SEC Petition Evaluation Report
 

Petition SEC-00090 

Report Rev #:_ 0 Report Submittal Date: December 19, 2007 

Subject Expert(s): Karin Jessen, Tim Adler, James Berger, Don Stewart 

Site Expert(s): Elizabeth Brackett 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition B 

Qualification Date 

DOE/AWE Facility Name 

SEC-00090 83.13 August 17, 2007 Mound Plant 

Petitioner Class Definition 

All employees who worked in all areas within the boundaries at the Mound Plant from February 1949 – 

present. 

Proposed Class Definition 

All employees of the Department of Energy (DOE), its predecessor agencies, and DOE contractors and 

subcontractors, who were monitored or should have been monitored, for internal Ra-Ac-Th exposures while 

working in all areas of the Mound site for a number of work days aggregating at least 250 work days from 

October 1, 1949 through February 28, 1959, or in combination with work days within the parameters 

established for one or more other classes of employees in the SEC. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

SEC-00091 83.13 Mound Plant Merged with SEC-00090 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

None 

ORAU Lead Technical Evaluator: Karin Jessen ORAU Review Completed By: Daniel H. Stempfley 

Peer Review Completed By: [Signature on file] 

Brant Ulsh 

12/19/2007 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

Stuart Hinnefeld for J. W. Neton 

12/19/2007 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

12/20/2007 

Date 
SEC-00090 12-19-07 Mound Plant 

This page intentionally left blank 

2 of 95 
 

SEC-00090 12-19-07 Mound Plant 

Evaluation Report Summary: SEC-00090 Mound Plant 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition 

Petition SEC-00090, qualified on August 17, 2007, requested that NIOSH consider the following 

class: All employees who worked in all areas within the boundaries at the Mound Plant from 

February 1949 – present. 

NIOSH-Proposed Class Definition 

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all employees of the Department of Energy (DOE), its predecessor agencies, 

and DOE contractors and subcontractors, who were monitored, or should have been monitored, for 

internal Ra-Ac-Th exposures while working in all areas of the Mound site for a number of work days 

aggregating at least 250 work days from October 1, 1949 through February 28, 1959, or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

Feasibility of Dose Reconstruction 

NIOSH cannot estimate internal Ra-Ac-Th exposures from the arrival of K-65 sludge in October 1949 

through February 28, 1959, when the related area of work was decontaminated and decommissioned 

and sufficient monitoring was in place. With exception of this class, per EEOICPA and 42 C.F.R. § 

83.13(c)(1), NIOSH has established that it has access to sufficient information to: (1) estimate the 

maximum radiation dose, for every type of cancer for which radiation doses are reconstructed, that 

could have been incurred in plausible circumstances by any member of the class; or (2) estimate 

radiation doses of members of the class more precisely than an estimate of maximum dose. 

Information available from the site profile and additional resources is sufficient to document or 

estimate the maximum internal and external potential exposure to members of the proposed class 

under plausible circumstances during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate internal Ra-Ac-Th 

exposures for the members of the proposed class. 

3 of 95 
SEC-00090 12-19-07 Mound Plant 

This page intentionally left blank 

4 of 95 
SEC-00090 12-19-07 Mound Plant 

Table of Contents 

Evaluation Report Summary: SEC-00090 Mound Plant ......................................................................... 3 

1.0 Purpose and Scope.......................................................................................................................... 9 

2.0 Introduction .................................................................................................................................... 9 

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis ............................................ 10 

4.0 Data Sources Reviewed by NIOSH.............................................................................................. 11 

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 11 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 12 

4.3 Facility Employees and Experts .......................................................................................... 13 

4.4 Previous Dose Reconstructions ........................................................................................... 15 

4.5 NIOSH Site Research Database .......................................................................................... 16 

4.6 Other Technical Sources...................................................................................................... 16 

4.7 Documentation and/or Affidavits Provided by Petitioners ................................................. 16 

5.0 Radiological Operations Relevant to the Proposed Class ............................................................ 17 

5.1 Mound Plant and Process Descriptions ............................................................................... 18 

5.2 Mound Functional Areas ..................................................................................................... 21 

5.2.1 Polonium Research and Production......................................................................... 21 

5.2.2 Plutonium-238 Research and Development ............................................................ 21 

5.2.3 Tritium Production .................................................................................................. 22 

5.2.4 Substitute Materials, Radium-226, Actinium-227 and Thorium-228 ..................... 22 

5.2.5 Thorium-232 Extraction .......................................................................................... 22 

5.2.6 Thorium-230 and Protactinium-231 ........................................................................ 23 

5.2.7 Rare Isotope Programs ............................................................................................ 24 

5.2.8 Uranium-234 from Plutonium-238 .......................................................................... 24 

5.2.9 Thorium-229 from Uranium-233 (Irradiated Thorium-232) ................................... 25 

5.3 Mound Radiological Buildings............................................................................................ 25 

5.3.1 Mound Site Decommissioning ................................................................................ 28 

5.4 Radiological Exposure Sources from Mound Operations ................................................... 29 

5.4.1 Alpha ....................................................................................................................... 29 

5.4.2 Beta.......................................................................................................................... 30 

5.4.3 Neutron .................................................................................................................... 30 

5.4.4 Photons .................................................................................................................... 32 

5.4.5 Incidents .................................................................................................................. 33 

6.0 Summary of Available Monitoring Data for the Proposed Class ................................................. 33 

6.1 Mound Internal Monitoring Data ........................................................................................ 34 

6.1.1 Tritium Bioassay ..................................................................................................... 37 

6.1.2 Polonium-210 Bioassay ........................................................................................... 37 

6.1.3 Plutonium-238 and Plutonium-239 ......................................................................... 38 

6.1.4 Radon Isotopes ........................................................................................................ 39 

5 of 95 
SEC-00090 12-19-07 Mound Plant 

6.1.5 Protactinium-231 ..................................................................................................... 40 

6.1.6 Thorium-230 ............................................................................................................ 41
 

6.1.7 Thorium-232 ............................................................................................................ 41
 

6.1.8 Substitute Materials, Radium-226, Actinium-227, and Thorium-228 Records ...... 42 

6.1.9 Uranium Records ..................................................................................................... 42 

6.1.10 Americium-241 and Curium-244 ............................................................................ 43 

6.2 Mound External Monitoring Data ....................................................................................... 43 

6.3 Mound Air Sampling Data .................................................................................................. 49
 

7.0 Feasibility of Dose Reconstruction for the Proposed Class ......................................................... 49 

7.1 Pedigree of Mound Data...................................................................................................... 50 

7.1.1 Internal Monitoring Data Review............................................................................ 51 

7.1.2 External Monitoring Data Review........................................................................... 55 

7.2 Internal Radiation Doses at Mound..................................................................................... 56 

7.2.1 Process-Related Internal Doses at Mound............................................................... 58 

7.2.1.1 Tritium...................................................................................................... 58 

7.2.1.2 Polonium-210 Operations......................................................................... 58 

7.2.1.3 Plutonium ................................................................................................. 59 

7.2.1.4 Other Radionuclides with Bioassay Monitoring Data .............................. 59 

7.2.1.5 Other Radionuclides with No Bioassay Data ........................................... 60 

7.2.1.6 Radon........................................................................................................ 62 

7.2.1.7 Missed Internal Dose ................................................................................ 64 

7.2.1.8 Decommissioning and Decontamination.................................................. 64 

7.2.2 Ambient Environmental Internal Radiation Doses at Mound ................................. 64 

7.2.3 Internal Dose Reconstruction .................................................................................. 65 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 65 

7.3 External Radiation Doses at Mound.................................................................................... 66 

7.3.1 Process-Related External Radiation Doses at Mound ............................................. 67 

7.3.1.1 Radiation Exposure Environment............................................................. 67 

7.3.1.2 Dosimetry Records ................................................................................... 68 

7.3.2 Ambient Environmental External Radiation Doses at Mound ................................ 68 

7.3.3 Mound Occupational X-Ray Examinations............................................................. 69 

7.3.4 External Dose Reconstruction ................................................................................. 70 

7.3.4.1 Photon Dose.............................................................................................. 70 

7.3.4.2 Electron Dose ........................................................................................... 70 

7.3.4.3 Neutron Dose ............................................................................................ 71 

7.3.4.4 Unmonitored Individuals Working in Production Areas.......................... 71 

7.3.4.5 Medical X-ray........................................................................................... 72 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 72 

7.4 Evaluation of Petition Basis for SEC-00090 ....................................................................... 73 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00090 ................................. 75 

7.4.1.1 Monitoring of Workers ............................................................................. 75 

7.4.1.2 Incident Occurrence and Reporting.......................................................... 75 

7.4.1.3 Employees Prohibited from Receiving Monitoring ................................. 76 

7.4.1.4 Mound Documentation ............................................................................. 76 

7.4.1.5 Occurrence Reporting............................................................................... 78 

7.4.1.6 The “Rad” Database ................................................................................. 78 

6 of 95 
SEC-00090 12-19-07 Mound Plant 

7.4.1.7 Mound Plant Employee Health Records Removed to LANL .................. 78 

7.4.1.8 Mound Plant Employee Health Records Kept in Building 61 ................. 80 

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00090 .................................. 81 

7.4.2.1 Employee badges ...................................................................................... 81 

7.4.2.2 Contamination Incidents........................................................................... 81 

7.4.2.3 Plutonium through Ventilation Ducts....................................................... 82 

7.4.2.4 Reports...................................................................................................... 82 

7.4.2.5 Documents taken from Mound ................................................................. 83 

7.4.3 Evaluation of General Concerns.............................................................................. 83 

7.4.3.1 Various Contamination Incidents ............................................................. 83 

7.4.3.2 Inadequate Monitoring and Protection ..................................................... 84 

7.4.3.3 Actinium-227 Urine Samples ................................................................... 84 

7.4.3.4 Neutrons ................................................................................................... 84 

7.4.3.5 D&D Era Bioassay ................................................................................... 85 

7.5 Summary of Feasibility Findings for Petition SEC-00090.................................................. 86 

8.0 Evaluation of Health Endangerment for Petition SEC-00090...................................................... 87 

9.0 NIOSH-Proposed Class for Petition SEC-00090 ......................................................................... 87 

10.0 References .................................................................................................................................... 90 

Tables 

4-1: No. of Mound Site Claims Submitted Under the Dose Reconstruction Rule ................................ 15 

5-1: Mound Plant Operational Chronology........................................................................................... 17 

5-2: Chronology of Significant Mound Laboratory Programs and Events ........................................... 19 

5-3: Principal Alpha-Emitting Radionuclides Present at Mound .......................................................... 29 

5-4: Beta Emitters Associated with Polonium Production at Mound.................................................... 30 

5-5: Neutron Energy by Facility and Operation.................................................................................... 31 

5-6: Photon Energy by Facility and Operation...................................................................................... 32 

6-1: Bioassay Programs and Action Levels........................................................................................... 36 

6-2: PORECON Polonium Record Summary ....................................................................................... 38 

6-3: Summary of Historical Plutonium Analytical Procedures ............................................................. 38 

6-4: PURECON Plutonium Record Summary ...................................................................................... 39 

6-5: Radon Isotope Survey Data by Building and Period ..................................................................... 40 

6-6: Summary of External Monitoring Data in the MESH Database.................................................... 45 

6-7: Mound Dosimeter Use and Assignment Policies........................................................................... 47 

6-8: Beta-Photon Dosimeter Types and Exchange Frequency.............................................................. 48 

6-9: Neutron Dosimeter Types and Exchange Frequency..................................................................... 48 

7-1: Radon Isotope Survey Data by Building and Time Period ........................................................... 62 

7-2: Radon-222 WLM Assumptions for Dose Reconstruction ............................................................ 63 

7-3: Summary of Feasibility Findings for SEC-00090.......................................................................... 86 

7 of 95 
SEC-00090 12-19-07 Mound Plant 

This page intentionally left blank 

8 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

SEC Petition Evaluation Report for SEC-00090
 

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all employees who worked in all areas 

at the Mound Plant from February 1, 1949 through August 17, 2007. It provides information and 

analyses germane to considering a petition for adding a class of employees to the congressionallycreated SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.1 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose. 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, NIOSH must also then determine whether or not there is a reasonable 

likelihood that such radiation doses may have endangered the health of members of the class. The 

regulation requires NIOSH to assume that any duration of unprotected exposure may have endangered 

the health of members of a class when it has been established that the class may have been exposed to 

radiation during a discrete incident likely to have involved levels of exposure similarly high to those 

occurring during nuclear criticality incidents. If the occurrence of such an exceptionally high-level 

exposure has not been established, then NIOSH is required to specify that health was endangered for 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

9 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

those workers who were employed for at least 250 aggregated work days within the parameters 

established for the class or in combination with work days within the parameters established for other 

SEC classes (excluding aggregate work day requirements). 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and to the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.2 

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis 

Two petitions associated with the Mound Site requested that NIOSH consider classes for addition to 

the SEC: 

1.	 Petition SEC-00090, qualified on August 17, 2007, requested the following class: All employees 

who worked in all areas within the boundaries at the Mound Plant from February 1949 – present. 

2.	 Petition SEC-00091, qualified on September 24, 2007, requested the following class: All 

employees who worked within the boundaries of the Mound Plant from February 1, 1949 through 

December 31, 1970. 

The petitioners provided information and affidavit statements in support of the petitioners’ belief that 

accurate dose reconstruction over time is impossible for the Mound workers in question. The SEC00090 petitioner claimed that personal monitoring records are buried at Los Alamos National 

Laboratory (LANL) and at the Nevada Test Site (NTS). NIOSH is aware that Mound records were 

buried at LANL. NIOSH determined that this concern was sufficient to qualify the petition. During 

the evaluation of this petition, NIOSH determined that the applicable buried records have been 

recovered or are otherwise accounted for (based on information NIOSH has collected, including an 

interview with a former Mound Records Manager). 

The information and statements provided by the petitioner qualified the petition for further 

consideration by NIOSH, the Board, and HHS. Petition SEC-00091 was qualified based on its 

timeframe being completely encompassed by Petition SEC-00090. Consequently, NIOSH 

merged the Petition SEC-00091 into Petition SEC-00090. This report, SEC-00090, evaluates 

the feasibility of reconstructing doses for all employees who worked in all areas at the Mound 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 

10 of 95 
SEC-00090 12-19-07 Mound Plant 

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

addressed in Section 7.4. 

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The 

NIOSH-proposed class includes all Mound employees who were monitored, or should have been 

monitored, for internal Ra-Ac-Th exposures from October 1, 1949 through February 28, 1959. The 

petitioner-requested class was reduced as a result of the feasibility evaluation documented in Section 

7.0. The petitioner-requested class was reduced because, except for the class above, NIOSH has 

obtained sufficient information to reconstruct doses for the entire evaluation period. NIOSH cannot 

estimate internal Ra-Ac-Th exposures from the arrival of K-65 sludge in October 1949 through 

February 28, 1959, when the related area of work was decontaminated and decommissioned and 

sufficient monitoring was in place. 

4.0 Data Sources Reviewed by NIOSH 

NIOSH identified and reviewed numerous data sources to determine information relevant to 

determining the feasibility of dose reconstruction for the class of employees proposed for this petition. 

This included determining the availability of information on personal monitoring, area monitoring, 

industrial processes, and radiation source materials. The following subsections summarize the data 

sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into 

Mound Plant operations or related topics/operations at other sites: 

•	 ORAUT-TKBS-0003, Technical Basis Document for the Savannah River Site, Rev. 01, Oak Ridge 

Associated Universities; August 21, 2003; SRDB Ref ID: 20178 

•	 TBD for the Mound Site – Introduction, ORAUT-TKBS-0016-1; Rev. 00; September 9, 2004; 

SRDB Ref ID: 19784 

•	 TBD for the Mound Site – Site Description, ORAUT-TKBS-0016-2; Rev. 00 PC-1; July 7, 2006; 

SRDB Ref ID: 30057 

•	 TBD for the Mound Site – Occupational Medical Dose, ORAUT-TKBS-0016-3, Rev. 01 PC-2; 

March 31, 2006; SRDB Ref ID: 30059 

11 of 95 
SEC-00090 12-19-07 Mound Plant 

•	 TBD for the Mound Site – Occupational Environmental Dose, ORAUT-TKBS-0016-4; Rev. 00; 

October 6, 2004; SRDB Ref ID: 19789 

•	 TBD for the Mound Site – Occupational Internal Dosimetry, ORAUT-TKBS-0016-5; Rev. 00; 

September 9, 2004; SRDB Ref ID: 19790 

•	 TBD for the Mound Site – Occupational External Dosimetry, ORAUT-TKBS-0016-6; Rev. 00; 

August 11, 2004; SRDB Ref ID: 19791 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

guidance for preparing dose reconstructions at particular sites or categories of sites. An ORAU 

Procedure provides specific requirements and guidance regarding EEOICPA project-level activities, 

including preparation of dose reconstructions at particular sites or categories of sites. NIOSH 

reviewed the following OTIBs and procedures as part of its evaluation: 

•	 OTIB: Maximum Internal Dose Estimates for Certain DOE Complex Claims, ORAUT-OTIB0002, Rev. 02; February 7, 2007; SRDB Ref ID: 29947 

•	 OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, 

ORAUT-OTIB-0006, Rev. 03 PC-1; December 21, 2005; SRDB Ref ID: 20220 

•	 OTIB: Interpretation of Dosimetry Data for Assignment of Shallow Dose, ORAUT-OTIB-0017, 

Rev. 01; October 11, 2005; SRDB Ref ID: 19434 

•	 OTIB: Internal Dose Overestimates for Facilities with Air Sampling Programs, ORAUT-OTIB0018, Rev. 01; August 9, 2005; SRDB Ref ID: 19436 

•	 OTIB: Estimating Doses for Plutonium Strongly Retained in the Lung, ORAUT-OTIB-0049, Rev. 

00; February 6, 2007; SRDB Ref ID: 29975 

•	 OTIB: Internal Dose Reconstruction, ORAUT-OTIB-0060, Rev. 00, February 6, 2007, SRDB Ref 

ID: 29984 

•	 OTIB: Internal Dosimetry Coworker Data for the Mound Site, ORAUT-OTIB-0061, Rev. 00; 

June 22, 2007; SRDB Ref ID: 32524 

•	 OTIB: Calculation of Dose from Intakes of Special Tritium Compounds, ORAUT-OTIB-0066, 

Rev. 00; April 26, 2007; SRDB Ref ID: 31421 

•	 PROC: External Dose Reconstruction, ORAUT-PROC-0006, Rev. 01; June 5, 2006; SRDB Ref 

ID: 29985 

12 of 95 
SEC-00090 12-19-07 Mound Plant 

•	 PROC: Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC-0060, 

Rev. 01; June 28, 2006; SRDB Ref ID: 29986 

•	 PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, Rev. 01; 

July 21, 2006; SRDB Ref ID: 29987 

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed 21 former Mound employees. In-person or 

telephone conversations were held with 20 of the former employees. Questions were developed and 

refined for each conversation to correspond to the former employee’s job title and work experience. 

For one interviewee, a questionnaire was sent and returned by e-mail. 

Interviewee selection was based on individual availability, information regarding job description, and 

potential knowledge of Mound working conditions during the period of the proposed class. The 

interviews ultimately included employees representing a wide range of Mound experiences, including 

records management, health physics, internal and external dosimetry, knowledge of site operations, 

and radiological incidents. Information obtained during the interviews contributed to the general 

knowledge of Mound conditions and monitoring practices and included information regarding records 

from the T building that were buried at the Los Alamos National Laboratory. 

Several interviews were conducted in August 2007, but the majority was conducted during late 

October and early November 2007. In general, the information obtained was consistent with that 

found in NIOSH documents regarding the Mound Site. 

•	 SEC ER-related Interview by ORAU Team with Chief Counsel; October 30, 2007; SRDB Ref ID: 

36860 

•	 SEC ER-related Interview by ORAU Team with Assistant HP; October 29, 2007; SRDB Ref ID: 

36862 

•	 SEC ER-related Interview by ORAU Team with Records Manager; August 9, 2007; SRDB Ref 

ID: 35950 

•	 SEC ER-related Interview by ORAU Team with Records Manager November 8, 2007; SRDB Ref 

ID: 36867 

•	 SEC ER-related Interview by ORAU Team with Research Chemist; October 30, 2007; SRDB Ref 

ID: 36866 

•	 SEC ER-related Interview by ORAU Team with Custodian, RCT; October 29, 2007; SRDB Ref 

ID: 36869 

•	 SEC ER-related Interview by ORAU Team with Research Chemist, Group Leader; November 6, 

2007; SRDB Ref ID: 36870 

13 of 95 
SEC-00090 12-19-07 Mound Plant 

•	 SEC ER-related Interview by ORAU Team with Technical Specialist, Manager of Internal 

Dosimetry; November 5, 2007 and December 7, 2007; SRDB Ref ID: 36873
 

•	 SEC ER-related Interview by ORAU Team with Laborer-then Material Handler-then Electrician; 

November 6, 2007; SRDB Ref ID: 36875
 

•	 SEC ER-related Interview by ORAU Team with Senior Research Specialist; November 9, 2007; 

SRDB Ref ID: 36876
 

•	 SEC ER-related Interview by ORAU Team with Senior Health Physicist; September 9, 2007; 

SRDB Ref ID: 35953
 

•	 SEC ER-related Interview by ORAU Team with member of Nuclear Physics Group; November 8, 

2007; SRDB Ref ID: 36878
 

•	 SEC ER-related Interview by ORAU Team with Subject Expert about Mound Records Disposal; 

August 16, 2007; SRDB Ref ID: 35952
 

•	 SEC ER-related Interview by ORAU Team with Decontamination Worker-then RCT; November 

6, 2007; SRDB Ref ID: 36934
 

•	 SEC ER-related Interview by ORAU Team with Electrician and Union Official; November 6, 

2007; SRDB Ref ID: 36879
 

•	 SEC ER-related Interview by ORAU Team with Internal Dosimetrist; October 31, 2007; SRDB 

Ref ID: 36881
 

•	 SEC ER-related Interview by ORAU Team with Custodian-then D&D Worker-then Health 

Specialist; November 6, 2007; SRDB Ref ID: 36882
 

•	 SEC ER-related Interview by ORAU Team with Senior Health Physicist-then HP Specialist-then 

Manager of Radon Group; Date not identified; SRDB Ref ID: 36883
 

•	 SEC ER-related Interview by ORAU Team with Radiological Engineer-then Supervisor for Health 

Protection; October 23, 2007; SRDB Ref ID: 36884
 

•	 SEC ER-related Interview by ORAU Team with Member of HP Group-then HP Supervisor-then 

Bioassay Lab Manager; October 29, 2007; SRDB Ref ID: 36877
 

•	 SEC ER-related Interview by ORAU Team with Internal Dosimetrist- then Dose Reconstruction 

Manager; October 24, 2007; SRDB Ref ID: 36886
 

•	 SEC ER-related Interview by ORAU Team with Operating Chemist-Internal Dosimetry 

Supervisor-Environmental Monitoring-Analytical Development-Nuclear Operations-Research 

Specialist; October 30, 2007; SRDB Ref ID: 36887
 

14 of 95 
SEC-00090 12-19-07 Mound Plant 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review for the period of February 1, 1949 through August 17, 2007. 

