
Environmental Management Project — Occupational Internal Dose, ORAUT-TKBS-0017-5,
Rev. 00, May 2004.

Oak Ridge Associated Universities Team (ORAUT), Technical Basis Document for the Fernald
Environmental Management Project — Occupational External Dose, ORAUT-TKBS-0017-6,
Rev. 00, April 2004.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant — Introduction,
ORAUT-TKBS-0028-1, C. Little and R. Meyer, Rev. 00, June 28, 2005.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant — Introduction,
ORAUT-TKBS-0028-1, C. Little and R. Meyer, Rev. 00 PC-1, June 20, 2008.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant — Site Description,
ORAUT-TKBS-0028-2, C, Little and L. McDowell-Boyer, Rev. 00, June 24, 2005.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant - Occupational
Medical Dose, ORAUT-TKBS-0028-3, T. Lopez and J. Furman, Rev. 00, June 24, 2005.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant - Occupational
Environmental Dose, ORAUT-TKBS-0028-4, L. McDowell-Boyer and C. Little, Rev. 00, June
28, 2005.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant - Occupational
Internal Dose, ORAUT-TKBS-0028-5, Janet A. Johnson and Roger B. Falk, Rev. 00, June 28,
2005.

Oak Ridge Associated Universities Team (ORAUT), Weldon Spring Plant - Occupational
External Dosimetry, ORAUT-TKBS-0028-6, J. Langsted and C. Little, Rev. 00, June 24, 2005.

Oak Ridge Associated Universities Team (ORAUT), Basis for Development of an Exposure
Matrix for the Mallinckrodt Chemical Company St. Louis Downtown Site and the St Louis
Airport Site, St. Louis, Missouri, Period of Operation: 1942~1958, Rev 01, March 2005.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: iRevision No. [Document No. Page No,
February 10, 2009 9 SCA-TR-TASK1-0028 4of6l
4.2.1 Fernald Site Data Applied to Weldon Spring Workers
4.2.2 Incomplete/Incorrect Information...........+0 "
4.2.3 Incomplete Dose Reconstruction Recommendations 5
4.24 Lack of Defined Monitoring and X-ray Exam Criteri 5
4.3. Unresolved Policy or Generic Technical Issues....... seaceeevess

5.0 References. 00
Attachment 1: NIOSH Technical Documents Considered During the Review Process...

Attachment 2: Site Expert Interview Summary ....cssessesccessrseesenseneesssssscesessncenrerscepscssccnectenenessee 61

NOTICE: This report has been reviewed for Privacy Act information atid has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: evision No. [Document No. Page No.
February 10, 2009 0 ____SCA-TR-TASK}-0028 46 of 61

indication that routine extremity monitoring was performed at WS during this period, or that
geometry factors were used to correct for the position of the badge versus the radiation source.
No WS site documents have been located that address the change in film badge response as a
function of radionuclide exposure, especially to low-energy photons and changes in beta
energies. Therefore, SC&A has the following areas of concern:

« No egress monitoring ~ Unmonitored external and internal doses from lack of personal

contamination and egress monitoring was previously described. The result of this lack of
egress monitoring applies to both unmonitored and monitored workers and is especially
important for shallow dose exposures.

Badge vs. exposure geometry factors ~ The problems associated with handling uranium
material {contact work as stated on page 20 of TBD-6 (ORAUT 2005f)] close to the
body/hands and having the dosimeter badge located on the chest area was not addressed
in TBD-6 or other WS site documents. A film badge does not register the same dose as
the worker’s tissue/organs are receiving from the beta and low-energy photons when
handling, machining, scooping, etc., uranium containing materials. For example, a 1958
office memo (MCW 1959) illustrates the fact that the shielding on a lathe greatly affects
the beta dose measured; i.e., decreases it from an average of 122 mrep/hr to 0 and Table I
of that document lists non-trivial beta doses as high as 10,000 to 35,000 mrep/hr

(mrep ~ mrem). Therefore, any material/distance between the beta source and the badge
on the worker’s chest that is not between the beta source and the worker’s trunk area will
cause an under-response in the recorded dose. A TIB needs to be developed for the WS
site to correct for this underestimate of dose, such as OCAS-TIB-0013 (NIOSH 2005)
was for the MCW Destrahan Street site. This is especially important for beta exposures.