(NOCTS data available as of December 6, 2007) 

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

Description Totals 

Total number of claims submitted for dose reconstruction 491* 

Total number of claims submitted for energy employees who meet the proposed class definition 

criteria (February 1, 1949 through August 17, 2007) 485* 

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

definition criteria 348 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

proposed class definition 420 

Number of claims for which external dosimetry records were obtained for the identified years in the 

proposed class definition 430 

Number of claims for which some internal and some external records were obtained for the identified 

years in the proposed class definition. 412 

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

total submitted claims. 

There are 485 Mound claims with some employment between the years of 1949 and 2007. However, 

five claims have not yet received a dosimetry response from the site; therefore, only the 480 claims 

that have received a dosimetry response from the site were reviewed for this evaluation. NIOSH 

reviewed each claim to determine whether internal and/or external personal monitoring records could 

be obtained for the employee. As indicated in Table 4-1, NIOSH has been able to obtain internal 

monitoring data for the majority of the claims that met the proposed class definition. Of the total 

number of claims submitted, 420 (88%) have internal monitoring data and 430 (90%) have external 

monitoring data. 

The dose reconstruction claimant interviews (CATI) conducted with the claimants provide some 

detailed information regarding work locations, hours worked, incidents, and hazards encountered. 

The interviews also identified conditions for which there would have been potential for either internal 

or external exposures. 

15 of 95 
SEC-00090 12-19-07 Mound Plant 

4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database to locate documents supporting the evaluation of 

the proposed class. There were 879 documents in this database that were identified as pertaining to 

Mound. These documents were evaluated for their relevance to this petition. The documents include 

historical background on external and internal dosimetry programs and evaluations; annual, semiannual, and quarterly technical summary reports; annual environmental reports; annual reviews of the 

Mound Plant; evaluations of specific buildings; site surveys; and facility and process descriptions. 

4.6 Other Technical Sources 

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

records repository: 

•	 PORECON (Polonium Reconstruction) Database: Mound-owned database that contains bioassay 

data 

•	 PURECON (Plutonium Reconstruction) Database: Mound-owned database that contains bioassay 

data 

•	 MORE (Mound Occupational Radiological Exposure) Records Center where original employeespecific health physics records were filed by employee name 

•	 MESH (Mound Environmental, Safety, and Health) Database: Mound-owned database that 

contains dosimetry (internal and external) results, medical information, and employment history. 

•	 Pre-1989 Dose Assessment Project: MJW Corp., as a Mound subcontractor, conducted a dose 

reconstruction project on internal doses received prior to 1989. The dose reconstruction efforts 

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

4.7 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners: 

Petition SEC-00090: 

•	 Copy of letter presented and submitted to the official record on May 15, 2007 to the U.S. 

Department of Labor, Ohio; OSA Ref ID: 103188 (6-4-07); 103455 (7-20-07) 

•	 Copy of Dayton Daily News (Ohio) article, Report Says Ill Mound Workers Treated Unfairly; 

OSA Ref ID: 103188 (6-4-07); 103455 (7-20-07) 

•	 Copy of Dayton Daily News (Ohio) article, Mound Plant Records Buried in New Mexico; OSA 

Ref ID: 103188 (6-4-07); 103455 (7-20-07) 

16 of 95 
SEC-00090 12-19-07 Mound Plant 

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

•	 Affidavit from former employee; OSA Ref ID: 103513 (7-30-07 

•	 Affidavit from former employee; OSA Ref ID: 103554 (8-13-07) 

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

Department of Labor dated Jun 7, 2007 in regard to her dose reconstruction. This letter indicates 

that the “prior dose reconstruction” may be invalid for not only the petitioner but for other Mound 

Plant employees; OSA Ref ID: 103554 (8-13-07) 

Petition SEC-00091: 

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

•	 No affidavits were associated with this petition. 

5.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize both radiological operations at the Mound Plant from February 

1, 1949 through August 17, 2007 and the information available to NIOSH to characterize particular 

processes and radioactive source materials. From available sources NIOSH has gathered process and 

source descriptions, information regarding the identity and quantities of each radionuclide of concern, 

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

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

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

NOTE: Throughout this evaluation report, the term “Mound” will be employed to refer to all 

historical phases of, and successive names for, the Mound Site. Mound was operated by several 

different companies. Table 5-1 shows the operational chronology. These companies contracted to the 

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

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

Table 5-1: Mound Plant Operational Chronology 

Company* Years 

Monsanto Chemical Company 1948-1961 

Monsanto Research Corporation 1961-1988 

EG&G Mound Applied Technologies, Inc 1988-1997 

Babcock and Wilcox of Ohio, Inc. 1997-2002 

CH2M Hill Mound, Inc. 2003-2006 

S. M. Stoller Corporation (DOE Legacy Management) 2003-present 

Accelerated Remediation Company (aRc): OU-1 Landfill 

and PRS-441 Rail Yard remediation 

2006-present 

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

17 of 95 
SEC-00090 12-19-07 Mound Plant 

5.1 Mound Plant and Process Descriptions 

The Miamisburg Closure Project (MCP), as it is currently called, has also been known as the 

Miamisburg Environmental Management Project (MEMP), the Mound Site, and formerly, the Mound 

Laboratory, Plant or Facility. The site took the “Mound” name from a nearby Native American burial 

mound. The 306-acre facility occupied a hill in the center of Miamisburg, Ohio. 

Mound was the nation’s first postwar U.S. Atomic Energy Commission (AEC) site to be constructed. 

It was established to consolidate and continue the polonium work conducted at the Dayton Project for 

the Manhattan Project. The Dayton Project was operated by Monsanto Chemical Company from 

January 1, 1943 to December 31, 1949. Several Dayton units became part of the Mound facility. The 

Dayton Site’s primary activity was to produce Po-210 to fabricate atomic warhead initiators. Dayton 

processes removed polonium as a contributor in the uranium-238 series or from neutron-irradiated 

bismuth. (For detailed information on the Dayton Project facilities and their activities, see the Mound 

site description in ORAUT-TKBS-0016-2.) Energy employees who worked for Monsanto on the 

Dayton Project are covered in SEC Petition Evaluation Report SEC-00049. 

Construction of the Mound Plant began in 1946, with polonium processing becoming operational in 

February 1949. There were originally 14 buildings with 360,000 square feet of space. Mound went 

on to play an important role in research and development, manufacture of weapons, and evaluation 

and maintenance of explosive components for the nuclear defense stockpiles. Other work there 

included tritium recovery, isotope separations methods, development and production of heat sources 

in support of space programs, support of the fossil fuels program, and a variety of nuclear materials 

processing. Radioisotopes of uranium and thorium were studied until 1985. At that time, the DOE 

discontinued or transferred the projects to other facilities. 

At Mound, the narrowly-focused polonium production work expanded to include the development and 

production of weapons components using Pu-238. Mound’s main focus was to support DOE weapons 

and non-weapons programs, especially chemical explosives and nuclear technology. One of its 

principal missions was to research, develop, and manufacture non-nuclear explosive components for 

nuclear weapons that were then assembled at other sites. 

Much of Mound’s Cold War work involved production of the polonium-beryllium (Po-Be) initiators 

used in early atomic weapons, and the research and manufacture of radionuclides. In the 1950s, the 

facility began to manufacture a variety of nuclear weapons parts, including cable assemblies, 

explosive detonators, and electronic firing sets. Mound work evolved to include stable isotope 

separation, fossil fuels research, development of radioisotope thermoelectric generators (RTGs) for 

providing electrical power for space exploration, and other non-nuclear research and development. 

Early Mound programs investigated the chemical and metallurgical properties of Po-210 and its 

applications. Research and development included the fabrication of neutron and alpha sources for 

weapons, and weapons use. Po-210 production declined in the 1960s until it was phased out in 1971. 

Developing, producing, and providing surveillance of detonators for military applications began in 

1957. Explosive timers were developed in 1959, and manufacture of timers began in 1963. 

Ferroelectric transducers and firing set component development and manufacture began in 1962. 

18 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

Tritium-handling technologies began in the mid-1950s in support of weapons and non-weapons 

programs. Tritium was recovered for reuse in weapons. Metal tritides were used at Mound primarily 

to trap H-3 using uranium tritides. In addition, research was conducted on metal tritides. Tritium 

targets might also have been processed. 

Other major Mound operations included: 

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

•	 Development and manufacture of chemical heat sources 

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

•	 Development of radioisotope heat sources used by the National Aeronautics and Space 

Administration and other programs 

•	 Research and development of chemical explosives and pyrotechnics, adhesives, plastics, and 

elastomers for the nuclear weapons program 

•	 Research and development of thermonuclear energy fuel systems 

•	 Research and development of the joining of exotic metals 

•	 Development of instrumentation for the nuclear safeguard program 

•	 Research and development of separation of gases and energy conversion systems 

• Research and development of technologies for radioactive waste management 

Table 5-2 lists the significant Mound Laboratory Programs and Events. 

Table 5-2: Chronology of Significant Mound Laboratory Programs and Events 

(Table 5-2 spans three pages) 

Year Activity 

1943 Planning begins for the Dayton facilities. 

10-44 Polonium operations begin at Unit III 

1946 Mound Laboratory planning started. 

1948 Mound Laboratory occupied. 

1949 • Polonium operations moved from Dayton Units to Mound Laboratory. 

• First program separated Ra-226 from barium-rich uranium ore, with pitchblende residue called K-65. 

• Experimental extraction of Ra-226 from the K-65 was conducted in the R Bldg. In October, Mound received 

200 lbs. of K-65 in a single drum. 

• Study of processes for decontamination of radioactive waste generated by Hanford Pu production reactors. 

• From 1949-1953, three different types of processing wastes were studied to concentrate constituents such as 

Cs-137, Ru-106, Sr-90, Zr-93, Co-60, Nb-94, Sb-125, Te-123, Ni-63, rare earth elements, and Pu-239. Benchscale testing began in the R building. 

19 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

Table 5-2: Chronology of Significant Mound Laboratory Programs and Events 

(Table 5-2 spans three pages) 

Year Activity 

1950 • Separation of Po-208 and Po-209 from proton (accelerator) irradiation of bismuth. 

• Separation of Ac-227 from irradiated Ra-226. 

• Uranyl sulfate – heavy water fuel system research. 

• Civilian power reactor research involving uranium, Pa-231, and Pu-239; mission ended in 1963. 

1951 Small amount of research with Ra-226 in preparation of cave operation in SW building. Involved irradiated 

Ra-226 and recovery of Ac-227 and Th-228 from Ra-226. 

1952 Pilot plant installed in SW building for processing reactor waste. Reactor waste processing areas also included 

Warehouses 9 and 13, WD, SD, SW, R, and M. 

1953 SW Building (tritium handling) constructed with a dirt floor. 

1954 • Invention of the Po-210-fueled thermoelectric generator. 

• Initiation of several programs requiring tritium-handling technologies. 

• Construction of thorium refinery for breeder reactor program (never operated). 

1955 • Repackaging of 6,000 55-gallon drums containing thorium ore and sludge was on-going through 1966 due to 

deterioration and failure of the drums. 

• August 1955: Small research program in R Bldg involving recovery and subsequent purification of Pa-231 from 

natural sources. 

• June 1955: Radium Cave operation shut down (Ra-226, Ac-227, Th-228, Ra-223, Ra-224 daughters) 

• Decontamination and decommissioning ongoing until February 1959. 

1956 • Completed separation of 1.3 grams of Pa-231 in Building HH. 

• Weighable quantities of Th-230 (ionium) separated. 

• Pu-239/Be neutron sources manufactured. 

• Nuclear weapon detonator development, production, and surveillance; mission ended in 1989. 

1959 • Pu-239 reactor fuels laboratory operational. 

• Tritium waste recovery and purification facility operational. 

• U-233 research involving about ten research personnel 

• D&D completed for old cave 

1960 Pu-238 used in large quantities in production operations. Process areas included the R, SM, and PP Buildings. 

1961 Development of Pu-238 heat sources for thermoelectric generators. 

1963 Several Po and Gadolinium polinide heat sources containing 100-1000 Ci of Po-210 were encapsulated in 

refractory metal. 

1964 • 190 mg of Ac-227 was processed in the new cave area. 

• Thorium ore and sludge moved to bulk storage in Building 21 

1965 Gaseous effluent control system operational in SW Building. 

1967 • 54,000 Ci of high-purity Po-210 were processed for Mound experimental work and commercial use. 

• 14.5 kg of Pu-238 were recovered from waste material. 

1968 PP Building 38 operational for processing Pu-238. 

1969 • Waste line break and subsequent contamination of the abandoned Miami-Erie Canal bed with Pu-238. 

• Began tritium recycling from retired weapon parts. 

• 3,701 Ci of Po-210 were produced for both internal and external customers. 

• Six SNAP 27 sources were produced. Each source contained 3735 Ci of Pu-238 

10/70 

– 6/71 

Plutonium inventory was reduced to a minimum level. 22.5 kg of Pu-238 scrap was shipped to SRS for burial. 

1972 • Tritium effluent control project began. 

• Non-weapons polonium work terminated. 

1973 Pu-238 oxide was processed for four multi-hundred watt (4.2 kg each) and 2 Viking sources (1.2 kg each) 

1974 • Thorium ore and sludge completely removed from site. 

• Po-210 decontamination of Technical (T) Building completed. 

1975 Pu-238 recovery operations terminated. 

1977 Californium Multiplier Neutron Radiography Facility installed. 

20 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

Table 5-2: Chronology of Significant Mound Laboratory Programs and Events 

(Table 5-2 spans three pages) 

Year Activity 

1989 Removal of soil contaminated with uranium near Building 34. 

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

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

1993 • DOE decision to transfer defense mission from Mound. 

• Pu-238 decontamination of PP Building 38 and Acid Leach Field (Area D). 

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

1995­

2006 

Decontamination and decommissioning of approximately 116 contaminated structures and 400 contaminated land 

areas 

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

treatment system) initiated 

5.2 Mound Functional Areas 

The following subsections describe the key functional areas of the Mound Plant. The source for most 

of the information below is ORAUT-TKBS-0016-2, which provides additional information regarding 

Mound functional areas. 

5.2.1 Polonium Research and Production 

Polonium research and production activities conducted at the Dayton Laboratory benefited from 

improved facilities at the Mound site specifically designed for those processes. These included the 

encapsulation of the process in purpose-designed process equipment with provisions for remote 

operation. A detailed description of this equipment is included in an unpublished chapter of the book 

Polonium by H. V. Moyer (Mound Po, various dates; Polonium, 1956). The controls used 

concentration cells to perform worked that had been performed at the Dayton Laboratory in openfaced hoods. 

In 1954, Mound began using Po-210 to produce thermoelectric energy. The first RTG was produced 

in 1958. Po-210 was primarily produced by neutron irradiation of naturally-occurring Bi-209 slugs to 

produce Bi-210 via a (n, γ) reaction followed by beta decay to Po-210. Prior to 1956, Mound’s first 

primary mission was to manufacture initiators for nuclear weapons. This included the extraction of 

Po-210 from neutron-irradiated bismuth slugs and beryllium-machining operations. Po-210 was also 

used in the first Space Nuclear Auxiliary Power (SNAP) program in 1961. Mound polonium research 

and production was gradually phased out in 1971. 

5.2.2 Plutonium-238 Research and Development 

Pu-238 research and development activities began at Mound during the mid-1950s. Pu-238 research 

programs were transferred from Lawrence Livermore National Laboratory to Mound in 1959. The 

first production of metallic Pu-238 was achieved in the spring of 1960. The research and development 

(R&D) activities were directed toward the development and production of stable RTGs. More than 

500 RTGs were produced for a variety of applications, including electric power generation for 

satellites, life support systems, spacecraft, pacemakers, and an artificial heart. The first SNAP 

21 of 95 
SEC-00090 12-19-07 Mound Plant 

provided 2.6 watts of power to the Transit navigation satellite in 1963. Metallic plutonium was 

initially used in SNAP applications because the devices were designed to disintegrate and burn during 

reentry. A change in philosophy resulted in the use of plutonium dioxide which was less vulnerable 

and maintained integrity during reentry. 

Reactor fuels research using Pu-239 led to the development of chemically and physically stable 

microspheres of unique plutonium compounds and alloys using an inductively-coupled plasma torch. 

These same processes were adapted during the mid-1960s for Pu-238 to produce high-integrity 

microspheres for heat sources with essentially no transportable or removable activity. 

From the early 1960s to the late 1970s, Mound continued to produce both heat sources and complete 

RTG systems in the SM and PP buildings. Related work with Pu-238 occurred in the R building and 

Building 50. 

5.2.3 Tritium Production 

Following some earlier research with small quantities of tritium, production of tritium for nuclear 

weapon applications began during the mid-1950s. Related activities included tritium enrichment, 

recovery processes, and control of tritium-contaminated wastes. The tritium recycling and enrichment 

system had many applications. The technology was further applied to reduce/recover tritium from 

stack effluents. Tritium processing took place in many of the buildings at Mound. 

5.2.4 Substitute Materials, Radium-226, Actinium-227 and Thorium-228 

Po-210 has a half-life of 138 days, so the shelf-life of fabricated components was limited. The items 

had to be replaced and returned for recovery and/or rework. Alternate alpha emitters with somewhat 

longer half-lives were sought to replace Po-210. One promising candidate was Ac-227, with a halflife of 21 years. A residue containing radium, known as K-65 residue, was received on site in October 

1949 for the purpose of recovering the AC-227 from this material (ORAU, 2003e, p.33). Recovery of 

Ac-227 from material containing the U-235 series was not as effective as the neutron irradiation of 

Ra-226 targets to produce the Ac-227. Initial Ra-226 recovery, purification, and production 

operations began at Monsanto in Dayton. Similarly, work progressed on extraction and production of 

Ac-227 from irradiated Ra-226. The level of effort for this program was considerably expanded at 

Mound. However, after rapid growth of the program during 1951 and 1952, the program essentially 

ended by July 1953, as alpha emitter-beryllium initiators were abandoned in favor of neutrons 

generated from small D-T accelerators. 

5.2.5 Thorium-232 Extraction 

In the mid-1950s, Mound was directed to perform the R&D necessary to extract thorium from 

Brazilian monazite sludge and other thorium-bearing materials. This thorium refinery was to provide 

target material for irradiation to produce U-233 and the thorium breeder reactor. A Th-232 refinery 

process pilot plant (the “Monex” process) was assembled in Room 1B of the SW Building in the 

spring of 1955. Construction began on the thorium refinery to the west of the SW building. The 

project had barely begun when it was ended. The construction directive was issued on March 11, 

1955 and the construction was cancelled on May 9, 1955. However, preparations included receipt of 

at least 1,650 tons of thorium-bearing material during December 1954 from the National Lead 

Company of Middlesex, New Jersey. Most was in the form of Brazilian monazite sludge, which 

22 of 95 
SEC-00090 12-19-07 Mound Plant 

comprises the residue after extraction of other valuable rare earths; however, the lot also included 

oxalate sludge, recycle metal (thorium metal pieces and turnings), thorium oxide (calcined sawdust), 

and thorium sulfate (Monex, 1955). The sludge was quite corrosive and many of the 6,000 drums 

were deteriorated and leaking upon receipt. Although the thorium refinery project had been 

terminated, the drums posed a high maintenance legacy. Drum deterioration was constant and failure 

was frequent. For this reason, several hundred drums were periodically re-drummed in the summer 

months between 1954 and 1966. By 1962, each had been re-drummed twice. Drums were stored in 

various locations throughout the plant, and in 1964, authorization was received to build a facility 

(Building 21) to store the material. This facility was completed in 1966, by which time the entire lot 

had been re-drummed a third time. The facility was essentially a “silo” with no doors or windows and 

two storage bays. One thousand thirty-eight drums were emptied into the smaller of two basins, and 

3,576 were dumped in the large basin (Meyer, date unknown). The remaining drums apparently 

remained in outdoor storage areas. Since the lot was composed of a variety of materials, some of the 

drums were likely to have been less corrosive, and so were not repeatedly re-drummed. 

5.2.6 Thorium-230 and Protactinium-231 

Starting in 1946, the Manhattan Engineer District began seeking supplies of Th-230 (U-238 series) 

and Pa-231 (U-235 series). The Th-230 was to be used in the Redwing nuclear tests and kilogram 

quantities were needed for nuclear weapons test diagnostics. Pa-231 and Pa-233 were to be produced 

by neutron irradiation of Th-230 and Th-232. An Ionium (Th-230) Program was mounted and in 1949 

Argonne National Laboratory developed a pilot plant using Th-230-enhanced wastes (known as Cotter 

Concentrate, St. Louis airport cake or simply Airport Cake) from Mallinckrodt in St. Louis. This was 

a raffinate produced after solvent extraction of uranium with diethyl ether and after extraction of Ra226. In November 1955, Mound was directed to construct a facility, within three months, to recover 

Th-230 from the Airport Cake. By May 18, 1955 five shipments totaling 400 grams (8.16 Ci) had 

been provided to the AEC. While directed to deliver another 500 grams, Mallinckrodt failed to 

deliver the required additional Airport Cake. Leftover Airport cake from the first runs was processed, 

but with difficulties due to concentrated impurities. In the late 1950s, Mound sent the remaining 22 

grams of Th-230, along with 250 grams of thorium oxide, to Idaho for irradiation in the high-flux 

Materials Testing Reactor (MTR). The capsules were allowed to decay for a year in the reactor canal, 

but it is not known if they were ever processed for recovery of Pa-231 and Pa-233. 

Pa-231 was produced in the early 1950s to be a surrogate for Pa-233 for a study of the physical and 

chemical properties of the element. In the thorium breeder reactor blankets, 27-day Pa-233 was 

created in the sequence Th-232 → Pa-233 → U-233. Production of Pa-231 proceeded intermittently 

between the 1950s and September 1979, the first campaign occurring during the period of 1954 

through 1958. The feed materials were U-235-bearing raffinates from Mallinckrodt, Fernald, and the 

Cotter Corp. in Canon City, Colorado. Processing R&D started in 1954 in Room 167 of the R 

building. Following lab scale pilot tests, Room 145 of the R building was set up to process fivekilogram batches. A pilot plant was installed in the HH building in July 1955. During March 1956, 

the operation was moved into the SW building and took advantage of some of the thorium refinery 

equipment. Approximately 20,000 lb. (80 drums) of this Sperry Cake was processed at Mound. This 

processing consumed approximately half of the material in order to produce the single gram of 

protactinium requested by the AEC. The remaining drums were to be used to produce another gram, 

but this work concluded after another 240 mg were produced. 

23 of 95 
SEC-00090 12-19-07 Mound Plant 

Later efforts to recover Pa-231 used a large amount of another type of residue from the uranium 

refining process called Cotter Cake. This material had been identified as a useful source of 

radionuclides during research associated with the Ionium (Th-230) Program. One thousand, two 

hundred-fifty-one drums of this material were received during 1975 for processing in the pilot plant 

built in the SW building. This plant ran from 1974 to 1979, during which 22 drums were processed to 

recover 339 g. of Th-230 and 890 mg of protactinium. 

5.2.7 Rare Isotope Programs 

The Rare Isotope Programs were originally known as the Separation and Purification of Special 

Heavy Element Isotopes. They began in the mid-1950s and lasted through 1985. Numerous projects 

were developed during that 30-year period. A variety of radionuclides and separation processes were 

generally carried out in the SW, SM, and R buildings. Principal processes included: 

• Extraction of U-234 from aged Pu-238 from 1962-1972 

• Extraction of Pa-231 and Th-230 from uranium ore “tailings” from 1954-1957 

• Extraction of Th-229 from U-233 (from irradiated Th-232) from 1966-mid 1970s 

• Extraction of Pa-231 from irradiated Th-230 

5.2.8 Uranium-234 from Plutonium-238 

About ten grams per year of U-234 were extracted from Pu-238 from the mid-1950s through the early 

1970s. The U-234 oxide was shipped to Oak Ridge for use with U-235 to make neutron flux 

measurements. U-234 was produced within 13 alpha glove boxes in the R Building. An associated 

solvent extraction system was in Room 1 of the SM Building. 

Most of the Pu-238 was initially precipitated as the oxalate. Pu-238 from returned heat sources was 

dissolved in nitric acid and then precipitated with dimethyloxalate. The filtrate contained the U-234. 

The Pu oxalate was calcined at 450o

 C and returned to storage to permit in-growth of U-234 for future 

processing. Following evaporation and addition of nitric acid, aluminum nitrate was added to the 

uranyl nitrate. After pH adjustment, the solution passed through an ion exchange column that 

adsorbed the U-234. Uranium was eluted from the columns with 7N nitric acid while 0.35 molar 

nitric acid eluted plutonium. Uranyl nitrate was converted to the chloride and passed into an anion 

exchange column. Uranium, plutonium and neptunium were distinctly eluted with varying 

concentrations of hydrochloric acid. Uranium chloride was precipitated with the addition of 

ammonium hydroxide. The filtered precipitate was washed, dried, and converted to uranium oxalate. 

In SM-1, U-234 was recovered from ion exchange raffinate solutions by extraction with tri-noctylphosphine oxide (TOPO). The aqueous phase was sent to plutonium recovery. Plutonium in the 

TOPO was stripped by a carbonate solution and also sent for recovery. The remaining TOPO was 

recycled through the process. 

24 of 95 
 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

5.2.9 Thorium-229 from Uranium-233 (Irradiated Thorium-232) 

Los Alamos provided a kilogram of U-233 in 1958. The U-233 and Th-229 were produced by 

neutron irradiation of Th-232 as shown in the following reactions. 

90 Th 232 ( 1.405E+10 yr) + o n 1 → 90 Th 233 

90 Th 233 (22.3 min) → 91 Pa 233 + -1 β o

 + γ

91 Pa 233 (27.0 da) → 92U 233 + -1 β o

 + γ

92 U 233 (1.59E+10 yr) → 90 Th 

229 + 2 α 4 

In 1966, small-scale separations of Th-229 were carried out within a new hot-cell facility in the SW 

building. Processing of the U-233 began in two Type A glove boxes with a connecting fume hood 

along the north wall of SW-22. The process also used bench tops in SW-140 and fume hoods in 

SW-132. 

The U-233 was dissolved in nitric acid. Liquid-liquid organic extraction was accomplished by adding 

di-sec-butylphenyl phosphorate and TOPO in diethylbenzene. Thorium was stripped from the organic 

phase with 0.5 molar oxalic acid followed by a second strip with 8 molar nitric acid. This process 

required 20 to 30 hours for a 75 g batch. This program processed 1.5 kg of aged U-233 to produce 30 

mg (6 mCi) of Th-229. 

The Mound Plant ceased non-weapons work in 1971 and stopped production of weapons components 

in 1995. 

5.3 Mound Radiological Buildings 

The following subsections provide a brief overview of the major Mound radiological buildings from 

February 1, 1949 through August 17, 2007. The source for most of the information below is ORAUTTKBS-0016-2, which also lists the radionuclides of concern for each building along with other 

information. For a detailed listing, refer to Mound Site Radionuclides by Location (King, 1995) 

Mound Unit V Buildings: 

•	 HH Building or Hydrolysis House derived its name from its primary function, the hydrolysis of 

highly-radioactive bismuth chloride and aluminum chloride solutions. In 1963, the HH Building 

was converted to stable gaseous isotope separation by use of thermal diffusion, liquid diffusion, 

and cryogenic processes. 

•	 PP Building or Plutonium Processing Building 38 was completed in December 1967. SM Building 

processes, fabrication operations, and recovery processes were transferred to PP Building along 

with waste treatment facilities, R&D (including material research), and analytical laboratory 

support activities. PP Building was used primarily for processing Pu-238 dioxide received from 

the Savannah River Plant (SRP). 

25 of 95 
 

SEC-00090 12-19-07 Mound Plant 

•	 R Building or the Research Building was built in 1948. It has handled a number of programs 

involving a number of radionuclides over the years, including Po-210, H-3, U-238, Ac-227, 

Pu-238, and Pu-239. The major radionuclide was Pu-238 with research beginning in 1959 and 

continuing through the 1960s. In addition, R&D was conducted with tritium and experimentation 

was conducted with metal tritides. Because some tritides were so poorly metabolized, their 

biological half-lives were in the order of hours. 

•	 SM Building or the Special Metallurgical Building was built in 1960 and became operational in 

1961. It was designed to receive a liquid plutonium nitrate mixture from the SRP that was used in 

a variety of programs, mainly heat source projects. In addition, SM Building housed recovery 

processing, waste treatment facilities, R&D, and analytical support activities. 

•	 SW Building was similar to R Building, consisting of many laboratories engaged in a variety of 

research, development, analytical, recovery, and surveillance activities. The “old cave” and “new 

cave” areas consisted of several rooms set up for “hot” work with several types of alpha and 

gamma radiation and project capabilities. Other major programs were the thorium refinery project, 

rare isotope program, neutron source, U-234 separation program, and the tritium programs. The 

tritium programs included tritium enrichment, effluent capture, process development, component 

evaluation, and scrap recovery and tritium waste solidification. SW building was used in 

processing Cotter Concentrate (St. Louis Airport Cake) starting in the early 1970s and terminated 

late in that decade. Pilot plant operations in SW were designed to recover Th-230 and Pa-231. 

•	 T Building was host to a number of research, development, and production programs using 

various radioisotopes, including Pu-239, Pu-238, U-233, U-235, and U-238. The two major 

programs were the polonium and tritium programs. From 1949 to 1973, Po-210 programs included 

processing and separation, fuels research and development, neutron source, and other research, 

development, and production programs. This work was performed on the first and second floors. 

An extensive renovation program from 1966 to 1968 prepared the way for additional R&D work, 

but the renovations were never used due to unanticipated funding reductions. T Building was 

essentially dormant from 1969 to 1972 due to this loss of funding. The tritium programs resumed 

in the early 1970s when a major effort was undertaken to reduce the fugitive emissions of tritium. 

Other T Building activities included nondestructive testing, environmental testing, gamma and 

mass spectroscopy, calorimetry, neutron activation analysis, and safeguards R&D. In 1974, 

decontamination of T-Buildings operations and service floors (50% of the building) was 

completed (Mound, 1999). 

•	 WD Building, which became operational in February 1949, was the central facility at Mound for 

the treatment of radioactive liquid wastes. From its inception, this facility included a low-level 

alpha wastewater system, with SW, R, PP, SM, HH, T, B, and H Buildings as sources. On arriving 

at WD Building, wastewater was precipitated, coagulated, and filtered, and the sludge was 

solidified so it could be shipped off site. The supernatant from the clarifloculator was filtered, 

neutralized to the proper pH, monitored to see if it was below standard, and released to the Great 

Miami River. 

26 of 95 
SEC-00090 12-19-07 Mound Plant 

•	 WDA Building, or the WDA alpha wastewater treatment facility, was built in 1966 as an annex to 

WD Building for the treatment of plutonium wastewater from the PP and SM Buildings. It was 

designed as both a high-risk drumming station and a low-risk wastewater treatment facility. 

•	 Special Metallurgical Building, or the SM Building, was built in 1960 and became operational in 

1961. It was designed to receive liquid plutonium nitrate mixture from the Savannah River Plant 

that was used in a variety of programs, mainly heat source projects. In addition, SM building 

housed recovery processing, waste treatment facilities, R&D, and analytical support activities. 

(ORAUT-TKBS-0016-2) This building also included the Plutonium Processing (PP) area change 

room, laboratories, maintenance shops, and building services. This building underwent 

decontamination and decommissioning starting in 1977. (Ten-Year Plan, 1977) 

Contamination Areas 

•	 Area 8, Thorium Contaminated Soils from Areas 1 and 9: This area is located northwest of 

Building 31, on the SM/PP hill on the eastern side of the Mound site. The area is approximately 

25,000 sq ft. Soil was buried in this area from decontamination activities from repackaging of 

Th-232 sludges in 1965 and 1966. Pu-238 and thorium have been detected in this area. 

•	 Area 10, Debris from Dayton Units: This area is located west of Building 30, on the slope of the 

SM/PP hill on the East Central portion of the Mound site. It was used for disposal of contaminated 

concrete from the Dayton Units. One-hundred-sixty truckloads from Unit IV and 100 truckloads 

from Unit III were deposited here. The area is approximately 15,000 sq ft. The primary 

contaminant was Po-210. Soil was buried in this area in 1950. 

•	 Area 12, Thorium Contaminated Soil: This area is located west of Building 38, on the SM/PP hill 

on the East Central portion of the Mound site. Th-232- and Pu-238-contaminated soil from SM 

building and thorium-contaminated soil from Area 1 were placed in this area in 1965. 

•	 WTS Pipline: This pipeline line ran from SM building and Building 38 to the WD building. In 

1969, the high-risk waste line ruptured below the WD building and resulted in Pu-238 

contamination of an off-site portion of the abandoned Miami-Erie Canal bed. In 1991, 

approximately 600 linear feet of contaminated pipe was unearthed and shipped off-site for burial. 

The pipe had been the waste line that connected HH Building with the WD facility. (Mound, 

1999). 

27 of 95 
 

 

SEC-00090 12-19-07 Mound Plant 

5.3.1 Mound Site Decommissioning 

Throughout the operating lifetime of the Mound Plant, facilities that no longer were necessary to site 

operations were removed from service and isolated, decontaminated, and/or demolished as 

appropriate. After weapons component production ceased in 1995, the emphasis of site activities 

shifted to decommissioning facilities. The decommissioning and eventual closure of the Mound Site 

is being conducted under the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) and a Federal Facilities Agreement among DOE, USEPA, and Ohio EPA in 

accordance with a process known as MOUND 2000. Following clean-up, properties at the former 

Mound Site are conveyed to the Miamisburg Mound Community Improvement Corporation 

(MMCIC). Land-use restrictions are conveyed with the property, if necessary, to ensure future 

protection of human health and the environment. Decommissioning management is the responsibility 

of the DOE Office of Environmental Management (EM). Responsibility for site management will be 

transferred to the DOE Office of Legacy Management (LM) following completion of clean-up. 

(Mound Site, Miamisburg, Ohio Fact Sheet, DOE, October 2007) (Transition Plan for the Mound 

Closure Project, DOE, March 2005). 

Since the termination of Mound production activities, the major DOE/EM contractors primarily 

involved with site closure and decommissioning have been: 

• EG&G Applied Technologies Prior to 1995 – September 1997 

• BWXTO, Inc. October 1997 – December 2002 

• CH2M HILL Mound January 2003 – July 2006 (decommissioning declared complete) 

In early 2003, S. M. Stoller Corporation was designated the major site contractor for DOE/LM. 

Accelerated Remediation Company (aRc) was selected in October 2006 to further remediate the OU-1 

Landfill and PRS-441 Rail Yard areas under a congressionally-funded project. These two contracts 

remain in effect as of this evaluation report. (Personal communication, 2007) 

A site assessment in 1995 identified approximately 116 remaining buildings and 400 remaining land 

sites with potential radioactive and/or hazardous material contamination. The 306-acre site was 

divided into discrete land parcels: Phase 1 (consisting of subparcels A, B, and C); Parcels 3, 4, 6, 6A, 

7, 8, and 9; and Parcels D and H. As of October 2007, Parcels D, H, 3, and 4 have been completed 

and conveyed to MMCIC; the Phase 1 parcel has been completed, but not yet conveyed to MMCIC; 

and Parcels 6, 7, and 8 have been remediated and are undergoing the CERCLA review process. The 

OU-1 Landfill and the Rail-Yard area in Parcel 9 are still in the process of remediation. Further 

information on the decommissioning activities for specific Mound Site facilities is available at the 

following DOE/LM web site: http:www.lm.doe.gov/land/sites/oh/mound/mound.htm. 

28 of 95 
 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

5.4 Radiological Exposure Sources from Mound Operations 

This section discusses the potential radiological exposure present at Mound during the period under 

evaluation. These sources include alpha and beta emissions, neutrons, and photons as well as a 

variety of incidents and accidents. 

5.4.1 Alpha 

The primary alpha-particle-emitting isotopes at Mound varied from area to area depending on the 

operations. Table 5-3 lists the alpha-emitting radionuclides of most concern, their radioactive 

half-lives, specific activities, and primary alpha energies. 

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

Radionuclide Half-Life Specific Activity (Ci/g) Alpha Energy (MeV) 

Americium-241 (Am-241) 432 years 3.4 5.5 (85%), 5.44 (13%) 

Actinium-227 (Ac-227) 21.77 years 73 4.9 (0.5%, 4.95 (0.7%) 

Plutonium-238 (Pu-238) 87.7 years 17 5.5 (72%), 5.46 (28%) 

Plutonium-239 (Pu-239) 2.41 x 104 years 6.2 x 10-2 5.16 (88%), 5.11 (11%) 

Plutonium-240 (Pu-240) 6.54 x 103 years 2.3 x 10-1 5.17 (76%), 5.12 (24%) 

Plutonium-242 (Pu-242) 3.76 x 105 years 3.9 x 10-2 4.9 (76%), 4.86 (24%) 

Polonium-208 (Po-208) 2.90 years 5.9 x 102

 5.21 

Polonium-209 (Po-209) 102 years 17 4.88 

Polonium-210 (Po-210) 138 days 4.5 x 103

 5.31 

Protactinium-231 (Pa-231) 3.28 x 104 years 4.7 x 10-2 5.0 (79%), 4.73 (11%) 

Radium-223 (Ra-223) 11.4 days 5.1 x 104 5.71 (54%), 5.61 (26%), 5.75 (9%) 

Radium-224 (Ra-224) 3.66 days 1.6 x 105 5.68 (94%), 5.45 (6%) 

Radium-226 (Ra-226) 1.60 x 103

 years 1.0 4.78 (95%), 4.60 (6%) 

Radon-219 (Rn-219) 3.96 seconds 1.3 x 1010 6.82 (81%), 6.55 (11%), 6.42 (8%) 

Radon-220 (Rn-220) 55.6 seconds 9.2 x 108

 6.30 

Radon-222 (Rn-222) 3.82 days 1.5 x 105

 5.49 

Thorium-227 (Th-227) 18.7 days 3.1 x 104 6.04 (23%), 5.98 (24%), 5.76 (21%) 

Thorium-228 (Th-228) 1.91 years 8.3 x 102 5.43 (71%), 5.34 (28%) 

Thorium-230 (Th-230) 7.70 x 105 years 1.9 x 10-2 4.68 (76%), 4.62 (24%) 

Thorium-232 (Th-232) 1.4 x 1010 years 1.1 x 10-7 4.01 (76%), 3.95 (24%) 

Uranium-233 (U-233) 1.59 x 105 years 9.5 x 10-3 4.82 (83%), 4.78 (15%) 

Uranium-234 (U-234) 2.45 x 105 years 6.2 x 10-3 4.77 (72%), 4.72 (28%) 

Uranium-235 (U-235) 7.04 x 108 years 2.1 x 10-6 4.4 (57%), 4.37 (18%), 4.58 (8%) 

Uranium-238 (U-238) 4.47 x 109 years 3.4 x 10-7 4.20 (75%), 4.15 (25%) 

29 of 95 
SEC-00090 12-19-07 Mound Plant 

5.4.2 Beta 

Although Po-210 itself does not emit beta radiation, the Bi-209 slugs and their containers, irradiated in 

reactors to produce Po-210, contained trace quantities of several non-radioactive elements that became 

activated to produce radioactive contaminants. Handling these slugs in preparation for chemically 

separating the Po-210 was the primary source of potential beta dose at Mound. Table 5-4 lists the beta 

emitters of concern from the polonium production process. (ORAUT-TKBS-0016-6) 

Table 5-4: Beta Emitters Associated with Polonium Production at Mound 

Radionuclide Maximum Energy (MeV) Average Energy (MeV) 

Sc-46 0.357 0.112 

Zn-65 0.329 (β+) 0.143 

Hg-203 0.213 0.580 

Ag-110m 0.531 0.165 

Fe-59 1.565 0.615 

Co-60 0.317 0.096 

Bi-210 1.161 0.389 

Beta-emitting radionuclides were present in other Mound operations, but to a much lesser degree than 

in polonium production. The beta-emitting radionuclides in addition to those in Table 5-4 included 

members of the naturally-occurring naturally uranium, thorium, and actinium decay chains, Sr/Y-90, 

Cs-137, and Xe-131. (ORAUT-TKBS-0016-2; ORAUT-TKBS-0016-6) 

5.4.3 Neutron 

There were three neutron energy spectra at Mound. The principal sources of neutrons at Mound were 

polonium-based sources (primarily Po-Be sources) and plutonium-based α,n sources (primarily PuF4 

and PuO2) from the manufacture of radioisotope thermoelectric generators. A Pu-Be source has an 

average emission energy neutron between 4 and 4.5 MeV; whereas plutonium-based sources have an 

average emission energy of approximately 1.4 MeV. The third and less common neutron spectrum 

was a fission spectrum (maximum emission energy of about 2 MeV) from spontaneously-fissioning 

radionuclides (e.g., Cf-252) and critical assemblies. Neutrons in the workplace would be expected to 

include a continuous spectrum of energies below the maximum emission energies due to their 

interactions with different materials. Because moderation of neutron energy occurs through 

interactions with shielding, facility construction materials, and process equipment and materials, 

neutrons in the workplace are typically highly-scattered, albeit with a neutron component 

characteristic of the original source (Neutron, 2001). 

30 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

Table 5-5 summarizes the respective neutron energy categories used by EEOICPA in accordance with 

the External Dose Reconstruction Implementation Guideline (OCAS-IG-001) applied to Mound site 

workplaces by facility and operation. (ORAUT-TKBS-0016-6) 

Table 5-5: Neutron Energy by Facility and Operation 

Facility Operation Period IREP Energy 

Category (MeV) 

Percentage 

PP Building: 

Waste Handling area Th-232 storage and re-drumming 1955-1975 0.1 – 2.0 

2.0 - 20 

75 

25 

R Building: 

 R 117 Storage Vault 1949-1990 0.1 – 2.0 

2.0 - 20 

50 

50 

SW Building: 

SW 8 Xe isotope separation 1957-1960 0.1 – 2.0 

2.0 - 20 

50 

SW 11-14 & 16 (area 50

1B) 

Decon of BiSO4 

Pa-231 purification 

1951-1953 

1956 

SW 19 (Old Cave) Radium-actinium separation 1951-1953 

SW 140 (New Cave), 

132, 136, 137 

Processing residue from 

pitchblende production 

1970-1979 

SW 146-147 Metallurgy laboratory 1967-1985 

SW 219 Neutron source production 1962-1965 

T Building: 

All but T 43, 44, 48, 

50-51, 57-59, 348-359 

Po neutron source program 1949-1973 0.1 – 2.0 

2.0 - 20 

25 

75 

31 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

5.4.4 Photons 

Photon sources were present in almost all Mound facilities. Most Mound facilities had mixed fields of 

neutrons, beta, and photons. The beta field is a lesser concern for many Mound workplaces with 

respect to external radiation protection because the shielding around the glovebox or process shielding 

is thicker than the maximum beta range. The energy spectrum was dependent on the particular ongoing operation. Table 5-6 summarizes the respective IREP input photon energy category by facility 

and operation (ORAUT-TKBS-0016-6). 