Total shallow dose ~ According to page 16 of TBD-6 (ORAUT 2005f), the dosimeters at
the WS site were calibrated using radium photon and uranium beta sources. This is
standard practice for uranium processing facilities. However, the WS site also handled
other radionuclides, as described in TBD-6 and other WS site documents; these included
Th-232 and RU with their associated decay products. Some of these radionuclides have
different beta energies than uranium. Additionally, TBD-6 does not address shallow dose
from low-energy photons, which may have been more predominate from these
radionuclides as compared to uranium. TBD-6 briefly discusses mixed beta-gamma
exposures on page [1 and states that they were determined by subtraction; it is assumed
that this means that the reading from the portion of the film behind the cadmium shield
(called SW) was subtracted from the reading of the film without cadmium shielding
(called OW), as indicated in Table 6-2 on page 12. This is not a valid procedure, unless
the beta-to-gamma ratio is known and remains constant, because beta and gamma
radiation have different darkening effects per unit dose, The response of film to gamma
radiation is very energy-dependent because of the photoelectric effect, whereas beta
interactions are not subject to this dependence. Shallow doses from both beta and Jow-
energy photons concerning calibration versus workplace radiation fields as a function of
location and time needs further investigation and more adequately addressed in this TBD.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.



[ffective Date: Revision No. [Document No. ~ Page No. ~
February 10, 2009 0 ; SCA-TR-TASK1-0028 52 of 61

originals were handwritten and some were typed). Additionally, the CER supplemental dose
database, which accompanies some of the workers’ files, appears to contain a fairly accurate
representation of the original data, and is listed in a consistent format. However, this was a very
limited qualitative review of a few cases by SC&A.

4.1.3 Objective 3: Adequacy of Data

The lack of WS site-specific data is evident in the WS site profile TBDs because in many
situations (environmental, internal, and external), the authors of the TBDs had to revert to use of
genetic dose reconstruction documents (i.¢., for occupational medical), other DOE site
data/TBDs (such as Fernald), or less-than-complete WS site data (such as parameter instead of
work area data) for the operational (1956-1966) and maintenance (1967-1984) periods at the
WS site. As previously pointed out by SC&A, the lack of adequate and accurate radiological
health documentation and data is the main issue concerning claimant-favorable dose
reconstruction for former WS site workers. The three main areas where the adequacy of data is
of concern are environmental, internal, and external doses, as outlined below.

The TBD used one serial of measurements (decontaminating 5-ton hoppers) and site parameter
measurements to determine contributing intakes to non-bioassayed workers during 1957-1967.
The hopper dust monitoring experiment was measurements performed on one day under one
particular condition, and the parameter measurements contributed very little (<1%) to the final
results. This limited (in space, operations, and time) airborne/intake data is not sufficient to
construct an adequate environmental intake dose database for unmonitored workers at the WS
complex, especially considering that a sizable fraction of the work force was not bioassayed on a
routine basis during this period.

The TBD does not address potentially missed internal doses, which should be part of a TBD for
internal dose. The LODs were generally high in the earlier years, which could result in
significant missed doses, For the dose reconstructor to assign missed dose, the TBD needs to
provide some information concerning the MDA for given bioassay techniques for the important
radionuclides of concern at the WS site as a function of time. Additionally, the TBD provides
some coworker internal dose information, but does not provide sufficient instructions for its use.
Most internal dose TBDs provide a summary section in the main text, or as an appendix, with
recommendations and procedural steps for using coworker data. To have adequate data for
internal dose reconstruction, missed dose and coworker dose data must be considered along with
recorded dose,

The external TBD (ORAUT 2005f) does not provide sufficient and/or consistent information
concerning the badging policies at the WS site in order to evaluate the adequacy of the workers’
dose records. Therefore, it has not been determined what badging criteria were actually used in
practice, and if workers who were not considered at the time to be exposed fo radiation were
potentially exposed, but not monitored because of being in a pre-defined category. The lack of a
consistent and documented badging policy may have impacted the adequacy of the dose records
necessary for dose reconstruction,

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution,
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


[Effective Date: IRevision No. t No. page No.
February 10, 2009 0 SCA-TR-TASK1-0028 6 of 6

UOz
U0s
ws
wscp
WSRP
WSQ

Uranium Dioxide

Uranium Trioxide

Weldon Spring

Weldon Spring Chemical Plant
Weldon Spring Raffinate Pit(s)
Weldon Spring Quarry

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.