Table 5-6: Photon Energy by Facility and Operation 

Facility Operation Period Energy (keV) Percentage 

HH Building: 

 HH 3, 4, 5, 8 Separation of He-3; Kr-85 1960-1995 30-250 

>250 

50 

 HH 5, 6 Pa-231/sludge separation 1955-1956 50

HH 8, 10-12 Hydrolysis of Al and Bi chlorides 1949-1958 

PP Building: 

Waste Handling area Th-232 storage and re-drumming 1955-1975 30-250 

>250 

75 

25 

R Building: 

 R-117 Storage Vault 1949-1990 30-250 

>250 

50 

50 

SW Building: 

SW 8 Xe isotope separation 1957-1960 30-250 

>250 

50 

SW 11-14 & 16 (area 50

1B) 

Decontamination of BiSO4 

Pa-231 purification 

1951-1953 

1956 

SW 19 (Old Cave) Radium-actinium separation 1951-1953 

SW 140 (New Cave), 

132, 136, 137 

Processing residue from 

pitchblende production 

1970-1979 

SW 146-147 Metallurgy laboratory 1967-1985 

SW 219 Neutron source production 1962-1965 

T Building: 

All but T43, 44, 48, 

50-51, 57-59, 348-359 

Po neutron source program 1949-1973 30-250 

>250 

50 

50 

H Building Hot laundry unknown 30-250 

>250 

25 

75 

WD Building: 

WD 1, 8, 101, 104 Wastewater treatment 1949-1990 30-250 

>250 

50 

WD 107 Ultra-filtration 1976-1981 50

WD 112, 113 Analytical work 1966-1979 

WD 113, 118 A&B Storage, waste incineration 1979-1994 

WD Penthouse Filter banks 1949-1993 

B Building Internal dose research 1950-1955 30-250 

>250 

25 

75 

32 of 95 
SEC-00090 12-19-07 Mound Plant 

5.4.5 Incidents 

Documentation of incidents is typically limited to reports of elevated urine activity or specific 

information describing the exposure scenarios. Based on information NIOSH reviewed, area access 

controls (e.g., designated/isolated work areas, gloves, vented fume hoods, and glove boxes), personnel 

protective equipment, and engineering controls were used to limit worker exposure. 

Incident reports are available through the Corrective Action Reporting System (CARS). The DOE 

also had an accident reporting system, known as the DOE Occurrence Reporting System (ORPS). An 

Energy Employee’s (EE’s) dose from an incident is expected to be included in the individual dose 

record provided by the site. If the EE (monitored or unmonitored) states that he/she was involved in 

an incident(s) in a telephone interview and there are no records in the claim file, an additional data 

request is made to Mound to attempt to verify the verbal information. 

6.0 Summary of Available Monitoring Data for the Proposed Class 

Radiation protection was a major concern at Mound from the beginning of operations. Initial Mound 

external and internal radiation monitoring and protection programs were implemented when work 

with radioactive materials was undertaken (Meyer, 1992). As at other DOE sites, advances in 

monitoring knowledge and assay skills led to monitoring improvements and expansion of the scope of 

Mound worker monitoring. 

The primary sources of monitoring data for this evaluation include the NIOSH Site Research Database 

(SRDB), the NIOSH OCAS Claims Tracking System (NOCTS), logbooks and forms located during 

data capture events at Mound, and three Mound databases. The Mound databases are designated as 

the Polonium Reconstruction (PORECON) database, the Plutonium Reconstruction (PURECON) 

database, and the Mound Environmental, Safety, and Health system (MESH). Two additional 

databases, the “Data Base of Excretion Data of Other Radionuclides” (ORAU 2003e) and the 

“Database of Ra-Ac-Th Excretion Data” (ORAU 2003d) have been compiled in part from nonplutonium data found in the PURECON database and from logbooks, cards, and forms reviewed 

during the Pre-1989 Dose Assessment Project. These latter two databases and the PURECON and 

PORECON databases contain only internal monitoring data. 

Additional data that are available include specific process information regarding Mound operations, 

including radionuclides and proportions in process systems for some years. These are currently 

available in the form of progress reports on research activities through 1951, in 1952 and 1953, and 

from late 1960 onward. Individual reports document specific processes, such as Bismuth Recovery 

Process, Engineering Research Final Report (Bismuth, 1952). 

Personnel dose monitoring data are also available in periodic health physics reports, which include 

summaries of external dose monitoring that state the number of dosimeters processed and the relative 

doses received. These data are not sufficient to assign individual doses, but do allow assignment of 

maximum doses when individual doses cannot be reconstructed more precisely based on other 

records. These data are available for the years 1948 to 1954; additional partial data are available for 

1955 through 1959. In this same category are complete records of air monitoring data for some 

buildings in some years (e.g., R and T Buildings in 1949). This information allows calculation of air 

33 of 95 
 

SEC-00090 12-19-07 Mound Plant 

concentrations in specific rooms, and overestimated internal doses may be calculated from these 

values when individual bioassay data are unavailable or unusable. Air concentration data are also 

summarized in periodic health physics reports. Though these are not useful for assigning individual 

doses, they do allow estimation of maximum doses. 

Some qualitative information in the reports is useful to ensure that health physics practices are 

modified to take changing source terms into account. Incidents and activities are also described. 

Quantitative data on the number of wipe surveys performed, the number of air samples taken, by area 

and room, support the correlation of air sample results with specific potential source terms. 

6.1 Mound Internal Monitoring Data 

Summaries of the available in vitro and in vivo data, as well as general overviews of sampling and 

analytical protocols, are provided in the following subsections. Additional details, including 

analytical methods, detectable activities, and reporting protocols can be found in the Mound 

Occupational Internal Dosimetry TBD (ORAUT-TKBS-0016-5) and in the History of Mound 

Bioassay Programs (Meyer, 1992). 

As noted in ORAUT-TKBS-0016-5, radionuclides were categorized by Mound staff as either primary 

or secondary based on the potential extent of use and the amount of bioassay data available. Primary 

radionuclides of concern are discussed in Mound internal dosimetry documentation, the History of 

Mound Bioassay Programs (Meyer, 1992), and Mound Site Radionuclides by Location (King, 1995). 

Primary radionuclides assessed for occupational internal exposure included: 

• Po-210 

• Plutonium Isotopes: Pu-238, Pu-239* 

• Tritium 

* Because Pu-240, Pu-241, and Pu-242 do not comprise a dosimetrically-significant proportion of the 

major plutonium source terms, NIOSH has chosen not to include these in its discussion. 

The above radionuclides were identified as primary because they were present in larger quantities and 

were more widespread at the site, often in multiple buildings and facility processes. Correspondingly, 

more monitoring data and site documentation are available (than for secondary radionuclides) to 

evaluate internal doses associated with these radionuclides. Primary on-site operations used all of 

these radionuclides in conducting key mission activities. 

Secondary radionuclides include those that were of limited use at the site or involved limited worker 

exposures. Often referred to as “other” radionuclides in Mound documents, they were part of smaller 

programs involving relatively few people. Many of the programs were relatively short-term research 

projects and brief production runs, and source material was received intermittently (MJW, 2002, 

Phase II, Appendix C). Fewer internal dosimetry data are available for these radionuclides than for 

the primary radionuclides. Available data for secondary radionuclides were collected from several 

sources during the Pre-1989 Dose Assessment Project and combined into two Excel spreadsheets: 

Database of Ra-Ac-Th Excretion Data (ORAU 2003d) and the Database for Other Radionuclides 

34 of 95 
SEC-00090 12-19-07 Mound Plant 

(ORAU 2003e). Data sources included logbooks, cards, and non-plutonium data extracted from the 

PURECON database. 

In addition to daughter products from the uranium and thorium decay chains, secondary radionuclides 

included: 

•	 Americium-241 • Radium Isotopes: Ra-228, Ra-226, 

•	 Curium-244 Ra-224, Ra-223 

•	 Uranium Isotopes: U-238, U-235, U-234, • Radon Isotopes: Rn-222, Rn-220, 

U-233 Rn-219 

•	 Thorium Isotopes: Th-232, Th-230, Th-228 • Protactinium-231 

•	 Actinium-227 

Mound also engaged in biomedical research using Calcium-45, Iron-59, Cobalt-60, Zinc-65 and other 

radionuclides. The quantities were minor compared to the primary and secondary radionuclides, and 

they were used in very few buildings for limited periods. Most of these radionuclides were present as 

sealed sources. Worker exposure was less likely, and bioassay data were not collected. 

Mound bioassay included primarily in vitro urine data and limited fecal sample results. In vitro urine 

data are the primary source of information to support dose reconstruction. Fecal analyses, in vivo 

chest counting, and air sampling information are considered of limited use due to limited availability 

(ORAUT-TKBS-0016-5). Additionally, these latter data are not kept in a central electronic database, 

but rather are maintained as hard-copy records, usually associated with an individual worker’s file. 

Fecal monitoring results from 1990 onward are available from MESH; 29 fecal results associated with 

eleven people sampled between 1966 and 1982 are in the PURECON database. Derived air 

concentration (DAC) data are available electronically from 2000 onward, but all other air monitoring 

data are on hardcopy. In vivo data are only available on hardcopy. 

Various bioassay programs were conducted at Mound from 1945 to the present using routine urine 

samples collected from workers (Meyer, 1992). Table 6-1 lists primary bioassay programs with 

reported radionuclide action levels for a urine sample in counts per minute, workers who were 

monitored, and frequency of monitoring. 

35 of 95 
 

SEC-00090 12-19-07 Mound Plant 

Table 6-1: Bioassay Programs and Action Levels 

Bioassay program Period Action levelsa Monitored workers Frequency 

In vitro monitoring 

Po-210 (Postum) recovery 1945-1974 10 cpm 50 ml-1 Operations personnel Weekly 24 hr to 

Monthly 

Ac-227, Ra-226, Th-228 1951-1960 8.3 cpm 24 hr-1 Research personnel Weekly 24 hr 

Th-232 sludge, re-drumming 1955-1975 2.8 cpm 24 hr-1 Th Refinery personnel Monthly 24 hr 

Th-230 (Ionium) research 1956-1959 3.5 cpm 24 hr-1 Research personnel Bi-Weekly 24 hr 

Pa-231 extraction 1956-1960 2.2 cpm 24 hr-1 Research personnel Monthly 24 hr 

U-233 research 1958-1960 20 cpm 1,500 ml-1 10 Research personnel Weekly 24 hr 

Tritium (hot gas) production 1957 to plant 

closure 10 μCi L-1 Recovery personnel Weekly Spots 

Weekly 24 hr 

Pu-239 neutron source 1957 to plant 

closure 3.5 cpm 24 hr-1 Processing personnel Weekly 24 hr to 

annually 

Pu-238 heat source 1960 to plant 

closure 3.5 cpm 24 hr-1 Processing personnel Weekly 24 hr to 

annually 

Am-241 & Am-243 1983 to plant 

closure 0.0 pCi/d b Potentially exposed personnel As needed 

Cm-244 1983 to plant 

closure 0.0 pCi/d b Potentially exposed personnel As needed 

In vivo monitoring 

Whole body counting 1960-1970 Not Available Operations personnel Annual 

Chest counting 1983 to plant 

closure Variablec Operations personnel Annual 

a. AL = action levels; observed counts per minute for 50 ml or 24-hour samples that result in a worker dose of 300 mrem/wk to the target organ. 

b. Smallest reported activity in database. 

c. Chest counting MDAs reported in the Mound TBD, Table 5-19 for Am, Pu, Th, and U isotopes. MDAs range from 0,1 nCi for Am-241 to 130 nCi 

for Pu-239. 

Routine bioassay monitoring included collection of spot and 24-hr urine samples, as identified in 

Table 6-1. For example, only those workers conducting research to separate and purify protactinium 

were monitored monthly for Pa-231. Twenty-four hour samples were also requested for Po-210 and 

the plutonium isotopes, typically as a follow-up to a potential intake. Monitoring frequencies were 

inferred from personnel sampling records. 

Individuals identified as being involved in an internal exposure incident, or who had urinalysis results 

in excess of the reporting limits, were required to submit additional 24-hr urine samples for analysis. 

Administrative personnel were not monitored and monitoring was discontinued for operational 

personnel if their work on a specific project was no longer needed. Operational personnel were 

monitored annually by whole-body or chest counting, or if there was a suspected exposure incident. 

Mound used the action levels in Table 6-1 to evaluate and control worker doses to a 300 mrem/week 

target organ dose limit. Results in excess of action levels triggered re-sampling and placement of the 

worker on the “hot roster” to control further exposures, if necessary. Typical dosimetry controls were 

in place by 1949 when Mound operations were moved from the Dayton facility. These controls 

followed the limits stated in the National Bureau of Standards Handbook 52 (NBS, 1953). 

36 of 95 
SEC-00090 12-19-07 Mound Plant 

Gross alpha analyses were conducted at Mound, and until 1980, activity was assigned to specific 

isotopes of plutonium and other alpha emitters based on sequential gross alpha counting or chemical 

separation followed by gross alpha counting. Alpha spectrometry capable of identifying specific 

alpha-emitting isotopes was not introduced until 1980. 

Individual radium bioassay samples were counted three times in a low-background proportional 

counter over a period of weeks. The individual radium isotope activities were then estimated by 

solving a system of simultaneous equations. This procedure requires equilibrium assumptions to 

properly infer activity associated with individual decay chain radionuclides. For example, sequential 

gross alpha counting was conducted on bioassay urine samples following radium extraction by coprecipitation to quantify Ra-223, Ra-224, and Ra-226 activity. Evaluation of alpha activity with 

decay time allowed the activities of individual radium isotopes to be estimated. 

6.1.1 Tritium Bioassay 

Tritium urinalysis for workers started in 1957. In 1958, an analytical method using a vibrating Reed 

Electrometer was officially adopted from a Savannah River Plant procedure and continued to be used 

into the early 1960s. Liquid scintillation counting began in 1961. Tritium results were always 

reported in units of activity per liter of urine. 

Available tritium data are contained within the MESH database. Data from 1957 through 1981 (over 

30,000 records) are in the form of annual dose summaries for workers. The remaining employee 

records (~ 250,000) span from 1981 through January 2006 and include bioassay results. 

6.1.2 Polonium-210 Bioassay 

All Mound employees working in polonium operations in T, HH, WD, H, B, and R Buildings were 

required to submit weekly spot urine samples (Meyer 1992). Samples were usually collected on 

Monday and Wednesday, or on Monday, Wednesday, and Friday. Po-210 bioassay data were 

documented on several different types of records at Mound (Meyer, 1992; Spitz, 1989). Weekly 

reports of urinalysis data were kept for workers; they were grouped by location with entries in cpm 

per specified volume and with 24-hr samples identified. Weekly results were transcribed onto 

Polonium Cards for individual workers with entries in cpm/50-ml unless otherwise stated. Twentyfour Hour Reports were also kept and used to convert individual 50-ml spot samples collected on a 

single day to a volume-weighted average 24-hr excretion in cpm. Finally, Special and Unscheduled 

Sample Forms were kept when any additional urine samples were required to document possible 

worker exposures, or to confirm previous results, with all entries in cpm and duplicate sampling 

indicated. 

Bioassay data for Po-210 have been placed in the PORECON database by MJW by evaluating 

individual dosimetry files from original logbooks and data cards during their work on the Pre-1989 

Dose Assessment Project (MJW, 2002, Phase I; MJW, 2002, Phase II). This database contains 

207,750 individual sample results spanning from 1944 to 1973. Bioassay results are reported as Bq/d, 

cpm, and dpm in this database. 

37 of 95 
 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

A summary of the number of records/year applicable to the proposed class time frame is presented in 

Table 6-2. 

Table 6-2: PORECON Polonium Record Summary 

Year 1949 1950 1951 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 

Records 16,550 18,064 17,332 18,360 10,957 2,638 1,787 1,752 2,309 2,754 3,219 5,124 6,472 

Year 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 

Records 7,743 7,890 8,343 7,090 6,659 7,526 6,444 3,194 1,043 353 74 31 

6.1.3 Plutonium-238 and Plutonium-239 

Bioassay of the plutonium isotopes at Mound underwent considerable change and improvement with 

the development of specific methodologies to isolate and count Pu-238 and Pu-239. The various 

methodologies are discussed in the Mound Occupational Internal Dosimetry TBD (ORAUT-TKBS0016-5); however the major features of the internal dose monitoring program for plutonium are 

summarized in Table 6-3 below. 

Table 6-3: Summary of Historical Plutonium Analytical Procedures 

Period Reporting levela

 Analytical method 

1954–1960 (Kirby, 1954) 

0.05 dpm 1.5 L-1 

0.5 dpm 1.5 L-1(Corrected 

DL)b 

Alkaline earth phosphate co-precipitation; plutonium separation with 

cerium carrier; gross alpha for plutonium; proportional counting; 

recoveries 6-85% due to colloidal plating of metabolized Pu. 

1961–1967 (Kirby, 1954) 

0.1 dpm 1.5 L-1 

Sample acidification; alkaline earth phosphate co-precipitation; 

plutonium separation with cerium carrier; gross alpha for plutonium; 

proportional counting; recoveries 90 ± 3%. Uranium and plutonium 

results reported separately only in 1966 using anion exchange 

methods. 

1968–1977 MD-20736 (Mound 1963) 

0.1 dpm 1.5 L-1 

Alkaline earth phosphate co-precipitation; plutonium separation with 

cerium carrier; anion exchange; electro-deposition; gross alpha 

reported for plutonium; proportional counting. 

1978–1979 MD-80030 (Mound 1981) 

0.1 dpm 1.5 L-1 

Alkaline earth phosphate co-precipitation; plutonium separation with 

cerium carrier; anion exchange; electro-deposition; alpha 

spectroscopy for Pu-238 and Pu-239/240; Pu-242 tracer. 

1980–present MD-80030 (Mound 1981) 

0.07 dpm 1.5 L-1 for routine 

samples 

Alpha spectroscopy for Pu-238 and Pu-239/240; anion exchange; 

Pu-242 tracer; blanks counted for decision level determination. 

a. The 24-hr reporting levels are based on a standard sample volume of 1.5 L. Standard man in ICRP Publication 2 (ICRP, 1959) and 

Reference Man in ICRP Publication 23 (ICRP, 1975) both have a urine volume of 1.4 L. Actual collected urine volumes will vary. 

b. Detection limit was corrected for a low chemical recovery of 10% due to colloidal plating of plutonium. 

38 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

Plutonium data are now readily available from the PURECON database. The PURECON database 

was established in 1991 by work performed by the University of Lowell Research Foundation. This 

work was undertaken to meet the requirements of DOE Order 5480.11, Radiation Protection for 

Occupational Workers (DOE, 1988), which became effective on January 1, 1989. In brief, Mound 

staff recognized that it needed to develop more reliable internal dosimetry record-keeping for 

plutonium; this resulted in the construction of a computer database from the original raw data. 

Subsequent QA/QC and repair work on the PURECON database has been performed (and 

documented) by MJW during its work on the Pre-1989 Dose Assessment Project (MJW 2002, Phase I; 

MJW, 2002, Phase II). 

A summary of the number of records/year applicable to the proposed class time frame is presented in 

Table 6-4. 

Table 6-4: PURECON Plutonium Record Summary 

Year 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 

Records 78 95 81 98 343 808 1,454 2,267 2,797 3,632 11 3,718 

Year 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 

Records 3,299 2,699 2,642 2,384 2,804 2,312 2,093 1,573 1,160 1,322 1,365 1,238 

Year 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 

Records 1,227 1,250 1,276 1,380 1,388 1,422 1,318 939 926 1,112 1,562 1 

6.1.4 Radon Isotopes 

Sources of radon (Rn-222), thoron (Rn-220), and actinon (Rn-219) were present at Mound due to 

radium and thorium processing and separation of Pa-231 and Ac-227. Thorium sludge from Th-232 

extraction and purification operations was stored outside in drums from 1954 to 1966. In 1966, 

thorium sludge stored in individual drums was transferred to storage basins in Building 21. The 

thorium was re-drummed and removed from Mound in 1974 and 1975. In 1975, 1,258 drums of 

Cotter Concentrate were stored to support purification of Pa-231 and Th-230. Table 6-5 shows the 

results of various radon surveys at Mound. 

39 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

Table 6-5: Radon Isotope Survey Data by Building and Period 

Building 

Survey 

dates 

Gas concentration (pCi/l) 

WL 

WLM yr-1 

(a) Radon Thoron Actinon 

SW Tunnel 10/12/79 88,000 28,000 640,000 

SW19 before vent 6/79-10/79 67-160 

SW19 after vent 3/80-4/80 7.7-13.4 0.03 0.4 

12/89 2.6 Not 

Detected 

12/99 1.0-5.8b 

4/00 0.7-7.2 

1998-2000 5.8-12

SW21 5/83 17.5-52.8 

12/89 34-118 0.3-0.7 0.4-1.3 

0.85 

median 

4.7-15.3 

4/90-6/90 117-161 10.0 median 

125 

SW22 6/90 125 

SW48 12/89 3.2 

Old SD 12/89 1.5-2.4 

Fire station 12/89 1.2-1.4 

Paint shop 12/89 0.9-1.2 

A 10/88-2/89 0.1-1.1 

All other buildings 12/89 4 0.4-0.9 

Outside facilities 5/83 0.24-0.59 

Reported background 0.1 to 2.1 

Average = 0.5 

a. Working level months per year (WLM yr-1) were determined as WL (2000 hr yr-1) (1/ 170 hr WLM-1). 

b. Bolded concentrations were derived from charcoal canister measurements. 