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

under the Energy Employees Occupational Centers for Disease Control and Prevention
{llness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Page 3 of 7
omplete Section DO you are a Jabor organization.

D.1__ Labor Organization Information:

Name of Organization

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

D.3 Address of Petition Representative:

Street Apt # P.O. Box
City State Zip Code
D.4 Telephone Number of Petition Representative: ( ) =

D.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 labor organizations that may represent or have represented this class of
employees (if known):

Go to Part E.

Name or Social Security Number of First Petitioner



Effective Date: [Revision No. [Document No. Page No.
February 10, 2009 ] SCA-TR-TASK1-0028 27 of 61

workers located near, but not in, a process area may have received unrecorded environmental
internal and external doses from sources other than natural uranium.

Likewise, it may not be claimant favorable to assume that all the beta doses were received from
natural uranium (as in ORAUT 2005f, page 23), based solely on the fact that 97% of the material
processed was natural uranium. Some workers may have received beta doses ftom other
radioisotopes if they were involved in EU, RU, thorium, and other mission-specific projects or
processes.

Assuming that natural uranium predominates as the source of a worker’s dose could lead to an
underestimate of the worker’s correct dose if the worker was exposed to radioactive materials
other than natural uranium.

3.1.2 Secondary Findings
Finding #4: Recycled Uranium Not Adequately Recognized in the TBDs

Recycled uranium (RU) and its associated radionuclides are one of the major concerns of former
WS site workers. During onsite worker interviews, in Computer Assisted Telephone Interview
(CATY reports, and in potential SEC issues, the radionuclides from RU (plutonium, neptunium,
U-236, and fission products, such as Tc-99) are listed as foremost concems and among the items
that the workers believe the government did not know, or was not fully disclosing the health
hazards of. Therefore, RU should be clearly identified in the TBDs and included in the materials
handled at the WS site, such as in the bullet points on page 6 of TBD-1 (ORAUT 2005a) and in
Section 2.2.2.2 of TBD-2 (ORAUT 2005b, page 10), with equal importance compared to other
materials. TBDs 1, 3, and 6 make no mention of RU; TBD-2 contains one paragraph on page 23,
and TBD-5 (ORAUT 2005e) has a short section concerning RU on page 15 and mentions it on
page 35, along with enriched (1%) uranium for 1963-1967. Of the six TBDs, the environmental
dose TBD-4 (ORAUT 2005d) contains the most material concerning RU. On pages 10-12 of
TBD-4, the assumption is made that because the amounts of RU handled at the WS site were a
small fraction of the total uranium materials handled, then there is no need to consider RU and its
associated contaminants to be potentially significant contributors to onsite environmental dose,
This may be true on average or for chronic offsite environmental doses, but this assumption does
not consider the fact that some workers or certain groups of workers may have received a
substantial portion of their inhalation dose from RU and its associated contaminants for a
significant amount of time near an RU-handling process, Although TBD-4 (ORAUT 2005d) did
mention RU, it did not address the issue of RU for unmonitored workers environmental dose in
sufficient detail.

Not only are the details of the RU at the WS site important, but also the source of the RU is
important, because RU from different DOE facilities contained different concentrations of
radionuclides (DOE 1985). Therefore, the associated radiation hazards (internal and external) to
WS workers would depend on the source of the RU. Defaulting to the Fernald site concerning
RU issues fas recommended in WS TBD-5 (ORAUT 2005e, page 15)j may not be technically
sound, especially in areas where data for Fernald is uncertain, SC&A’s review of the Fernald
site profile (SC&A 2006) is summarized as follows:

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82,


Effective Date: Revision No. ument No. [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 15 of 61

13 OPPORTUNITIES FOR IMPROVEMENT

SC&A has identified some areas where changes in the TBDs would be beneficial to the claimant
by preventing possible mistakes during dose reconstruction or clarifying items to make them less
ambiguous. These are listed as Observations in this section.

1.3.1 Observations - General
Observation — Lack of Coverage of Offsite Activities

Apparently, some work was performed by offsite contractors for the WS site, which consisted of
inspection of uranium metal samples by cutting of the material and then irradiation using high-
energy betatrons. This procedure could induce fission in uranium and create fission products
that could emit radiation not normally encountered in a uranium facility, and expose nearby WS
workers and transporters who may not have normally been badged; and it could have created
inhalable radioactive material for which bioassays were not performed. This subject should be
investigated and addressed in the appropriate TBDs.

1.3.2 Observations —- Occupational Medical Dose

Equation 3-1, Dom = SnDi, is provided on page 6 of TBD-3 (ORAUT 2005c) and the individual
terms in the equation are defined, except for the term “S.” This may have been meant to be the
Greek symbol sigma “Z” for summing, instead of an “S.”

1.3.3 Observations — Environmental Dose
Observation #1 — Application of Environmental Doses
Section 4.1.2 of TBD-4 (ORAUT 2005d, page 6) states the following:

The term occupational environmental dose refers to the radiation dose received in
the course of work duties outside plant buildings, but on the WSCP site. This
TBD considers internal and external exposures to radionuclides in the outdoor
environment separately in calculating this dose. Dose reconstructors can use
estimated occupational environmental dose to develop a reliable individual dose
when a worker was not monitored adequately.

However, this statement should be qualified to apply only to workers that were not routinely
exposed and would not be considered a radiation worker by today’s standards. If the worker
would be considered a radiation worker by today’s standard, then the dose reconstruction should
be based on coworker dose data, not environmental dose data.

Observation #2 — Special Uranium Curie

The equation for the special uranium curie is correct on page 31 of TBD-5 (ORAUT 2005e), and
on page 14 of TBD-4 (ORAUT 2005d), where it is stated that “The original data are reported in

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



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: 0920-0639 Expires: 07/31/2010

Exposure Cohort Petition — Form B 20f7

Survivor Informatior Complete Section B if you are a Survivor or representing a Sur

Fifst Name Middle Initial Last Name

B.2 Social Security Number of Survivor:

Ss Apt #

State Zip Code

City
B.4_—_ Telephone Number of Survivor:
B.5 Email Address of Survivor:

Go to Part C.

Employee Information — Complete Section C UNLESS you are a labor organization.

First Name Middle Initial Last Name

C.2. Former Name of Employee (e.g., maiden name/legal name change/other):

Mr/Mrs/Ms. First Name i iti: Last Name
C.3. Social Security Number of Employee: __]
C.4 Address of Employee (if living):

Street Apt # P.O. Box
City State Zip Code
C.5 Telephone Number of Employee: ( ) =

C.6 Email Address of Employee:

C.7 Employment information Related to Petition:
C.7a_ Employee Number (if known):

C.7b Dates of Employment: Start na 195 2 End 961
C.7c Employer Name: Mailinekrod+ Chemical orKs
C.7d Work Site Location: We loon SS pring. Plant

C.7e Supervisor's Name:

Go to

Name or Social Security Number of First Petitioner:



[Effective Date: evision No. [Document No. ‘age No. :
February 30, 2009 0 __ SCA-TR-TASK1-0028 39061

This is the case for Th-234, which delivers significant dose in the gastrointestinal tract. Table 1
illustrates the dose coefficients for gastrointestinal organs due to inhalation of U-238 and
Th-234. The dose coefficients due to inhalation of Th-234 are very similar to the ones due to
inhalation of U-238. Therefore, Th-234 inhalation needs to be considered in addition to the
inhaled U-238 and sequent build up of Th-234 inside the body from the inhaled U-238.

Dose from internal Pa-234m

The dose contribution due to Pa-234m from the decay of Th-234 in the body also needs to be
included in the internal dose calculations. While it is true that the Pa-234m outside the body
only contributes to the external dose, the Pa-234m originating inside the body from Th-234
decay must be included in the internal dose calculations.

Finding #19: Incomplete Assessment of Radon Exposure

Table 5-2 of TBD-5 (ORAUT 2005e) describes the potential radionuclide exposure in the
different buildings of the WSCP. Radon is listed as a source of exposure inside Buildings 101,
103, 105, 403 and 407. However, the recommended approach in TBD-5 (page 37) to estimate
radon doses is based on environmental radon concentrations (calculated from source terms) for
the areas within 100 meters of the assumed release point, the acid recovery plant stack. Using
this approach requires that several assumptions be made, which results in large uncertainties in
the dose estimates for workers located in indoor workplaces.