The following radionuclide-specific program and internal data availability information was initially 

collected during work performed for the Pre-1989 Dose Reconstruction Project. Unless noted 

otherwise, the source first summarizing the information presented below is the “Other” Radionuclides 

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

data for the following radionuclides have been compiled into Excel spreadsheets titled Database of 

Excretion Data of Other Radionuclides (ORAU 2003d) and the Database of Ra-Ac-Th Excretion Data 

(ORAU 2003e). 

6.1.5 Protactinium-231 

Programs involving the recovery and purification of Pa-231 began in the early 1950s and continued 

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

and used a Mallinckrodt raffinate known as “Sperry Cake” as a feed material. Later efforts to recover 

Pa-231 used another type of residue from the uranium refining process called Cotter Cake. This 

material had been identified as a useful source of radionuclides during research associated with the 

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

during 1975 for processing in the pilot plant built in the SW building. This plant ran from 1974 to 

1979, during which 22 drums were processed to recover 339 g of Th-230 and 890 mg of protactinium. 

40 of 95 
 

SEC-00090 12-19-07 Mound Plant 

The bioassay program to support the recovery/purification process of protactinium began in August 

1955 (Meyer, 1992). The samples were subjected to various precipitation and dissolution procedures 

to extract radium, thorium and protactinium fractions (Kirby, 1952; Kirby, 1954; Kirby, 1959). The 

available protactinium data were found in a historical file within a notebook during the Pre-1989 Dose 

Reconstruction Project and are now compiled in the Data Base of Excretion Data of Other 

Radionuclides (ORAU 2003e). 

6.1.6 Thorium-230 

The bioassay program for Th-230 ran from March 1956 through September 1958. Initially, 24-hour 

urine samples were collected, thorium separation was performed, and the thorium fraction was 

analyzed. It appears that this process did not provide the desired results and, after about 10 samples 

(about mid-May 1956), the procedure was changed to a “radium separation.” It was most likely 

assumed that Ra-226 was in equilibrium with its parent Th-230; thus, all counts would be considered 

ionium counts. 

Primary Th-230 bioassay records consisted of a log book and duplicate records in a brown notebook 

(ORAUT-TKBS-0016-5). Secondary Th-230 results included a form (Form 0-634) and then began as 

weekly reports on March 17, 1958. Weekly reports included Name, Isotope, and Result. Results 

reported on Form O-634 included: Name, Badge Number, Date, Type of Analysis, Isotope, and Result 

(MJW, 2002, Phase I). The Database of Ra-Ac-Th Excretion Data now serves as the repository for 

these data (ORAU, 2003d). 

6.1.7 Thorium-232 

The Thorium-232 Refining Program was a process intended to produce thorium salts. These salts 

were to be produced in a newly-constructed refinery and used to produce metallic thorium for the 

thorium fuel cycle of the breeder reactor. The research and development for the refining process, 

known as the Monex Process, was done in the R Building. The directive to construct the required 

refinery was issued in March 1955, but construction was canceled in May of the same year. Research 

work on the pilot plant continued and was completed in July 1955. 

Although a small number of samples were processed between 1951 and 1954, the primary urinalysis 

sampling to support Th-232 refining and subsequent re-drumming of source materials began in 

August 1955 and continued until November 1959. 

Approximately 170 samples are available for Th-232 in the years between 1960 and 1967. A total of 

25 samples are available from the years 1972, 1978, and 1979 (combined). Bioassay records indicate 

that urine samples from persons involved in the Thorium-232 Program were analyzed for both radium 

and thorium. The thorium is assumed to be Th-232, Th-228, and Th-230. 

41 of 95 
SEC-00090 12-19-07 Mound Plant 

6.1.8 Substitute Materials, Radium-226, Actinium-227, and Thorium-228 Records 

As part of the Substitute Materials Program, a search was undertaken for other alpha-emitting isotopes 

with neutron-generating efficiency comparable to Po-210. Ac-227 was selected as a possible 

replacement for Po-210 for initiator production. This program involved the separation of Ac-227 from 

neutron-irradiated Ra-226. 

Between June and October 1954, almost 48 g of radium had been processed and canned. This work 

resulted in 47.5 Ci of Ra-226, 14.9 Ci of Ac-227, and 24.6 Ci of Th-228 being purified by the end of 

the year. 

Urine analysis techniques were developed to support the processing of neutron-irradiated Ra-226 in 

the SW Building. According to the History of Mound Bioassay Programs (Meyer, 1992), preliminary 

work for analyzing urine samples containing Ra-226, Ac-227, and Th-228 was completed in 1952. A 

few urine samples were analyzed in 1951 and 1952 as part of the research work for the program. 

Several cases of personnel exposure were detected by routine urinalysis in December 1952. Results of 

these 1952 samples do not appear to be in any logbooks, nor could data sheets be found. At the time, 

urine samples were being analyzed by a simple procedure for radium only. 

Differential decay analyses indicated that in addition to the radium, varying amounts of actinium and 

thorium were present in the samples; therefore, a new procedure was developed to determine their 

respective activities. To accomplish this, thorium and radium were chemically separated from the 

urine samples and the radium fraction was counted for total activity. Ra-223 is a decay product of Ac227 via Fr-223 (1%) and Th-227 (99%). Ra-224 is a decay product of Th-228. Ra-223 and Ra-224 

have short half-lives so they grow in relatively rapidly. Decay and in-growth curves were plotted and 

activities calculated using these curves. Samples were counted periodically for several weeks and 

simultaneous equations were then used to determine the activity of Ra-226, Ra-223, and Ra-224. The 

quantity of Ac-227 and Th-228 could then be inferred from the results. 

According to the History of Mound Bioassay Programs (Meyer, 1992), sixteen people are listed as 

having participated in the program. However, a compilation of data during the Pre-1989 Dose 

Assessment Project shows approximately 120 people as having submitted urine samples for radium 

analysis. The last routine sample was processed in February 1959 when decontamination of the Cave 

Area was completed. A few more samples were analyzed between 1963 and 1967. 

6.1.9 Uranium Records 

Several isotopes of uranium have been used at various times throughout the history of Mound. The 

largest uranium program appears to have involved about ten people in limited research on U-233 

during 1958 and 1959. This was most likely a part of the reactor fuels program. Urine sampling for 

this program began in July 1958 and ended July 1959. Over 130 bioassay results are available for this 

time period. 

From 1962 to 1972, another program produced U-234 by chemically separating it from aged Pu-238 

(Meyer, 1992). About 10 grams (6.2E-02 Ci) were produced annually; the U-234 that was produced 

was shipped as the oxide. There was no indication of a specific bioassay program associated with this 

work. 

42 of 95 
SEC-00090 12-19-07 Mound Plant 

There was also a program involving U-233 beginning in 1966 and continuing into the mid-1970s 

(Meyer, 1992). In this program, 1.5 kg of aged U-233 were processed to obtain 30 mg of Th-229. 

However, the Annual Overview section of the Meyer document only indicates a bioassay program for 

uranium through 1966. Available uranium bioassay records are limited to 44 bioassay results from 

1965-1966. Of these, five were specifically labeled as U-233 results. 

A gross alpha procedure was used for analyzing the uranium content of spot urine samples. The 

majority of available uranium urine sample results do not indicate which isotope of uranium was 

suspected to be present. Spot samples were used for screening; 24-hour samples were collected when 

a more precise or definitive result was needed. An anion exchange procedure was used on the later 

samples. 

6.1.10 Americium-241 and Curium-244 

Documentation for Am-241 and Cm-244 is very limited. Primary records for Am-241 and Cm-244 are 

unknown. The available data were first discovered in (and extracted from) the PURECON database 

during the Pre-1989 Dose Assessment Project (MJW, 2002, Phase II). Seven bioassay results are 

available for Am-241 for one person in 1987. Thirty-eight Cm-244 results are available for six 

workers in 1983, and two results for an individual in 1986. All Am-241 and Cm-244 urinalysis data 

are in units of activity (pCi). The MJW Report (MJW, 2002, Phase II) assumed that Am-241 and Cm244 data in Mound dosimetry records are in units of activity excreted per 24-hour period. From 

currently available records, it is unclear in which programs the monitored people were involved. 

6.2 Mound External Monitoring Data 

The following discussion provides a summary of the Mound site external dosimetry program as well 

as the types, quantity, and quality of data that can be used for external dose reconstruction. Details 

regarding the dosimeters used are presented in ORAUT-TKBS-0016-6. Additional information 

regarding the external dosimetry equipment, methodologies, and techniques in use during most of the 

proposed class time period is provided in the History of Personnel External Dosimetry Program at the 

Dayton Project and Mound Laboratory 1946-1993 (Meyer, 1994). 

In 1948, as initial operations were being planned for the newly-established Mound Laboratory, 

Mound’s health physicists, employed by the Monsanto Chemical Company, consulted with their 

counterparts at the Oak Ridge National Laboratory concerning external dosimetry techniques that 

would be appropriate for continuing the Po-210 production operations previously conducted at 

locations in the Dayton area. A continuous external dose monitoring program began. This program 

developed policies and made programmatic corrections as necessary. Mound used a film badge 

external dosimetry monitoring system from 1946 to 1977. From 1977 to the present, Mound has used 

a TLD system. Records of radiation exposures from personnel dosimeters worn by workers and coworkers are available for all years of the proposed class time period. The MESH database serves as 

the primary electronic repository of these records. It contains all radiation doses measured for Mound 

employees from 1947 to 2005. Periodic health physics reports contain summaries of the number of 

dosimeters read for each period, and the number of results in each of several dose ranges. When 

individual doses cannot be reconstructed more precisely, maximum doses can be based on these 

reported results. 

43 of 95 
SEC-00090 12-19-07 Mound Plant 

Individual dosimeter cycle results are not complete in that, at the end of 1977, the Mound dosimetry 

group was unable to recover any individual monitoring data for the previous years from the 

mainframe computer. A summary report was generated of the annual recorded doses of all monitored 

employees from 1947 through 1977 (Guido, 2003; Meyer, 1994, Volume III, 1973 Appendix 3, 

pp. 207-211). Individual dosimeter results survive in some employee claimant files for employees 

with early termination dates (before about 1960). Discovery efforts are on-going to retrieve the 

balance of individual employee cycle data. 

Positive photon doses are present in the records for many workers from the beginning of Mound site 

operations, and neutron doses were first recorded in 1949. 

Recorded beta doses are uncommon in Mound site records until approximately 1960. Data from 

Dayton Units III and IV did include some beta measurements. Photon exposures were based on the 

optical density of the monitoring film behind a shield (e.g., brass, Cd, Te, Ta) sufficient to block 

low-energy radiation, including beta particles; the optical density of the ‘unshielded’ or ‘openwindow’ portion of the film could be used to estimate beta doses. However, early beta doses were not 

read and are not a part of employee records until at least January 1960 (Meyer, 1994, Volume I, p. 

164). The reason for this lack of data is that beta dose rates were likely low in the T Building, which 

was specifically designed to isolate the process solutions. On December 1, 1965, technicians began to 

read the open-window portion of the film as well as the area behind the shield (and the sensitive and 

insensitive films as well) as part of the calibration procedure. The purpose of the additional 

measurements was to permit better evaluation of low-energy gamma photons (Meyer, 1994, Volume I, 

p. 310). Evaluation of the MESH database for beta results generally supports Meyer’s report of beta 

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

not noted until 1968. 

Table 6-6 presents a summary of the available external monitoring records. To obtain a count of the 

minimum number of records believed to be beta-only measurements, the database was queried for the 

number of beta results that were greater than the recorded deep dose. This resultant yearly count has 

been included in Table 6-6. 

44 of 95 
SEC-00090 12-19-07 Mound Plant 

Table 6-6: Summary of External Monitoring Data in the MESH Database 

(Table 6-6 spans two pages) 

Year Number of Workers 

Monitored 

Number of Records 

Availablea 

Number of Beta 

Recordsb 

1949 620 620 1 

1950 630 630 0 

1951 669 669 0 

1952 654 654 0 

1953 579 579 0 

1954 321 321 0 

1955 209 209 0 

1956 168 168 0 

1957 203 203 0 

1958 302 302 0 

1959 384 384 0 

1960 502 502 0 

1961 608 608 1 

1962 663 663 1 

1963 751 751 1 

1964 993 993 1 

1965 1036 1036 5 

1966 1323 1323 2 

1967 1397 1397 2 

1968 1436 1436 423 

1969 1485 1485 554 

1970 1506 1506 1208 

1971 1396 1396 835 

1972 1412 1412 219 

1973 1410 1410 142 

1974 1331 1331 866 

1975 1539 1539 1075 

1976 1059 1059 755 

1977 1306 2452 1464 

1978 1324 8757 1978 

1979 1464 8889 1717 

1980 1600 9355 1324 

1981 1792 10099 1376 

1982 1987 9244 1373 

1983 2300 9403 2018 

1984 3315 10955 5718 

1985 3508 10996 6362 

1986 3309 12421 4889 

1987 3957 14504 5083 

1988 4638 16382 5000 

45 of 95 
 

 

SEC-00090 12-19-07 Mound Plant 

Table 6-6: Summary of External Monitoring Data in the MESH Database 

(Table 6-6 spans two pages) 

Year Number of Workers 

Monitored 

Number of Records 

Availablea 

Number of Beta 

Recordsb 

1989 4386 15769 386 

1990 4191 14947 127 

1991 4227 13151 166 

1992 5036 12958 42 

1993 7589 24374 24 

1994 6294 17571 18 

1995 2246 6182 22 

1996 1325 4478 133 

1997 1056 3488 125 

1998 947 3112 32 

1999 1017 3617 84 

2000 978 3117 7 

2001 846 2617 12 

2002 781 2419 29 

2003 603 898 0 

2004 70 158 3 

2005 58 114 0 

a Prior to 1977, only individual annual summaries are available; therefore, the number of records equals the number 

of employees. After 1977, dosimeter readings are available. Records typically include both photon and neutron 

measurement results. 

b	 The number of beta records represents the number of results where the beta dose is greater than the recorded deep 

dose for a given dosimeter. 

46 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

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

Table 6-7: Mound Dosimeter Use and Assignment Policies 

Date Photon dosimetry 

February 21, 1949 Operations began in T Building. Film badges, one sensitive and one insensitive film, with 1-mm 

cadmium filter read weekly and two pocket ion chambers read daily. Beta window not read. 

December 1951 Film badges read every 2 weeks. 

May 1966 Use of pocket ion chambers discontinued. 

September 1968 New dosimeters with security credential. Based on Nevada Test Site badges but with different 

filters. Modified later with TLD photon dosimeters plus Nevada Test Site neutron dose film. In 

1977, questions were raised about low-energy photon dose underestimates with tantalum shields. 

1972 Routine extremity dosimetry began. 

December 1977 All-TLD dosimeters introduced. 

October 1986 New soft-pack dosimeters. 

June 1991 New hard-pack dosimeters with neutron track etch capability. 

June 1993 Added neutron track etch capability for future use. 

September 1949 NTA track etch film for fast neutrons first used in T and R Buildings. Read 10 fields at 980 power 

magnification and averaged readings. 

September 1956 Began reading 10 fields at 430-power magnification with projection microscope and averaged 

values. 

December 2, 1957 Returned to using 980-power projection microscope to read NTA film. 

January 21, 1963 Began routine monitoring of night maintenance staff in Building P. 

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

October 1964 Began using new projection microscope with better light. 

March 1966 Began badging all hourly Engineering Department staff members who spent a portion of their time 

in radiation control areas of plant. 

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

August 1, 1968 Exchange frequency for Buildings R and SW personnel changed to 4 weeks. 

Nov./Dec. 1977 All-TLD dosimeters introduced. Began using TLDs for neutron exposure monitoring. 

October 1986 New soft-pack dosimeters. 

June 1991 New hard-pack dosimeters with neutron track etch capability. 

June 1993 Added neutron track etch capability for future use. 

Table 6-8 below summarizes the beta-photon dosimeter types, exchange frequencies, and types of 

workers who were monitored. 

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

who were monitored. 

47 of 95 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

Table 6-8: Beta-Photon Dosimeter Types and Exchange Frequency 

Period Dosimeter type 

Dosimeter 

holder 

Exchange 

frequency Comments 

2/1949–11/1951 DuPont D552 Oak Ridge/steel Weekly All radiation workers 

12/1951–1957 DuPont D552 Oak Ridge/steel Biweekly All radiation workers 

1957–1960 DuPont (model unknown) Oak Ridge/steel Biweekly All radiation workers 

1961–1962 DuPont 558 Oak Ridge/steel Biweekly All radiation workers 

1963–1968 DuPont D556 Oak Ridge/steel Weekly Some radiation workers 

Biweekly Most radiation workers 

Monthly General area workers 

1968–1969 DuPont D556 Oak Ridge/steel Biweekly Dependent on work area 

Monthly 

Quarterly 

1970–1977 Kodak Type 3 Mound holder Biweekly Dependent on work area 

Monthly 

Quarterly 

1977–1986 Harshaw 8810 TLD-700 Cycolac Biweekly Dependent on work area 

Monthly 

Quarterly 

1986–1987 Harshaw 8810 TLD-700 Cycolac Monthly Dependent on work area 

Quarterly 

1987–1991 Harshaw 8810 TLD-700 Cycolac Monthly All employees monitored 

Quarterly 

1991–site closure Harshaw 8801 TLD-700 Cycolac Monthly Dependent on work area 

Quarterly 

Table 6-9: Neutron Dosimeter Types and Exchange Frequency 

Period Dosimeter type 

Dosimeter 

holder 

Exchange 

frequency Comment 

1949–8/1951 Kodak NTA Oak Ridge/steel Weekly All radiation workers 

8/1951–1957 Kodak NTA Oak Ridge/steel Biweekly All radiation workers 

1957–1960 Kodak NTA Oak Ridge/steel Biweekly All radiation workers 

1961–1962 Kodak NTA Oak Ridge/steel Biweekly All radiation workers 

1963–1968 Kodak NTA Oak Ridge/steel Weekly Some radiation workers 

Biweekly Most radiation workers 

Monthly General area workers 

1968–1977 Kodak NTA Mound holder Weekly Dependent on work area 

Biweekly 

Quarterly 

1977–1986 Harshaw TLD-600 TLD-700 Cycolac Weekly Dependent on work area 

Biweekly 

Quarterly 

1986–1987 Harshaw TLD-600 TLD-700 Cycolac Monthly Dependent on work area 

Quarterly 

1987–1991 Harshaw TLD-600 TLD-700 Cycolac Monthly Dependent on work area 

Quarterly 

1991–2003 Harshaw TLD-600 TLD-700 Cycolac Monthly Dependent on work area 

Quarterly 

48 of 95 
SEC-00090 12-19-07 Mound Plant 

Early Mound site neutron dosimeter results were more accurately measured using NTA film than the 

spectra present at most AEC sites, due to the higher-energy spectrum associated with Po-Be sources. 

For this reason, Mound neutron doses can be based substantially upon measured doses even in the 

NTA film era. Periodic health physics reports demonstrate that not all workers were monitored for 

neutron doses; however, neutron dosimeters were required for work in those areas with significant 

neutron dose rates. For this reason, those workers with the highest potential neutron doses are 

assumed to have been monitored, which provides a sufficient basis for estimation of a maximum 

neutron dose for others workers. 

6.3 Mound Air Sampling Data 

Mound health physics program records include a number of air samples for alpha- and beta-emitters. 

Typically, such data are of limited use in dose reconstruction due to the great uncertainties associated 

with the doses estimated based on measured air concentrations. When possible, dose reconstructions 

are usually performed based on data related to a specific claim (including bioassay data), which 

provides a much more direct assessment of the uptake of a given radionuclide and the resulting organ 

dose. Air concentration measurements are used to assign internal doses from radioactive material in 

the general environment, in accordance with the Mound Occupational Environmental Dose TBD, 

(ORAUT-TKBS-0016-4). 

Measured air concentrations are useful for estimating maximum doses when bioassay data are 

unavailable. Performance of routine air monitoring was a feature of the Mound health physics 

program since the beginning of Mound operations. Air sample results are available in at least 

summary form for the years 1949 through 1954. This information will be integrated into the revision 

of the Mound Occupational Internal Dosimetry TBD. In some cases, this information will be used to 

bound doses for unmonitored internal exposures, as described in Section 7.0 of this report. 

7.0 Feasibility of Dose Reconstruction for the Proposed Class 

The feasibility determination for the proposed class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must 

establish whether or not it has access to sufficient information either to estimate the maximum 

radiation dose for every type of cancer for which radiation doses are reconstructed that could have 

been incurred under plausible circumstances by any member of the class, or to estimate the radiation 

doses to members of the class more precisely than a maximum dose estimate. If NIOSH has access to 

sufficient information for either case, NIOSH would then determine that it would be feasible to 

conduct dose reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class (discussed in Section 9.0 of this report). If the conclusion is one of 

infeasibility, NIOSH systematically evaluates the sufficiency of different types of monitoring data, 

process and source or source term data, which together or individually might assure that NIOSH can 

estimate either the maximum doses that members of the class might have incurred, or more precise 

quantities that reflect the variability of exposures experienced by groups or individual members of the 

49 of 95 
SEC-00090 12-19-07 Mound Plant 

class as summarized in Section 3.0. This approach is discussed in OCAS’s SEC Petition Evaluation 

Internal Procedures which are available at http://www.cdc.gov/niosh/ocas. 

The next four major subsections of this Evaluation Report examine: 

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00090 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Mound Data 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

Since its inception, all Mound radiation monitoring procedures and record-keeping were carried out to 

comply with Federal radiation protection regulations. Each employee’s accumulated radiation 

exposure, as measured on a continuing basis by various radiation detection dosimeter and assays, was 

entered into personal radiation records for permanent documentation. 

Monitoring record-handling and storage has varied over time, and with changing operators. As 

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

external and internal data. Individual workers’ files have been diligently maintained. 