The data from MCW St. Louis Downtown Site and the St Louis Airport Site in ORAUT-TKBS-
0005 (ORAUT 2005h) has shown that there is no correlation between outdoor and indoor radon
concentration. In Table 24 of ORAUT-TKBS-0005, page 209, radon measurements for indoor
and outdoor are listed. Indoor radon measurements in the Scalehouse and outdoor radon
measurements in Scalehouse exhaust are reproduced in Table 2 for 1948. The average values for
indoor measurements are approximately 4 times greater than the average values for outdoor
measurements. The same pattern is observed in the indoor and outdoor measurements presented
in other tables in ORAUT-TKBS-0005,

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: evision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 230f61 |

Because of the singularity of purpose, limited operating period, and relatively small size of the
WS site (as opposed to other DOE sites or national laboratories), SC&A did not submit a list of
questions to NIOSH as part of its evaluation of the WS site TBDs. SC&A believed that the
resources and time that would have been involved in submitting questions and obtaining
responses could be more effectively spent in performing document research and other tasks for
this site profile review.

2.4 REPORT ORGANIZATION

In accordance with directions provided by the Advisory Board and with site profile review
procedures prepared by SC&A and approved by the Advisory Board, this report is organized into
the following sections:

(1) Executive Summary

(2) Scope and Introduction

(3) Vertical Issues

(4) Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction.

Based on the issues raised, SC&A prepared a summary list of findings, which are provided in the
Executive Summary. Issues are designated as Primary Findings if SC&A believes that they
represent deficiencies in the TBD that need to be corrected and which have the potential to have
a substantial impact on at least some dose reconstructions. Issues can also be designated as
Secondary Findings or Observations if they simply raise questions, which, if addressed, would
further improve the TBDs and may possibly reveal deficiencies that will need to be addressed in
future revisions of the TBDs. Detailed analyses of the primary and secondary findings are
provided in Section 3 of this report.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Heatth for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: evision No, [Document No. Page No.
February 10, 2009. a SCA-TR-TASK1-0028 32 of 61 |

Primary Findings

Finding #10: Lack of Atmospheric Monitoring Data for Operational Period

There is no substantial site-wide atmospheric monitoring data available for the operational period
to assure an accurate and integrated environmental dose assessment. The current TBD-4
(ORAUT 2005d) recognizes this lack of site-wide atmospheric monitoring data. SC&A has
previously emphasized the need for such site-wide data during crucial periods and questioned
whether NIOSH could reasonably assess environmental dose, using only limited environmental
data, as presented in this TBD. NIOSH has relied upon the use of dose estimates for the public,
derived from its reviews of the Fernald plant data, to estimate the onsite environmental dose for
the WSCP workers. This is problematic in that raw emissions data from Fernald is not easily
converted to environmental dose for the WS site workers when several emission points of
varying geographic locations have to be considered, as well as the lack of knowledge that could
place workers at specific locations during exposure events. The TBD also evidences that
effluent data before 1981 has not been identified and/or validated, and therefore, has relied solely
on an incomplete air monitoring data point as its basis. NIOSH should therefore consider the
need to revise the TBD or better demonstrate that use of this approach is claimant favorable.

The TBD describes the predominant operation of the WSCP (1957-1967) as basically a limited
uranium conversion operation to produce metal for shipment offsite. It is further argued that
newly formed metals and other products were not prone to any long-term storage and would
release minimal environmental contaminants. It is also concluded that only minimal releases of
uranium occurred up to 1985 as the facility was shut down from 1967 to 1985. Although
thorium was monitored in more recent years, the TBD emphasizes the fact that significant
quantities of Th-232 and Th-230 were not introduced at WSCP, and accordingly present a lower
(less than 5%) environmental dose hazard. Based upon these conclusions, NIOSH believed an
estimated atmospheric dispersion model for WSCP was not warranted to further estimate
environmental dose. The TBD further concludes, based solely upon limited air monitoring data
after 1981, that environmental doses to all onsite workers would be negligible (i.e., less than
100 mrem per year) during the monitoring and pre-restoration period (1967-1992). SC&A
believes that the limited environmental data presented in the TBD and the lack of environmental
surveys of onsite locations over time does not support the tacit conclusion of negligible dose to
onsite personnel.

Finding #11: Insufficient Data for Assigning Unmonitored Workers Internal
Environmental Dose

TBD-4 (ORAUT 20054, page 14) used one serial of measurements (decontaminating 5-ton
hoppers, August 1960) (Holt 1960) and site parameter measurements to determine contributing
intakes (Table 4-6 of TBD-4) to non-bioassayed workers during 1957-1967. The hopper dust
monitoring experiment was measurements performed on one day under one particular condition,
and the parameter measurements contributed very little (<1%) to the final results. The following
are some of the reasons that it may not be a technically sound approach to use this limited data to
assign unmonitored workers’ internal environmental dose over a period of 11 years:

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution,
However, this report is pre-decisional and has not been reviewed by the Advisory Board op Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


[Document No. age No.

Effective Date: evision No. .
SCA-TR-TASK 1-0028 18 of 61

February 10, 2009 0

2.0 SCOPE AND INTRODUCTION

The review of the Weldon Spring (WS) site, in Weldon Spring, Missouri, was conducted during
January ~ September 2008 by a team of SC&A health physicists and technical personnel.
Almost al! the records for the site have been declassified at this time. However, one member of
the SC&A team held a “Q” clearance that permitted unencumbered access for this review, as

needed,

Some SC&A team members also participated in the MCW downtown St. Louis, Missouri
(estrahan Street), site profile review and were involved in the Special Exposure Cohort (SEC)
petition for that site. Because the downtown site was a precursor for the WS site, experience
gained at the first site was useful for the WS site profile review.

SC&A understands that site profiles are living documents, which are revised, refined, and
supplemented with NIOSH technical information bulletins (TIBs) as required to help dose
reconstructors. Site profiles are not intended to be prescriptive or necessarily complete in terms
of addressing every possible issue that may be relevant to a given dose reconstruction. However,
future revisions in the WS site TBDs would serve to mitigate some of the gaps and issues raised
in this report.

2.4. REVIEW SCOPE

Under the EEOICPA and federal regulations defined in Title 42, Part 82, Methods for Radiation
Dose Reconstruction Under the Energy Employees Occupational Hiness Compensation
Program, of the Code of Federal Regulations (42 CFR Part 82), the Advisory Board is mandated
to conduct an independent review of the methods and procedures used by NIOSH and its
contractors for dose reconstruction. As a contractor to the Advisory Board, SC&A has been
charged under Task 1 to support this effort by independently evaluating a select number of site
profiles that correspond to specific facilities at which energy employees worked and were
exposed to ionizing radiation.

This report provides a review of the six site profile documents (QRAUT-TKBS-0028-1 through
ORAUT-TKBS-0028-6) for the WS site in Weldon Spring, Missouri. The TBD ORAUT-TKBS-
0028-1, Weldon Spring Plant — Introduction, was re-issued with some minor changes on June 30,
2008; however, the changes in that document did not impact this review. To date, these
documents have not been supplemented by site-specific TIBs, but there are several generic TIBs
that provide additional guidance to the dose reconstructor.

Implementation guidance is also provided by so-called “workbooks,” which have been
developed by NIOSH for selected sites to provide more definitive direction to the dose
reconstructors on how to interpret and apply TBDs, as well as other available information. To
date, no WS site-specific workbooks have been developed.

SC&A, in support of the Advisory Board, has critically evaluated the WS site TBDs for the
following:

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisionai and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Revision No, [Document No. _ Pe No,

Effective Date:
February 10, 2009

9 SCA-TR-TASK1-0028 20f61
S. Cohen & Associates: Document No.
SCA-TR-TASK 1-0028
Technical Support for the Advisory Board on Effective Date:
Radiation & Worker Health Review of Draft — February 10, 2009
NIOSH Dose Reconstruction Progrant Revision No.
0 — Draft
REVIEW OF THE NIOSH SITE PROFILE
FOR THE WELDON SPRING SITE IN Page 1 of 61
| WELDON SPRING, MISSOURI
Supersedes:
Task Manager:
N/A
Date:
Joseph Fitzgerald
Project Manager:
Date:
John Mauro

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution,
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: IRevision No. (Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 54 of 61_

that data for the worker population at the WS site through the years, and therefore, the adequacy
of the recorded and/or coworker dose data.