In 1993, the DOE decided to close the Mound Plant pursuant to the DOE Weapons Complex 

Reconfiguration Program. This was an effort to realign the weapons complex into a smaller, less 

expensive operation. The focus during the realignment was to maintain the enduring stockpile while 

retaining necessary resources and sustaining weapons production competency. Records generated in 

support of past missions were transferred to various receiver sites, or dispositioned per the National 

Archives and Records Administration (NARA)-approved retention schedules. Receiver sites include 

the Kansas City Plant, Savannah River Site, Los Alamos National Laboratory, Sandia National 

Laboratory, associated DOE Operations and Field Offices, the DOE Historian's Office, and the Office 

of Scientific and Technical Information (OSTI). Transfers of documentary materials also required 

transfer of document ownership and maintenance responsibilities in order to preserve the existing 

information assets of the weapons production complex. Details of these records transfers are provided 

in Mound Records Transfer History (Long, 2007). In addition, a description of Mound records 

disposition to LANL (a petition basis) is included in Section 7.4.1.7. 

DOE has completed environmental remediation and restoration of all but one Operable Unit at the 

site. In May 2006, responsibility for managing Mound records was transferred to the Stoller 

Corporation/Source One Management contracting team, with oversight by the DOE Office of Legacy 

Management (DOE/LM). 

50 of 95 
SEC-00090 12-19-07 Mound Plant 

Upon request (and as applicable), the Stoller Corporation/Source One Management contracting team 

provides employees’ original hardcopy records in addition to database printouts (prior to 1958), which 

ensures the ability to confirm data. These hardcopy records are in the form of various preprinted 

forms, cards, or reports (depending on what was in use at the time). Per Dose Reconstruction 

Training, ORAUT-TRNG-0051, when performing dose reconstructions, personnel performing dose 

compare available hard copy data with database printouts. 

The history and general quality of available Mound monitoring record data sets are summarized in 

following subsections. Dosimeter performance, bioassay procedures, and the QA/QC procedures 

associated with various monitoring campaigns were quite extensive at Mound and have been 

described in several documents. The ORAUT internal and external TBDs (ORAUT-TKBS-0016-5, 

ORAUT-TKBS-0016-6) provide some details. Extensive details of procedures and their evolution are 

contained within Meyer’s external monitoring and bioassay history documents (Meyer, 1992; Meyer, 

1994). 

7.1.1 Internal Monitoring Data Review 

Unless otherwise noted, the following characterizations of Mound internal data have been taken from 

three documents describing work performed for the Pre-1989 Dose Assessment Project (MJW, 1998; 

MJW, 2002, Phase I; MJW, 2002, Phase II). Internal monitoring data collection and assessment was a 

primary goal of Phase I of that project. Below is a summary of more detailed information available in 

the documents referenced above. 

Plutonium Bioassay Data 

The PURECON database was established in 1991 by the University of Lowell Research Foundation. 

This work was undertaken to meet the requirements of DOE Order 5480.11, Radiation Protection for 

Occupational Workers (DOE, 1988), which became effective January 1, 1989. A document entitled 

Plutonium Historical Dose Reconstruction Program provided the historical backdrop for this effort 

(Meyer and Reeder, 1992). In brief, Mound staff recognized that it needed to develop more reliable 

internal dosimetry record-keeping with respect to plutonium, which resulted in building the computer 

database from the original raw data. 

As noted above, QA/QC and repair work has been performed on the PURECON database by MJW 

during its work on the Pre-1989 Dose Assessment Project (MJW, 2002, Phase I; MJW, 2002, Phase 

II). During its initial assessment of the existing database (5% check), MJW noted that for all 

PURECON records checked for errors of all types, there was an 8.2 % error rate was observed. This 

was considered unacceptable because some of these errors dealt with misidentification of bioassay 

data that could directly affect the results of the MJW dose screening program. Details of these checks 

are provided in the Phase I Report, Volume I, Appendix II-2 (MJW, 2002, Phase I). 

Also provided in Volume II, Appendix A, Subpart 2 of the Phase I Report, is a memo submitted to 

Mound in September 1997 with recommendations regarding assessment and repair of the entire 

PURECON (and tritium) databases. The recommendations were approved and a description of the 

work performed is discussed in Section II(C)(1) of Volume I. In essence, a test plan was devised that 

allowed continued testing of the PURECON database against a predefined set of test conditions 

(derived from a proposed Pu-screening algorithm) until a zero error condition was returned. 

51 of 95 
SEC-00090 12-19-07 Mound Plant 

Questionable results were all checked against original logbook entries. All database alterations 

identified by the test plan implementation were documented on Form TPOOl-I, MESH Record 

Quality Assurance Form. 

In July 1999, approximately 350 (8 1⁄2” by 11”) “KARDEX” cards were discovered among the 

miscellaneous bioassay records in the Mound Occupational Radiological Exposure (MORE) records 

cabinets. The existence of these data was mentioned in the Meyer bioassay history document (Meyer, 

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

noted that the KARDEX data were the correct results and should replace any logbook data entered for 

that time period. Analysis of this new information showed that the KARDEX data took into account 

background that the logbook entries for the same period did not. 

The approximately 2300 data points for 238 individuals for the time period 1960-62 were entered into 

an Excel spreadsheet, and the pCi value for a 24-hour sample was calculated. This information was 

then printed out for each individual and placed, along with a copy of the original KARDEX data, in 

the identified individual’s Phase II data packet. In addition, the database was updated to include all 

new KARDEX data. 

In general, the KARDEX data were calculated to be 0.1 to 0.2 pCi lower than the data in the 

PURECON database for the period 1960 through 1962. In several cases, existing PURECON data 

that were >MDA were calculated using the new KARDEX data to be <MDA. The net effect of 

updating the PURECON database with the KARDEX data has been to take into account background 

data for the period of 1960 to 1962, thus lowering the net result. Comparison of the PURECON 

database with the KARDEX data for 1962 showed that the majority of results in PURECON had been 

entered correctly. 

As detailed in the Pre-1989 Dose Assessment Project Phase I Final Report (Volume I), the 

PURECON database for Pu was thoroughly reviewed for errors. A complete QA review of the 

database was required based on an initial random check of 5% of the existing data. This 100% QA 

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

corrections were recorded. The corrected database was given one additional QA review following 

completion of all additional data entries; the person performing the initial data entry did not perform 

the final database QA. During all PURECON database work, the database was maintained on a secure 

network server located at the MJW offices. 

Polonium Bioassay Data 

The Po bioassay database for Mound employees contains 207,750 individual sample results spanning 

from 1944 to 1973. Code-named PORECON, it was created from polonium data cards contained in 

individual dosimetry files located in MORE records. Since these data cards were transcribed from 

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

whereby a data clerk entered the “card” data into a database and a different data entry clerk made a 

second independent entry. The database creation program automatically checked the two entries and 

alerted the second clerk if a discrepancy was present. When a discrepancy occurred, the second clerk 

was required to alert MJW supervisory staff. The supervisor interpreted the data and corrected the 

discrepancy, at which point the program accepted the data. 

52 of 95 
SEC-00090 12-19-07 Mound Plant 

Once the database was complete, the second phase of QA was initiated. Supervisory staff compared 

the results of all 24-hour urine samples entered into the database with the original hard copy logbook 

results. These samples were chosen for 100% review because 24-hour samples were typically 

collected following a known or suspected intake, and therefore represented some of the larger results. 

In addition to this review, 1% of the remaining records were compared to the hard copy results. The 

goal was to verify that there was less than a 1% error rate in the database construction. If a larger 

error rate had been found, additional QA would have been performed. 

As this data comparison was performed, it turned up gaps of a few weeks to several years in the data 

of several individuals. This was unusual because samples were typically collected on a weekly basis. 

These gaps were researched using Microsoft Access to identify gaps by a preset time period such as 

30 days, 60 days, etc., up to one year. These data gap printouts showed the length of the gaps, and 

potentially, the data that were absent. Examples of a data gap printout are shown in Appendix D of 

the Phase I Final Report (MJW, 2002, Phase I). The data gap research also helped identify those 

periods of potentially-missing data in an individual’s file so that the paper records of weekly reports 

and logbooks could be searched for the occurrence of a particular name. It should be noted that for 

the early Po records, only the person’s name was used as a means of record identification. In many 

instances, the name was not complete; in a few cases, only nicknames were entered. Consequently, it 

is unknown if all records for an individual were reconstructed correctly in that regard. 

Once the initial Po database entry work was complete, MJW turned its attention to additional sources 

of Po data that had not been previously identified. As was previously discussed, the original Po 

logbooks were consulted throughout the Po data entry process to resolve conflicts found on the Po 

cards. As a result of continuing to consult these logbooks, additional data were discovered that had 

never been captured on Po data cards. These new data were input into the Po database as they were 

discovered. 

Additional data added to the PORECON database came from a 3-ring binder containing two sets of 19 

microfiche discovered in historical file drawers. Labeled “Po-210 Historical Exposure Data,” the data 

entered on the fiche contained the worker's name, SSN, and Po bioassay data consisting of the sample 

date and result. Because the origin of these data was unknown, they were treated as potential 

information which may be missing from the PORECON database. Therefore, a 100% check of the 

fiche data against the PORECON database was performed. The results showed that a few persons 

listed on the fiche were not included in the database. They also showed that, for several individuals, 

the fiche contained more sample information than the database. Finally, in a few instances, the fiche 

data were in conflict with the database information. In this case, the original Po logbooks were again 

consulted to resolve any conflicts. 

Almost from the inception of the Pre-1989 Dose Reconstruction Project, there were reports by former 

Mound staff of human bioassay data present in original logbooks sent for classified storage at the Los 

Alamos National Laboratory (LANL). Discussions were initiated between DOE Mound and DOE 

LANL in October 1997 regarding a limited search of the Mound logbooks. After several months of 

discussion, MJW staff spent two days at LANL in March 1998 reviewing approximately 230 

classified, potentially radiologically-contaminated logbooks. The results of this review showed that 

about 10% of the logbooks examined contained human bioassay results for polonium. An additional 

5% of the information gathered was also related to Po research, such as nose wipe data, blood sample 

data, fecal sample data, and various animal studies. Additional discussions were then held between 

53 of 95 
SEC-00090 12-19-07 Mound Plant 

Mound DOE and LANL DOE to retrieve a selected number of Mound logbooks. A total of 

approximately 1500 logbooks were returned to Mound following declassification. A complete review 

of these declassified records was performed and the results of this additional work showed that only 

about 5% of these logbooks contained human bioassay results for Po with some additional animal 

data. 

After the polonium logbook material from LANL had been declassified and reviewed by MJW staff, 

Mound staff discovered that not all pertinent Po records had been sent to LANL. Several thousand 

additional logbooks located on site were identified as potentially containing project-relevant material. 

Once the scope of the project was defined and funded, a review of the classified records in the 

logbooks was begun. Five Q-cleared individuals working part-time reviewed approximately 5,300 

logbooks. Again, approximately 5% of the logbooks provided information relevant to human Po 

bioassay data while an additional 5% of the information retrieved related to animal studies using 

various Po compounds. 

It was discovered during MJW’s review of logbooks and microfiche that all of the data found in the 

Mound logbooks retrieved from LANL was recorded on the microfiche. It is likely, therefore, that in 

reviewing all of the microfilm at Mound related to Po bioassay data, all available data have been 

reviewed regardless of the location of the hardcopy information. 

Tritium Bioassay Data 

Mound tritium data reside in the MESH database. Initial review of the data by MJW during the 

Pre-1989 Dose Reconstruction Project revealed that records entered into the system from 1957 until 

1982 only listed the year, the person's social security number (SSN), and a dose in rem. Database 

information from 1982 to the present consisted of the original tritium bioassay analytical data with 

sample dates, in addition to the information listed above, with the exception that no annual dose is 

given in any post-1981 records. No documentation was located in the historical files that described the 

algorithm used to calculate the dose reported in the database for the earlier years. However, the 

bioassay methods used throughout the tritium monitoring period, as well as the associated detection 

limits and accuracy, are known (Meyer, 1992). As noted by Meyer, “urine sampling counting for 

tritium has been automated since the early days of tritium work and the processing of the data has 

been handled by computer for many many years...The calculation of whole body exposure has been a 

routine procedure in tritium dosimetry.” 

Except for the years 1976 and 1977, primary data for tritium bioassay results are available. Workers 

involved with the Pre-1989 Dose Reconstruction Project located and used original logbook bioassay 

data for the highest-exposed employees (pre-1982) for tritium dose algorithm development. The 

format used for recording primary (and secondary) tritium records has changed many times through 

the years of tritium bioassay. The tritium dose records available to the dose reconstructor consist, 

with rare exceptions, of information in the MESH database. Tritium dose records in MESH contain 

annual totals through 1981, and actual bioassay results for 1982 and after. Dose reconstruction is 

based on the ‘recording level’ of 6 μCi/L through the year 1995 unless individual bioassay results 

(zero or non-zero) are provided. Positive recorded annual doses are modified with the correction 

factor in accordance with Equation 5-4 in the Mound Occupational Internal Dosimetry TBD 

(ORAUT-TKBS-0016-5). If the modified dose is greater than the missed dose, based on the recording 

level, modified dose is assigned. If the missed dose is greater, then missed dose is assigned. 

54 of 95 
SEC-00090 12-19-07 Mound Plant 

“Other Radionuclides” Bioassay Data 

For the purposes of this report, “other” radionuclides are defined as radionuclides other than tritium, 

Po-210, or plutonium isotopes. Bioassay data for other radionuclides were collected from several 

sources and compiled into Excel spreadsheets as part of the Pre-1989 Dose Reconstruction Project. 

Unlike the plutonium (PURECON) database or the polonium (PORECON) and tritium databases, 

which were created from fairly well-organized individual dosimetry records, the “other radionuclide” 

information was generally very poorly-documented and the interpretation of the bioassay results were 

often at best scientific approximations. It appears that because the activities involving the other 

radionuclides were not large-scale operations, the documentation of associated bioassay sample 

information was secondary to the larger plutonium, polonium, and tritium sampling and analysis 

programs. 

Logbooks served as the primary source of information MJW used to construct the Excel spreadsheets. 

Additional results came from Kardex files. A total of 215 records were found in, and extracted from, 

the PURECON database. The curium and americium data found in PURECON represent the only 

data discovered to date for those radionuclides. 

Difficulties encountered in attempting to interpret available bioassay records are noted in a paper 

entitled MJW Corporation Position on “Other” Radionuclides for the Pre-1989 Dose Assessment 

Project (MJW, 2002, Phase II). MJW notes therein that gross alpha counting was used to obtain the 

available results. Some of the results were not associated with a name, social security number, or 

health physics number. Often, there were no units associated with a result. In many cases, there were 

results for an element such as radium or thorium, but it was unclear which isotope was intended. 

There was no information on the age, solubility, or chemical form of the elements. In some cases, it 

appears bioassay results were repeatedly reported for two, or sometimes three, different radionuclides. 

For example, a person may have identical results for protactinium and Th-232. In other cases, urine 

samples may have been analyzed for radium/actinium/thorium by differential decay analysis of the 

radium fraction. The same urine sample may have also been analyzed for Th-232 by doing a Ra-Th 

separation. The results of the differential decay analysis appeared to conflict with the Th-232 analysis 

in that the dominant radium isotope is Ra-223 whereas Ra-224 would be expected. This would seem 

to indicate that the thorium results should have been interpreted as Th-227. 

The methodologies used to reconstruct dose for these radionuclides are discussed in Section 7.2.1.4. 

7.1.2 External Monitoring Data Review 

After polonium operations began in February 1949, the results of the pocket dosimeter measurements, 

film badge readings, and neutron doses were entered in each employee’s radiation exposure record on 

Form 1015-X, which remained in use until December 1959. Beginning in May 1959, neutron 

exposure data were entered on punch cards and processed by the External Exposure Analysis System 

(EXAS) program. Beginning on January 2, 1960, results of both photon and neutron monitoring film 

were entered on punch cards (Meyer, 1994, Volume I, 1960 Appendix I, pp. 133–138). After that 

time, dose data based on film measurements were entered on Form 1015-X. 

Beginning in March 1963 pocket dosimeter results were entered into a file-card system. The use of 

punch cards for recording pocket dosimeters ended, and a Kardex file cabinet was purchased for the 

55 of 95 
SEC-00090 12-19-07 Mound Plant 

file cards. The file cards were used from March 25, 1963, until December 27, 1963 (Meyer 1994, 

Volume I, 1963 Appendix III, p. 263). Beginning on December 30, 1963, pocket dosimeter data were 

entered on Form 1333. This form, which permitted the use of a Rolodex V-File for more efficient 

handling of daily records, remained in use through May 1966. 

The External Radiation Analysis Data (ERAD) program replaced EXAS in 1978, and the Mound 

Environmental Safety and Health (MESH) program replaced ERAD in September 1989. 

The MESH database contains all measured employee radiation doses since 1947, although only the 

annual summary dose is available for years before 1977. Annual doses are sufficient for 

overestimation of employee doses; however, the lack of individual dosimeter cycle data requires 

claimant-favorable assumptions to calculate missed external doses. Missed external dose is the 

potential dose received by an individual below the technological limit of the dosimeter to detect 

(called the limit of detection, or LOD). 

Early neutron dose measurements were made using neutron track emulsion, Type A (NTA) film. 

These film dosimeters likely responded in a manner proportional to the doses received for early 

operations at Mound, resulting in neutron doses due to the relatively high-energy spectrum associated 

with neutrons from Po-Be sources. Other operations had lower average-energy neutron spectra. 

Obviously, many changes have occurred over time with regard to Mound’s dosimetry program and 

record-keeping practices. As described by Meyer, the need for a “some day in the future” capability 

for total program reconstruction was not a well-defined “need,” especially in the early decades of 

operation (Meyer, 1994). In practice, maintaining controlled record storage was more of a challenge 

than developing the records themselves. Nevertheless, a large number of documents describing the 

program and dosimetry performance are available. After evaluating these, NIOSH identified no 

significant administrative practice that would jeopardize the integrity of the recorded external dose. 

Many of these documents are referenced in ORAUT-TKBS-0016-6, incorporated into the History of 

Personnel External Dosimetry Program at the Dayton Project and Mound Laboratory 1946-1993 

(Meyer, 1994), and in the SRDB. Program descriptions and assessments for later years are also 

available in the SRDB. 

7.2 Internal Radiation Doses at Mound 

The principal source of internal radiation dose for members of the proposed class would have been 

inhalation and ingestion of radiological contamination during the following operations: 

•	 Research and development (R&D) of fabrication of neutron sources for nuclear weapons initiators 

and neutron sources for other uses 

•	 Research for alternatives to Po-210 for use in weapons initiators (because the short half-life of 

Po-210 required the frequent re-manufacture of the initiators) 

•	 Radioisotope thermoelectric generators (RTGs) and radioisotope heat sources, which have been 

used on a variety of missions to provide heat and electric power 

•	 Tritium-handling technologies that supported weapons and non-weapons programs 

56 of 95 
SEC-00090 12-19-07 Mound Plant 

• Research on metal tritides and tritium targets 

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

• Research into production of alternative reactor fuels such as thorium 

• Research and development of the joining of exotic metals 

• Research and development of technologies for radioactive waste management 

The potential internal sources would have been dependent on the operational area and activities. The 

major sources of intakes have been polonium, plutonium, and tritium. Bioassay monitoring was 

typically conducted for the radionuclides determined by the site radiation protection program to be of 

primary dosimetric concern. 

Mound listed the following radionuclides as primary radionuclides because they could deliver 

relatively high doses to human receptors, had widespread use at the site in multiple buildings and 

facility processes, and had sufficient site documentation to evaluate internal dosimetry. Tritium was 

included due to potential absorption via hydrogen exchange across the skin barrier. (ORAUT-TKBS0016-5) 

• Po-210 • Pu-241* 

• Pu-238 • Pu-242* 

• Pu-239 • Pa-231 

• Pu-240* • H-3 

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

Radionuclides of secondary concern to Mound staff were assessed with limited internal dosimetry 

data due to the limited worker exposures. Short-lived radioactive gases and their respective daughter 

products were generated at Mound by activities involving uranium and thorium chain extraction and 

separation activities, as well as by the manufacturing of sealed sources. Exposures to these gases were 

minimized by a ventilation system installed in 1980 and were largely restricted to the SW building 

where radium and actinium work took place. The following are the secondary radionuclides in 

addition to daughter products from the uranium and thorium decay chains: 

• Am-241 • U-233 

• Cm-244 • Th-232 

• U-238 • Th-230 

• U-235 • Th-228 

• U-234 

Comparison results to quantify “short” and “long-lived” radionuclides or specific measurements of 

“Short-Lived Daughter Products” are contained in health physics periodic reports starting in March 

1952. 

57 of 95 
 

SEC-00090 12-19-07 Mound Plant 

7.2.1 Process-Related Internal Doses at Mound 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the proposed class. More detailed 

information on the individual topics can be found in Section 6.1 of this report and in (Meyer, 1992) 

and (King, 1995). 

7.2.1.1 Tritium 

Extensive use of tritium began at Mound in the mid-1950s, and some limited exposure may have been 

possible prior to that time. Most of the tritium exposure at Mound was assumed to be related to the 

uptake of tritiated water (HTO), which is effectively monitored using urine bioassay. Tritium dose 

assessments at Mound were reliably measured using standard assessment methodologies starting in 

1957. Measured doses are modified to reflect current dose models as discussed in Section 5.3.1.1 in 

the Mound Occupational Internal Dosimetry TBD (ORAUT-TKBS-0016-5). Recommended doses for 

unmonitored exposures are also provided in the referenced section. The quantity and quality of 

available tritium urinalysis results are sufficient for estimating maximum doses or precisely estimating 

doses. 