4.1.4 Objective 4: Consistency among Site Profiles

When compared to other site profiles, SC&A’s review of the WS site profile TBDs (ORAUT
2005a-f) did not find major inconsistencies that would significantly impact dose reconstruction
or create claimant-unfavorable situations. In reviewing the WS site TBDs, SC&A did note that
surrogate information/data was used more frequently than normally used in other site profiles.
The WS site TBDs went beyond comparing the general operations and mission of the WS site
with other sites, to actually using some of the recorded/derived data from the Fernald site.
Additionally, the WS site TBDs did not provide summary sections concerning the
application/limitations/instructions for use of the coworker dose data presented in the TBDs as
most site profiles do,

4.1.5 Objective 5: Regulatery Compliance
No regulatory compliance issues were identified by SC&A in the WS site TBDs.
4.2 USABILITY OF SITE PROFILE FOR INTENDED PURPOSES

Because the purpose of a site profile is to support the dose reconstruction process, it is critical
that the site profile assumptions, analytic approaches, and procedural directions be clear,
accurate, complete, and auditable (i.¢., sufficiently documented). The WS site TBDs generally
provided some method of assessing worker’s internal, external, occupational medical dose, and
environmental dose; however, SC&A has some concerns in the use of these TBDs for dose
reconstruction.

4.2.1 Fernald Site Data Applied to Weldon Spring Workers

While NIOSH attempted to use WS site information and data to the extent it was available,
NIOSH also made extensive use of Fernald site data and extrapolated it to WS site workers. The
assumptions necessary to equate Fernald site information/data to WS site workers was not
always sufficiently supported. Therefore, SC&A questions whether some of the data and
recommendations in the present WS site TBDs are usable for WS site workers.

4.2.2 Incomplete/Incorrect Information

In several places in the WS site TBDs, complete information/data is not provided for the dose
reconstructor. For example, the method used at the WS site to determine shallow dose is not
sufficiently addressed, and Table 6-2 on page 12 of TBD-6 (ORAUT 2005f) is not complete.
Additionally, cost-center codes are not reliable categories to use to assess uranium urine data as
used in TBD-5 (ORAUT 2005e). Different solubility classes are listed for different isotopes of
the same element in Table 5-6 of TBD-5 (ORAUT 2005¢), but the WS site could have had only
one type of solubility for all isotopes of a given element in a given process or building. SC&A.
found that TBD-5 (ORAUT 2005e) failed to include some decay components of the uranium
decay chain, and that the assessment of radon exposure was incomplete.

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Heaith for factual accuracy or applicability within the requirements of 42 CFR 82.


[Effective Date: |Revision No. [Document No. ~ Page No. —_
February 10, 2009 0 SCA-TR-TASK1-0028 40 0f61

Table 2, Comparison of Indoor and Outdoor Radon Measurements for the Scalehouse
(Data from Table 24 of ORAUT-TKBS-0005)

Workplaces Measured radon concentrations for 1948 in units of 1 x 10 Ci/,
No. ofsamples [Min | _Med/Mean |" Max | GSD
Indoor areas

Scalehouse 21 0.00 4.05 33
Scalehouse 193 0.03 2.02 32.8
Scalehouse Sampie room. 6 0.22 4.10 19
Scalehouse Sample room 68 0.03 2.84 25

Average = 3.25

Yards and other outdoor areas

Scalehouse intake/exhaust 3 0.12 2.06
Scalehouse exhaust 18 __ 4 0.13 3.08
Scalehouse exhaust i 0.93
Scatehouse exhaust a 24 i) 2.2 49

Average = 0.85

Ratio of Indoor/Outdoor = 3.25/0.85 ~ 4.

This shows that the approach recommended in TBD-5 is not always claimant favorable. NIOSH
should propose a more reliable and claimant-favorable approach to assess the radon exposure for
WSCP.

Finding #20: Different Solubility Classes Listed for Same Element
Table 5-6 of TBD-5 (ORAUT 2005e, page 15) provides a list of solubility classes for uranium
and thorium compounds in some of the buildings at the WSCP. Some of this information is

summarized below:

Table 3. Solubility Classes for Uranium and Thorium at WSCP

Building 103:

U-234; _D=0.20; W=0.50; Y=0.30;,
U-235:_D=0.20; W=0.44; Y=0.36;
U-238: D=0.75; W=0.25.

Building 108:

D=0.19; W=0.20; 3
7: D=0.14; W=0.47; Y=0.39;
U-238: D=0.19; W=0.20; Y=0.61,
Buildings 406, 408, 410, 417:
Th-232: W=0.35; Y=0.65;
Th-228: W=0.65; Y=0.35.

Because there were no means of separating isotopes of a given element at the WSCP, the
chemical properties were the same for all uranium isotopes and the chemical properties were the

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.



Effective Date: IRevision No. |Document No. Page No.
February 10, 2009 0 SCA-TR-TASK 1-0028 42 of 61

Each exposed person is scheduled three or more times per year, more frequently
if there is reason to suspect increased exposure. The rotation of group
representation tends to show the average level and variation within each plant
area. Unexposed persons are scheduled less frequently to provide a control base.

Additionally, a document entitled, Urinary Uranium Program, issued by MCWUD in 1960
(MCW 1960) provides instructions for waged and salaried personnel:

1. Wage - Wage employees working with uranium are to be sampled in a series
of five samples twice a year. As much coverage as possible is desired for
different types or degrees of exposure; therefore, each series of samples or
group weeks should contain personnel from as many work areas or crafts as
possible, Example: All the pipefitters or the Pot Room operators should not
be scheduled in the same series.

For the selection of these groups, the place and type of work needs to be
known. The names and cost centers of the employees may be obtained from
the IBM wage report. For Maintenance personnel, the information as to
crafts may be obtained from the Maintenance Office. The shift schedules of
the Production operators in the Sampling Plant and Refinery may be obtained
Jvom the Job History Sheets received by the Health Department.

2. Wage personnel not in contact with uranium are sampled once quarterly, as
clase scheduling is not necessary; therefore, the IBM wage report will suffice
Sor selection.

3. Salary — Salaried personnel are sampled one, two or three times a year;
therefore, all the salaried personnel are treated as one representative group.

However, SC&A’s preliminary review of some of the WS site claimant files indicates that, while
the urine samples were sometimes started on a Friday, they did not necessarily follow a M-F-M
schedule, and were not generally on a rotating or routine basis, Therefore, when urinalysis data
is used, either for individual claimants or as a basis for deriving coworker doses, it should be
used with the caution that it is does not necessarily represent the prescribed sampling schedules
in the MCW documents. From an initial analysis of WS site claimant files, SC&A did find that,
while the urinalysis sampling routine was not always as prescribed, most of the claimants’ DOE
files contained individual urinalysis results by date, as opposed to an average of a number of
analysis results by week or quarter.

Secondary Findings
Finding #22: Cost-Center Codes may not be Reliable for Dose Reconstruction

The use of the cost-centers codes listed on pages 19 and 22-27 of TBD-5 (ORAUT 2005e) are
not practical, because workers’ DOE files generally do not contain cost-center information; some

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Effective Date: ‘Revision No. |Document No, Page No, 11 _|

February 10, 2009 0 SCA-TR-TASK1-0028 __ | Sof6l
ACRONYMS AND ABBREVIATIONS

Advisory Board Advisory Board on Radiation and Worker Health

AEC Atomic Energy Commission

CATI Computer Assisted Telephone Interview

CER Center for Epidemiological Research

CFR Code of Federal Regulations

Ci Curies

DOE Department of Energy

DR Dose Reconstruction or Dose Reconstructor

dpm Disintegrations per Minute

DU Depleted Uranium

EEOICPA. Energy Employees Occupational IlIness Compensation Program Act of 2000

EU Enriched Uranium

GSD Geometric Standard Deviation

keV Kilo electron Volt

LAT Lateral

LOD Limit of Detection

MCW Mallinckrodt Chemical Works

MCWND Mallinckrodt Chemical Works Nuclear Division

MCWUD Mallinckrodt Chemical Works Uranium Division.

MDA Minimum Detectable Activity

NIOSH National Institute for Occupational Safety and Health

n/p Neutron-to-Photon Ratio

NTA Eastman Kodak Nuclear Track Film Type A

OCAS Office of Compensation Analysis and Support

ORAUT Oak Ridge Associated Universities Team

OTIB ORAU Technical Information Bulletin

OW Open window

PFG Photofluorography

RU Recycled Uranium

SC&A S. Cohen and Associates

SEC Special Exposure Cohort

sw Shielded window

TBD Technical Basis Document

TIB NIOSH Technical Information Bulletin

U30g, Triuranium Octoxide (called yellow cake)

UF4 Uranium Tetrafluoride (called green salt)

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.