7.2.1.2 Polonium-210 Operations 

Full-scale separation of Po-210 from irradiated bismuth took place on the second floor of the T 

Building from 1949 to 1971. Facilities and activities included neutron source calibration, 

decontamination laboratories, a storage pool for irradiated bismuth slugs, neutron source processing, 

and analytical laboratories. Po-210 was also present in Building HH from 1949 to 1959, generating 

sludge materials with 0.02 Ci/l total alpha activity. Use of Po-210 in the R Building involved research 

and electrodeposition studies from 1948 to 1951, and the manufacturing of Po-Be neutron sources 

from 1956 to 1961. Po-Be sources were first manufactured at Mound as neutron source initiators to 

support various weapons programs. Polonium was later used to produce Po-210 heat source 

generators (King, 1995). Intakes of polonium and the resulting dose may be calculated using bioassay 

data that existed as early as 1944. 

The SW Building was used for counting Po-210 sources, neutron source measurement, source strength 

verification, and Po-209 and Po-210 retrieval. Aqueous wastes containing Po-208, Po-209, and 

Po-210 were present in the WD and WDA Buildings beginning in 1949. Chemical forms included 

polonium nitrate and polonium chloride (Meyer, 1992). 

As discussed in Section 6.0 of this report, MJW placed Po-210 bioassay data in the PORECON 

database during the Pre-1989 Dose Assessment Project after evaluating individual dosimetry files 

from original logbooks and data cards. PORECON contains over 207,750 individual sample results 

spanning from 1944-1973. 

These data may be supplemented with available process information to estimate a reasonable 

bounding dose. 

58 of 95 
 

SEC-00090 12-19-07 Mound Plant 

7.2.1.3 Plutonium 

Pu-238 is the primary radionuclide of concern with respect to internal dose at the Mound site 

beginning about 1959. The first production RTG, the SNAP-3A, was built in 1958 using Po-210 

alpha decay as a heat source. President Eisenhower used the current to generate a radio transmission 

from the Oval Office in 1959. Subsequently, the SNAP-3 was redesigned to use Pu-238 in order to 

extend the life of the generator. The SNAP-3B was first launched in the Navy Transit satellite 

program. 

Production of Pu-238 was a large-scale project, eventually using the SM and PP buildings, and 

extending from 1959 through the late 1970s. A number of material forms were used, including 

Pu-238 metal, plutonium oxide, plutonium dioxide, and plutonium metal ceramic (cermet). The 

generator projects included a number of spacecraft power sources for satellites, the Apollo program, 

and planetary and interstellar space exploration programs employing the Pioneer and Voyager 

spacecraft. Other sources were fabricated for use in buoys, for potential use in pacemakers, and in 

diving suit heat sources. Production efforts were reduced in the period of the 1970s. During this time, 

encapsulation of the Pu-238 was moved to the Savannah River Site, and after 1979, unencapsulated 

Pu-238 was not routinely handled at Mound. The program had an indeterminate status for a number of 

years, but operations with RTG fuel were officially moved to the INEEL site in 2006. 

The Mound site featured only limited exposure to weapons-grade plutonium in small-scale research 

operations and the preparation of a small number of neutron sources. Weapons-grade Pu-239 used in 

the Mound plutonium neutron source project (R building, 1956-1958) was reported to be over 95% 

pure by mass, with trace amounts of Pu-240 and Pu-241, which are not dosimetrically significant 

(King, 1995). Additional information on Pu-239 feed material characteristics can be found in the 

Mound site profile. 

Plutonium bioassay results are available from 1956 through 1991 in the PURECON database. 

Subsequent plutonium internal dose monitoring results are listed in the MESH database. Early results 

were based on gross alpha measurements, and the resulting doses must be calculated based on the 

potential exposure. Later measurements (1980 and after) were isotopic for Pu-238 and Pu-239. These 

data may be supplemented with available process information to estimate a reasonable bounding dose. 

7.2.1.4 Other Radionuclides with Bioassay Monitoring Data 

The Mound site conducted diverse activities in research and chemical engineering; a number of which 

are discussed in Sections 6.1.4 through 6.1.10. Each process is summarized below with respect to 

methodology used to reconstruct internal dose. 

•	 Protactinium-231, 1954-1958: This limited program featured bioassay data for the primary 

radionuclide beginning in 1955, and this value is used to assign missed dose as well as potential 

dose from intakes implied by positive results. These data may be supplemented with available 

process information to estimate a reasonable bounding dose. 

59 of 95 
SEC-00090 12-19-07 Mound Plant 

•	 Thorium-230, 1954-1956: Programs involving Th-230 featured bioassay data for the primary 

radionuclide, and this value is used to assign missed dose as well as potential dose from intakes 

implied by positive results. Air activity measurements are available in periodic health physics 

reports specific to the ionium program. Along with available process information and bioassay 

data available from 1956 onward, maximum doses can be estimated, or doses can be estimated 

more precisely than a bounding dose estimate. 

•	 Thorium-232, 1954-1956 (Research); 1956-1975 (Storage): Programs involving Th-232 featured 

bioassay data for the primary radionuclide, and this value is used to assign missed dose as well as 

potential dose from intakes implied by positive results. Small numbers of bioassay results are 

available from 1951 to 1954, with larger numbers available from 1955 through 1959. Additional 

bioassay data associated with the periodic re-drumming of material is available prior to and after 

the time the material was in the Building 21 storage basins. These data may be supplemented with 

available process information to estimate a reasonable bounding dose. 

•	 Radium-226, Ac-227, and Th-228, 1949-1954 (research and production); 1955-1959 

(decontamination and decommissioning): These radionuclides were part of research on production 

for use of Ac-227 as a substitute for polonium in neutron initiators. The decontamination and 

decommissioning of the building where the work was done was completed in February 1959 

(Meyer, 1992, p.38). NIOSH has access to a limited number of bioassay results for these 

radionuclides; however, interpretation of the results is uncertain. NIOSH cannot bound the dose 

for the time period October 1, 1949 through February 28, 1959. 

•	 Uranium: Processes with uranium were associated with reactor fuels research. Existing bioassay 

results are used to assign missed dose as well as potential dose from intakes implied by positive 

results. Along with available process information and bioassay data, maximum doses can be 

estimated or doses can be estimated more precisely than a bounding dose estimate. 

•	 Americium-241 and Cm-244: Limited programs with these materials resulted in a small number of 

bioassay results. These are used to assign missed dose as well as potential dose from intakes 

implied by positive results. These data may be supplemented with available process information 

to estimate a reasonable bounding dose. 

7.2.1.5 Other Radionuclides with No Bioassay Data 

A number of radionuclides are described in the literature as available through direct exposure during 

research activities, or as part of the waste disposal system. Small quantities of a variety of 

radionuclides associated with research-scale activities and their progeny are available in subsequent 

years to decontamination and decommissioning workers, as listed in the King document (King, 1995). 

Like most radiation protection programs, the Mound program sampled for those radionuclides having 

the potential to produce the majority of the internal dose. Radionuclides were considered less 

significant for several reasons, including: 

•	 Limited amounts of material and limited number of personnel exposed 

60 of 95 
 

SEC-00090 12-19-07 Mound Plant 

•	 Very small doses compared with the primary dose radionuclide. For example, a spectrum of betaand gamma-emitters associated with the irradiated bismuth feed product for the polonium 

refinement process is listed in King with the statement that “Polonium-210 is the major 

radionuclide of concern, with Zinc-65 a distant second” (King, 1995) 

•	 Insignificant dose commitment due to a short effective half-life. An example of this would be 

La-140, used as a radiotracer 

For Mound chemical research operations, descriptions of the process and results exist in Mound 

progress reports, technical reports, and in peer-reviewed journals. From these documents, the 

proportions and amounts of radionuclides can be determined with sufficient accuracy to estimate a 

maximum dose. Another source of information is air monitoring results available for some buildings 

and time periods. 

Examples of other radionuclides for which doses will be calculated based on data other than bioassay 

results are listed below. 

•	 Fission product dose from ‘reactor waste’ research (1949-1953. A project was conducted in the R 

Building to research the feasibility of removing fission products from waste streams, including the 

bismuth phosphate, tributyl phosphate, and the solvent extraction (Purex) plutonium separation 

processes. Progress reports, such as Decontamination of Process Waste Solutions Containing 

Fission Products by Adsorption and Coprecipitation Methods (Information Report) (Decon, 

1951), contain detailed descriptions of the process, along with chemical composition and 

radioassay results. Additionally, bioassay was performed for individuals with plutonium as the 

indicator element. From these, maximum exposures may be determined with sufficient accuracy 

to determine a maximum dose. 

•	 Separation of yttrium from strontium (1952-1954). A small research project was conducted to 

separate Sr-90 from its progeny Y-90 (in secular equilibrium in material aged more than 30 days). 

No bioassay data exist for this operation; however, a description of the chemical process exists in 

the document Preparation of Carrier-Free Yttrium-90 (Yt-90). 

•	 Radiotracers (1949-1954). The literature suggests that there was some potential for exposure to 

La-140 and Ba-140 (in secular equilibrium), which was used as a radiotracer to determine the 

efficiency of the separation process with lanthanum and barium modeling the chemical behavior 

of radium and actinium. The proportions of the radionuclides in the process material are listed in 

the progress reports such as Report for Research on Substitute Materials, October 1, 1951 to 

December 31, 1951 (Actinium-227) (Ac-227, 1952). A maximum dose may be estimated for 

potential exposure to these radionuclides during this activity. 

61 of 95 
 

 

 

SEC-00090 12-19-07 Mound Plant 

7.2.1.6 Radon 

Beginning in 1952, sources of radon (Rn-222), thoron (Rn-220), and actinon (Rn-219) were present at 

Mound due to radium and thorium processing and separation of Pa-231 and Ac-227. Thorium sludge 

from Th-232 extraction and purification operations was stored outside in drums from 1954-66. In 

1966, drummed thorium sludge was transferred to Building 21. 

Table 7-1: Radon Isotope Survey Data by Building and Time Period 

Building 

Survey 

dates 

Gas concentration (pCi/l) 

WL 

WLM yr-1 

(a) 

Radon 

(Rn-222) 

Thoron 

(Rn-220) 

Actinon 

(Rn-219) 

SW Tunnel 10/12/79 88,000 28,000 640,000 n/a n/a 

SW-19 before vent 6/79-10/79 67-160 

SW-19 after vent 3/80-4/80 7.7-13.4 0.03 0.4 

12/89 2.6 Not 

Detected 

12/99 1.0-5.8b 

4/00 0.7-7.2 

1998-2000 5.8-12 

SW-21 5/83 17.5-52.8 n/a n/a n/a n/a 

12/89 34-118 0.3-0.7 0.4-1.3 

0.85 

median 

4.7-15.3 

4/90-6/90 117-161 10.0 median 

125 

SW-22 6/90 125 n/a n/a n/a n/a 

SW-48 12/89 3.2 n/a n/a n/a n/a 

Old SD 12/89 1.5-2.4 n/a n/a n/a n/a 

Fire station 12/89 1.2-1.4 n/a n/a n/a n/a 

Paint shop 12/89 0.9-1.2 n/a n/a n/a n/a 

A 10/88-2/89 0.1-1.1 n/a n/a n/a n/a 

All other buildings 12/89 5 0.4-0.9 n/a n/a n/a n/a 

Outside facilities 5/83 0.24-0.59 n/a n/a n/a n/a 

Reported background 0.1 to 2.1 

Average = 0.5 

n/a n/a n/a n/a 

a. Working level months per year (WLM yr-1) were determined as WL (2000 hr yr-1) (1/ 170 hr WLM-1). 

b. Bolded concentrations were derived from charcoal canister measurements. 

The SW-19 Building had elevated radon concentrations emanating from radium and thorium 

processing wastes. On October 12, 1979, inert gas concentrations in the SW Building underground 

tunnel were measured at 88,000 pCi/l Rn-222, 28,000 pCi/l Rn-220, and 640,000 pCi/l Rn-219. A 

Rn-222 concentration of 88,000pCi/l would correspond to 352 WL, assuming an ICRP 50 indoor 

mean radon daughter equilibrium factor of 0.45 (ICRP, 1987). The tunnel was not an occupied work 

area; however, elevated concentrations of radon were transported from the tunnel into SW-19 work 

areas. Measurements of Rn-222 near an employee’s desk ranged from 67 to 160 pCi/l in 1979. 

A ventilation system was installed in early 1980 to vent SW Building tunnel air (Meyer, 1992). This 

system reduced Rn-222 concentrations in SW-19 by a factor of 10 or more. This result was confirmed 

with continuous measurements from 7.7 pCi/l to 13.4 pCi/l. A working level (WL) measurement by 

62 of 95 
 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

the employee’s desk following ventilation system installation was 0.03 WL or 0.03 (12 mo/yr) = 0.4 

working level month (WLM) compared with an occupational limit of 4 WLM/yr (King, 1995). 

A DOE radon study was conducted from December 12-15, 1989, to measure radon in various Mound 

buildings (UNC Geotech, 1990). The majority of buildings had radon concentrations below 1.0 pCi/l 

Rn-222, except SW and Old SD buildings. In June 2000, a radon study summary report was issued 

based on 1990 and 1999 measurements (BWXT, 2000). Mound site radon background was reported 

to be 0.5 pCi/l with a range of 0.1 to 2.1 pCi/l. 

SW-19 was the only building at Mound identified as an area of potential occupational exposure to Rn222 and Rn-220 (King, 1995). Rn-220 and Rn-219 measurement results were very limited despite the 

high concentrations observed in the underground tunnel. The only Rn-219 measurements were made 

in Building 21 at 0.3 to 0.7 pCi/l, but the holding time before analysis was excessive compared to the 

four-second half-life of Rn-219. The only Rn-220 measurement in SW-19 was below detection. Rn220 and Rn-219 exposures would not be detectable in excreta by bioassay due to very short half-lives. 

(ORAUT-TKBS-0016-5). 

The WLM values in Table 7-2 have been used to reconstruct doses for EEOICPA claimants suspected 

of having been exposed to radon in air. All WLMs have been assumed to be median values of 

lognormal distributions with a geometric standard deviation (GSD) of 3.0. 

To reconstruct missed doses, a background radon concentration of 0.5 pCi/l can be used, which 

converts to 0.03 WLM indoors assuming 100% occupancy and 0.45 (ICRP, 1987). 

Table 7-2: Radon-222 WLM Assumptions for Dose Reconstruction 

Building conditions Period 

Radon 

(pCi/L) 

Radon 

(WL) 

Radon 

(WLM) 

SW Tunnel Prior to Ventilation 1949-1979 88,000 352 4,100 

SW-19 Ra-Ac Pilot Project 1949-1952 160 0.72 8.5 

SW-19 Ra-Ac Old Cave Production 1952-1960 160 0.72 8.5 

SW-19 Post Production, Prior to Ventilation 1961-1979 160 0.72 8.5 

SW-19 Post Production, Post to Ventilation 1980-1995 0.7-13.4 0.03 0.4 

SW-21 1952-1995 17.5-125 0.85 10.0 

SW-22 1966-1995 125 0.56 6.6 

SW-48 1980-1995 3.2 0.01 0.2 

Descriptions of radiation protection activities in periodic health physics report demonstrate that the 

health physics program was considering short-lived air activity to the extent that this activity was 

routinely reported through the era of radium and thorium processing, and Pa and Ac separation. For 

periods outside these years, and for which air concentrations are not available, doses may be estimated 

based on the measured air concentrations and scaled based on the available source term, as determined 

in the available process information. Maximum exposures may be determined with sufficient 

accuracy to determine a maximum bounding dose. 

63 of 95 
SEC-00090 12-19-07 Mound Plant 

7.2.1.7 Missed Internal Dose 

Missed dose is calculated using bioassay data specific to individuals and represents dose from intakes 

that could have been received, but were not detected by the bioassay method used (urinalysis in most 

cases for Mound). Missed dose is assigned based on the minimum detectable amounts (MDAs) for 

each radionuclide and the bioassay method listed in the Mound Occupational Internal Dosimetry TBD 

(ORAUT-TKBS-0016-5). Missed dose is applied only for monitored individuals. Doses that may 

have been received, but for which no dose monitoring was performed, are more properly termed 

“unmonitored dose.” Some employees may have received unmonitored exposures to radioactive 

material. Doses for these individuals may be bounded using process information in the technical 

reports on Mound research, measured air concentrations, or a combination of the two. 

7.2.1.8 Decommissioning and Decontamination 

Contractors responsible for performing decommissioning activities were responsible for developing 

and implementing radiation control programs consistent with DOE requirements in 10 CFR pt. 835. 

These contractor programs included provisions to monitor external and internal personnel radiation 

exposures. The potentials for radiation exposure during decommissioning were generally 

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

commensurate with the specific decommissioning operation being performed. Data collected included 

air monitoring, bioassay, and external exposure monitoring. Personnel monitoring results were 

provided to the contracting DOE office and included in individual claim files and comprise the 

external and internal dose monitoring results for each individual. The internal data for these personnel 

can be extensive in terms of the number of radionuclides for which bioassay was conducted. 

7.2.2 Ambient Environmental Internal Radiation Doses at Mound 

Unlike some of the other major DOE facilities, Mound did not generally experience significant 

site-wide ambient contamination, and there was less concern about the potential for internal dose 

related to ambient working conditions. Nevertheless, the use of facility ambient air monitoring data 

for purposes of assessing internal radiation doses was evaluated for purposes of performing EEOICPA 

dose reconstructions. Except for some data for airborne radon and tritium, use of these data was not 

considered a viable approach due to unknown factors potentially affecting the representativeness of 

actual breathing zone air concentrations. Personnel ambient exposure/dose is accounted for in the 

available monitoring data for those personnel and these data can be used to bound the 

ambient/environmental doses. Further evaluation of these exposures was not performed or required 

for this evaluation report. In any case, the existing Mound air monitoring data are currently contained 

in broadly-dispersed record sources. 

64 of 95 
SEC-00090 12-19-07 Mound Plant 

7.2.3 Internal Dose Reconstruction 

For the period October 1, 1949 through February 28, 1959, NIOSH has determined that internal doses 

from Ra226, Ac227, and Th228 associated with the separation operation in SW-19 cannot be determined 

with sufficient accuracy. This is based on the following factors: 

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

interpretation of the results is uncertain (MJW, 2002). 

2.	 While it is likely that the bioassay results relate to the workers directly involved in this operation, 

it is not known what fraction of those workers was sampled. 

3.	 There is strong evidence that airborne contamination was produced by this operation, and that this 

contamination was spread beyond SW-19 to other areas in R and SW Buildings. This situation 

created significant exposure potential among R and SW Building workers for these radionuclides. 

The limited number of individuals for whom Ra-Ac-Th bioassay results are available suggests that 

the larger population in the R and SW Buildings were unmonitored for potential intakes. 

4.	 The reported airborne contamination concentrations throughout R and SW Buildings are relatively 

high in some cases, suggesting the potential for non-trivial intakes and consequent internal doses. 

While it is likely that significant exposure potential resulting from this operation was limited to the R 

and SW Buildings, it is not clear as of this writing whether access to these buildings was strictly 

limited to the personnel regularly working in them. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

Potential for radionuclide intakes existed at Mound. Mound sought to limit internal exposures and 

maintained a progressive bioassay program throughout its operational history. NIOSH has both 

demonstrated that employees with the greatest potential for internal intake were monitored, and 

determined that the available bioassay data can be used to reconstruct or bound potential internal 

radiation doses for those employees, with the exception of those workers who may have been exposed 

to Ac-227, Th-228, and Ra-226 from October 1, 1949 through February 28, 1959. 

NIOSH can bound the doses arising from exposure to polonium, tritium, plutonium, radon, 

protactinium, Th-230, and Th-232, uranium, and stable metal tritides using the scenarios described in 

the previous sections. 

65 of 95 
SEC-00090 12-19-07 Mound Plant 

NIOSH has established that unmonitored intakes of radionuclides associated with radium-thoriumactinium processing, and purification research and production, may have resulted in unmonitored 

doses to research and process workers, and workers incidentally exposed in these facilities. For this 

reason, a class of workers is being proposed for addition to the SEC. For the other periods of Mound 

site operations, NIOSH has access to sufficient information to either estimate the maximum internal 

radiation dose for every type of cancer for which radiation dose are reconstructed that could have 

incurred under plausible circumstances by any member of the class; or estimate the internal radiation 

doses to member of the class more precisely than a maximum dose estimate. 

7.3 External Radiation Doses at Mound 

The principal source of external radiation doses for members of the proposed class is associated with 

Po production operations, which moved from the Dayton Project to the Mound Site in 1949. The 

narrowly-focused Po production work expanded to the development and production of weapons 

components. Production of Pu-238 and Pu-239 grew from the early Po work. The principal Mound 

mission was the research, development, and manufacture of non-nuclear explosive components for 

nuclear weapons that were assembled at other sites. Research and development included the 

fabrication of neutron and alpha sources for weapons and non-weapons use. Starting in the 1950s, 

Mound developed radioisotope thermoelectric generators (RTGs) which have been used on a variety 

of missions to provide heat and power for spacecraft. Po-210 production declined in the 1960s and 

was phased out in 1971 (ORAUT-TKBS-0016-2). 

External dose monitoring formed a part of personnel protective practice from the early days at Mound, 

starting with the first operational process, polonium neutron source preparation. External dose 

monitoring continued throughout Mound’s operational history. It is known that employees at the 

Dayton Laboratory (Units III and IV) were unmonitored for neutron dose; however, neutron dose 

monitoring forms a part of most early dose monitoring records in Mound employee files. These 

results reflect measurements with neutron-track emulsion (NTA, for neutron track, type A) which, in 

contrast with measurements at other sites during that era, likely provided a proportional estimate of 

neutron doses in the spectrum generated by Po-Be sources. Later measurements were made with 

thermoluminescent dosimeters (TLDs). 

Photon dose monitoring was conducted from the onset of Mound operations using standard film 

dosimeters and, later, TLDs. Film and TLD dosimeters provided reliable measurements of the 

photons in Mound work areas. Shallow doses, from beta-emitters and low-energy gammas, were 

detected on a portion of this dosimeter as well. 

66 of 95 
SEC-00090 12-19-07 Mound Plant 

7.3.1 Process-Related External Radiation Doses at Mound 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the proposed class. 

7.3.1.1 Radiation Exposure Environment 

The external dose received by Mound workers was a function of the physical location of the workers 

on the site, the processes taking place, the types and quantities of material present, and the time spent 

at each location. Most doses for Mound processing personnel resulted from a mixed field of photons 

and neutrons. Beta doses or doses from low-energy photons were present in some workplaces. 

Breakdowns of the workplace radiation field characteristics are given in the relevant tables in the 

Mound Occupational External Dosimetry TBD (ORAUT-TKBS-0016-6). 

The primary sources of external dose at the Mound site are the two major production programs 

involving polonium and plutonium. Tritium is not a source of external radiation dose. Laboratory 

dose rates could also result in significant external doses, depending on the process and the amount of 

material. Photon and neutron doses have been reliably measured using film dosimeters from the first 

days of Mound operations. A summary of the characteristics of the major external dose sources is 

presented below: 

•	 Polonium Processing: Polonium is essentially a ‘pure’ alpha-emitter; however, alpha interactions 

within the material matrix can generate neutrons with energy proportional to the energy of the 

alpha particle. These neutrons’ energies will be degraded through scattering and moderation. 

Thermal neutron interactions will include capture with emission of prompt gamma rays. Thus, the 

polonium production work resulted in both photon and neutron dose rates. 

The average energy of the Po-Be sources fabricated for nuclear weapons and other purposes is 

reported to be approximately 4.5 MeV. This high average energy is measured with great 

reliability using the NTA film dosimeters. Photon doses were reliably measured for all Mound 

employees entering areas where radiation dose fields existed. NIOSH is confident that with the 

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

estimate. 

Initial polonium processing efforts at the Dayton Laboratory included considerable beta dose, 

particularly of the extremities. The design process for the T Building, where polonium was 

processed at Mound, took these high levels of beta radiation into consideration. Rooms 75 and 76, 

where the loaded bismuth slugs were processed, were equipped with leaded windows (White 

Paper T, 2002) and an “elevated platform (‘Rooms’ 275 and 276) was used to access valves and 

doors by remote operations.” (King, 1995, Section 6.2.50). This evidence suggests that the beta 

dose rates were controlled to a significant extent. That this is the reason that the site did not record 

beta dose readings is documented in a January 4, 1960 memorandum from the health physics 

supervisor, W.A. Bigler. The memo requires that open-window portions of the dosimeter film 

will be read “on any film where the open window is visibly darker than the rest of the film.” 

(Meyer, 1994, Volume I, Page 250) This change was made in response to the fact that health 

physics personnel had noticed darkening of this portion of the film where it “had not been noted 

before.” (Meyer, 1994, Volume I, page 164). The on-going TBD revision process will evaluate 

67 of 95 
SEC-00090 12-19-07 Mound Plant 

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

to non-penetrating radiation (i.e., skin, breast, testes, lip). NIOSH is confident that with the 

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

estimate. 

•	 Plutonium Processing: Plutonium processing also resulted in mixed-field doses from photons and 

neutrons. Since Pu-238 was used as a heat source rather than as a neutron source (in the primary 

processing operation), neutron dose arose from alpha-n interactions of plutonium and its 

compounds. Most processing took place after the health physics program began reading and 

recording non-penetrating dose from beta and low-energy gamma radiation, so doses are measured 

for the most exposed workers. 

7.3.1.2 Dosimetry Records 

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

operations, and for all years of the proposed class time period. The MESH database serves as the 

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

are available for all monitored employees. (Guido, 2003; Meyer, 1994) 

7.3.2 Ambient Environmental External Radiation Doses at Mound 

The ambient environmental external dose is the occupational dose received by individuals while 

outside operational facilities, such as process buildings. External dose from radioactive materials 

outside the body may be the result of direct radiation from radioactive materials in soil, from adjacent 

operational facilities and waste storage areas, from submersion in air containing radionuclides from 

effluent releases, and from re-suspension from soil. The Mound Occupational Environmental Dose 

TBD (ORAUT-TKBS-0016-4) and Occupational Onsite Ambient Dose Reconstruction for DOE Sites 

(ORAUT-PROC-0060) provide the historic background, rationale, and data for reconstruction of 

occupational environmental doses for unmonitored personnel at Mound. The conclusion from the 

above-mentioned references is that Mound facilities and soil are unlikely to have contributed 

significantly to the ambient environmental dose. In addition, the TBD evaluates external doses from 

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

annual effective air-submersion external exposures from all radionuclides in these sources during the 

period 1949 through 2002 were less than 5.0E-10 Sv (ORAUT-TKBS-0016-4). The conclusion of the 

TBD is that submersion dose from effluents is insignificant and does not need to be considered in dose 

reconstruction. The ambient environmental dose would be accounted for, and bounded from, the 

occupational monitoring data for personnel; therefore, further evaluation of the ambient environmental 

dose is not necessary in this evaluation. 

68 of 95 
SEC-00090 12-19-07 Mound Plant 

7.3.3 Mound Occupational X-Ray Examinations 

Diagnostic X-ray procedures were a contributor to the occupational radiation exposure of Mound 

workers. In general, the dose from such exposures was not measured, considered, or included as part 

of the overall occupational exposure of the employee, although it clearly was occupationally-related. 

Diagnostic medical X-rays administered in conjunction with routine or special physical examinations 

required for employment are a valid source of occupational exposure. Unlike occupational exposures 

incurred during normal work processes, individual diagnostic medical X-ray exposures were not 

monitored, necessitating reconstruction of doses acquired in this manner. (ORAUT-TKBS-0016-3) 

Mound employees received posterior–anterior (PA) chest X-rays at hiring, at specified intervals 

thereafter, and at termination. In 1983, a policy modification required X-rays for terminating 

employees only if they had not had a chest X-ray within the previous 9 months; this changed to 6 

months in 1988. In 1988, a lateral (LAT) view was required for women known to have undergone 

breast augmentations; the frequency of these examinations is not known. ORAUT-TKBS-0016-3 lists 

examination frequencies over the years for different groups based on information obtained from the 

Mound data files. The records returned by DOE include the occupational medical X-rays performed 

for Mound employees. These are reviewed during dose reconstruction. Typically, the average 

frequency is less than one per year for most employees. Typically, dose reconstructors assume annual 

frequencies as an overestimating assumption. 

Prior to 1980, details about the X-ray apparatus and technique parameters are not known and default 

values were used for entrance kerma (ORAUT-TKBS-0003). Since at least 1980, the X-ray apparatus 

at Mound was a stationary enclosed unit with the control panel separated from the tube head by a wall. 

From 1980 through 2003, the equipment consisted of a single-phase, TWX-325 control unit with a 

Eureka Emerald 125 X-ray tube, Eureka Linear II automatic collimator, and S&S 1417B vertical 

cassette holder (VCH) used with no grid and 14- by 17-in. Kodak X-O-Matic Regular film. Actual 

measurement data obtained by the Ohio Department of Health were used. ORAUT-TKBS-0016-3 

summarizes technique parameters and entrance kerma for PA and LAT views, respectively. For the 

period before 1980, no external collimation was assumed when converting entrance kerma to organ 

doses. 

Although there is no specific evidence in the history data file (Mound, 2002) to indicate the use of 

photofluorography at Mound, evidence suggests that General Electric mobile X-ray units might have 

been used at various U.S. Atomic Energy Commission, Energy Research and Development 

Administrations, or U.S. Department of Energy sites (NCRP, 1989). A review of files from the 1940s 

and 1950s reveals that when photofluorography was used, an unusually large number of X-ray 

examinations would be performed in a given day. Thus, a larger than normal number of X-ray records 

for a given day might be a positive indicator of the use of photofluorography. However, in the 

absence of specific data on the use of photofluorography at Mound, or even that such equipment was 

present on site, this analysis assumes that photofluorography did not occur at Mound. The analysis 

will be performed in accordance with the guidance in ORAUT-OTIB-0006, Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures. 

69 of 95 
SEC-00090 12-19-07 Mound Plant 

7.3.4 External Dose Reconstruction 

By December 6, 2007, EEOICPA claims meeting the proposed class definition being evaluated in this 

report had been submitted to NIOSH. Of those 491 claims, NIOSH has completed dose 

reconstructions for 348 claims. 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon Dose 

• Electron Dose 

• Neutron Dose 

• Unmonitored Individuals Working in Production Areas 

• Medical X-ray 

7.3.4.1 Photon Dose 

Photon doses are reliably measured at Mound using the various dose measurement methodologies 

described in the Occupational External Dosimetry TBD (ORAUT-TKBS-0016-6). Correction and 

bias factors, as necessary, are applied in accordance with this document. 

For external doses based on dosimeter results (zero and non-zero), measured doses can be estimated 

more precisely than maximum doses. Because individual cycle data are not available for 1977 and 

before, missed external doses are estimated less precisely than the measured doses. Since some 

information is available (e.g., routine dosimeter exchange frequencies and minimum levels of 

detection for Mound dosimeters), missed external doses, though overestimated, are also estimated 

more precisely than maximum doses. Therefore, NIOSH can bound the dose with sufficient accuracy. 

7.3.4.2 Electron Dose 

Electron doses are reliably measured using the “open-window” portion of the Mound dosimeters. As 

stated above, the Mound radiation protection program did not record the measurement from this 

portion of the dosimeter prior to 1960. However, when darkening of the open-window portion of the 

film was noted, the site program began reading the affected films. Electron doses can be estimated 

more precisely than maximum doses in most years at Mound; however, for years when open-window 

doses were not read or recorded, sufficient information is available to estimate maximum doses to the 

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

accuracy. 

Electron missed doses are applied in accordance with the methodology defined in the technical 

information bulletin Interpretation of Dosimetry Data for Assignment of Shallow Dose (ORAUTOTIB-0017). 

70 of 95 
SEC-00090 12-19-07 Mound Plant 

7.3.4.3 Neutron Dose 

Neutron dose monitoring was identified as an area requiring improvement during operation of Dayton 

Units III and IV. When the polonium operation moved to the Mound site, neutron dose monitoring 

began after August 1949, though operations with polonium began in February of that year. The health 

physics program did not assume a need for neutron dosimetry prior to the beginning of dose 

monitoring in late 1949. Once begun, neutron dose monitoring with neutron-track emulsion was 

likely to measure the neutrons associated with the Po-Be sources with reasonable accuracy, based on 

the calibration protocol used. 

Unmonitored neutron doses may be bounded using neutron-to-photon ratios based on Mound data. 

NIOSH also has considerable Mound NTA processing data, which provides another option to validate 

the claimant favorability of the neutron dose calculated using the neutron-photon ratio and the 

measured photon dose. Mound data includes NTA calibration with the plutonium tetrafluoride source 

that likely provides a neutron spectrum most similar to the neutron spectra in Mound plutonium 

facilities. In addition, the earlier doses determined with NTA film, once corrected for energy response 

limitations (i.e., the fraction of the neutron spectrum that was not measured by the NTA), can be used 

as another method of validation. 

Calculation of missed neutron dose at Mound is more problematic than photon missed dose, which is 

also based on total annual doses through the year 1977. Claimant-favorable assumptions are used to 

overestimate the missed dose as with the photon dose; however, correction factors applied to the 

missed doses in accordance with the Mound Occupational External Dosimetry TBD result in a 

significant multiplication of the likely missed doses. For this reason, use of a neutron-to-photon ratio 

will likely result in a more reasonable estimate of neutron missed dose. 

Given the fact that reliably-measured photon doses are associated with Mound workers, NIOSH can 

bound the dose with sufficient accuracy. 

7.3.4.4 Unmonitored Individuals Working in Production Areas 

The requirement to wear external dosimeters at Mound was based on the areas an employee accessed. 

This policy is described at several points in the comprehensive history of the Mound site external dose 

monitoring program (Meyer, 1992). Since this is the case, it is unlikely that individuals routinely 

entered production areas without dosimeters. Some individuals were not routinely monitored for 

external dose; however, they were required to use a temporary or “visitor’s” badge upon entry to 

controlled areas. Discussion of the policies for distributing visitors’ badges is also present in the 

external dose history. Since all workers entering radiation-controlled areas were required to wear a 

dosimeter, it is certain that those receiving the highest dose were monitored. For unmonitored 

individuals, claimant-favorable assumptions for on-site ambient doses are applied as part of the 

estimate. 

Other information in routine health physics reports suggests that only some individuals were 

monitored for neutron dose. This policy may be based on dosimeters being assigned only to 

individuals working with neutron sources and initiators, and could result in unmonitored neutron dose 

from alpha-n reactions associated with Pu-238 and, possibly to a lesser degree, Po-210 in the major 

Mound processes. Because the workers who were monitored were the most highly-exposed, as well 

71 of 95 
SEC-00090 12-19-07 Mound Plant 

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

proportional dose from neutrons as described in Neutron Dose, Section 7.3.4.3. 

7.3.4.5 Medical X-ray 

In December 2003 and January 2004, an X-ray segregation project was conducted. Due to 

decomposition, it became necessary to segregate the decomposed X-ray film from the good film. The 

films which could not be interpreted and posed a health hazard to workers were segregated and 

destroyed. DOE Administrative Record Retention Schedule 21 Item 21.d provides for the immediate 

destruction of the decomposed film. (Long, 2007) 

In the absence of measurement data or other specific information, a claimant-favorable approach for 

organ doses for LAT view can be calculated by multiplying the entrance kerma for the PA view by a 

default value of 2.5 and using this value along with the ICRP (ICRP, 1982) tables to compute the 

appropriate organ dose. For evaluation purposes, X-ray doses are always considered acute with 

photon energies in the range of 30 to 250 keV. For actual dose calculations, a normal distribution 

with an uncertainty of +30% at the 99% confidence interval can be assumed. However, only the 

positive uncertainty should be used and a multiplier of 1.3 can be used to include uncertainty at the 

99% confidence interval. (ORAUT-TKBS-0016-3) 

Based on the information available to NIOSH, the medical X-ray dose for the class under evaluation 

can be reconstructed with sufficient accuracy. 

Missed Dose 

Calculation of missed external dose at Mound is problematic because only annual dose results are 

available, in almost all cases through the year 1977. For the year 1978 and after, actual zero and nonzero results are used. If cycle data are not available for the earlier period, then missed doses are 

necessarily overestimated. In most cases, annual total doses are assumed to have been received in a 

single cycle, and the balance of the results is assumed to be zero dosimeter results; monitoring 

frequency assumptions are based on Table 6-11 in the Mound Occupational External Dosimetry TBD, 

or assumed to be the maximum routine dosimeter exchange frequency. This is known to be an 

overestimating practice. Other cases may require less overestimating assumptions; however, for 

individual cases, the method of arriving at the assumed number of zero dosimeter results is explained 

in the dose reconstruction report. 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

NIOSH has established that it has access to sufficient information to: (1) estimate the maximum 

external radiation dose for every type of cancer for which radiation doses are reconstructed that could 

have been incurred under plausible circumstances by any member of the class; or (2) estimate the 

external radiation doses to members of the class more precisely than a maximum dose estimate. 

72 of 95 
SEC-00090 12-19-07 Mound Plant 

7.4 Evaluation of Petition Basis for SEC-00090 

The following subsections evaluate the assertions made on behalf of petition SEC-00090 for the 

Mound Site. 

The petitioner provided four affidavits, one from herself and three from former EEs. Two of 

the affidavits describe contamination in Building 61, a non-radiologically controlled building. 

The other two affidavits do not provide any supporting information regarding the petition. One 

affidavit is a work summary and the other is a copy of a letter sent to the petitioner from the 

U.S. Department of Labor in regard to her personal dose reconstruction. 

The petitioner provided an affidavit contending that contaminated items were moved to areas 

of Building 61, a non-radiological controlled area, for disposition to other government agencies 

and eventually to public sale and/or auction, and that the workers in Building 61 had no 

follow-up monitoring when the contaminated equipment was found. In addition, concern was 

raised about other incidents of radiological contamination continuing throughout the plant and 

that as many as one incident per week occurred after serious decommissioning work began. 

The petitioner contends that most of the incident critiques found violations of radiological 

procedures or lack of radiological control. 

SEC-00090: The last item in the petitioner affidavit states that many Mound records were 

shipped to Nevada for burial because it was decided that the monitoring and 

decontamination processes “were too costly to pursue”. The contents of the “records 

would provide valuable data regarding the change in Mound culture from Safety First to 

Cut Costs and Get Out”. 

A second affidavit provided by a former employee lists several points of concern, including a 

change in policy regarding the use of dosimeters and whole-body count requirement, incidents 

of contaminated material outside of radiological controlled areas, an employee with a full body 

burden as a result of an accident, reports of exposure to radioactive material and documents 

taken from Mound by an employee and the retrieval of these documents by Babcock and 

Wilcox. 

The petitioner also included a letter sent to the U.S. Department of Labor in response to the 

denial of her claim. Three discussion points, as paraphrased by NIOSH, included: 

1.	 Monitoring of potentially-radioactive material was done in a haphazard way and eventually 

monitoring of personnel via dosimeter, urinalysis, etc., was even more sporadic and 

eventually administratively denied to all except those employees chosen by Rad Control; 

2.	 Mound Plant Employee Health Records are not available. The records were removed from 

the Mound Plant in 2005 and buried at LANL without the knowledge and permission of the 

DOL due to radioactive contamination; 

3.	 Mound Plant Employee Health Records were removed from their storage site and kept in 

Building 61 prior to shipment. 

73 of 95 
SEC-00090 12-19-07 Mound Plant 

The letter, as written by the petitioner, can be found in petition SEC-00090 (OSA Ref ID: 

103188). 

SEC petitions 00090 and 00091 were merged. Both petitions listed concerns regarding records 

disposal at LANL and NTS. The History of Mound (Long, 2007) provides in-depth review of the 

records history and the records disposal at LANL and NTS. 

In November 1989, the U.S. Environmental Protection Agency (EPA) placed the Mound Site on the 

National Priorities List (CERCLIS No. OH6890008984). In 1993, DOE made a decision to close the 

Mound Site under the DOE Weapons Complex Reconfiguration Program. The reconfiguration was an 

effort to realign the weapons complex into a smaller, less-expensive operation. The realignment focus 

was to maintain the stockpile while retaining the required resources. Records generated in support of 

past missions were transferred to various receiver sites, or dispositioned per the National Archives and 

Records Administration (NARA)-approved retention schedules. Receiver sites include the Kansas 

City Plant, Savannah River Site, Los Alamos National Laboratory, Sandia National Laboratory, 

associated DOE Operations and Field Offices, the DOE Historian’s Office, and the Office of 

Scientific and Technical Information (OSTI). 

Mound Data Buried at the Nevada Test Site (NTS) 

There are 1,639 potentially-contaminated lab notebooks that were buried at NTS after they were 

electronically imaged using Image Alchemy Software. These lab notebooks were indexed as part of 

the Classified Document Consolidation Project (CDCP) to a Searchable Classified Records Database 

(SCRD). Emergency disposal approval was granted by NARA in August 1999. Images were 

transferred to CD-ROMs which then became the official record, and the contaminated notebooks were 

destroyed per an approved DOE method. 

Mound Data Buried at the Los Alamos National Laboratory (LANL) 

The issue of Mound records buried at LANL was a topic of discussion at the ABRWH meeting on 

February 7, 2007. Glen Podonsky of the Department of Energy participated in this discussion, as well 

as members of the Board. In the intervening months, NIOSH has interviewed individuals with direct 

knowledge of this issue, and reviewed all available pertinent documentation. 

There were 458 boxes of inactive classified contaminated and potentially-contaminated records 

shipped from Mound’s classified Long Term Storage facility and the T Building classified vault to 

LANL at the direction of DOE Albuquerque Weapons Quality Division and supported by 

DOE/MEMP. Copies of receipts for contaminated or potentially-contaminated records shipped to 

LANL in August 1995 were sent to DOE/MEMP. These boxes were never formally inventoried at 

folder or document level. They were not included in the tracking database because of the 

classification. This collection contains classified R&D notebooks created in the 1950s and 1960s, 

financial and program records including detonator assembly, acceptance, surveillance reports, and 

reservoir R&D and engineering reports. 

Forty-three of the 458 boxes were returned to Mound to support the Pre-1989 Dose Reconstruction 

Project being performed by MJW Corporation because it was believed that bioassay data were 

74 of 95 
SEC-00090 12-19-07 Mound Plant 

contained within them (see Section 7.1.1 for more details). The boxes contained photocopies, 

printouts, and excerpted or redacted formerly-classified laboratory notebooks. The record copies of 

the returned notebooks were scheduled, imaged, indexed with the Document Control classified 

collection, and included in the hard drive and CD shipments. Two sets of the hard drive and CDs 

were created; one set was sent to NNSA, and the second to OSTI in 2003. LANL was to image the 

remaining 415 boxes of contaminated, classified documents to make them available electronically. 

Per the Records Manager at the time, LANL never received the DOE funding to image the collection. 

In 2002, the DOE OFO General Counsel informed the BWXT Records Manager that LANL had 

requested approval to destroy the collection, but no further communication regarding the subject was 

located. DOE/LM recently received documentation validating the request and authorization for 

destruction of the collection. 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00090 

The following major topics were detailed in Petition SEC-00090. Italicized statements are from the 

petition; the comments that follow are from NIOSH. Please note that the petitioner made statements 

in the petition, attached a letter that was included in the petition, dated May 15, 2007, and provided an 

affidavit. All three of these comments made by the petitioner covered the same issues, but were 

worded differently. One wording was chosen to answer the issue of concern. 

7.4.1.1 Monitoring of Workers 

SEC-00090: Mound developed a culture of haphazard, administrate [sic] very controlled monitoring 

of workers with regard to the employee input. [Another similar statement was made in a letter dated 

May 15, 2007, and attached to the petition. It reads:] Monitoring of potentially radioactive materials 

and Mound Plant Employees was done in a haphazard way, with changing criteria almost daily. 

Monitoring of personnel via dosimeter, urinalysis, etc. was even more sporadic and eventually 

administratively denied to all except those employees chosen by “Rad Control”. In place 

Administrative Controls prohibited the collection of Radiological data for most all Mound employees. 

Historical documents exhibit an on-going program of evaluation and modification of the internal and 

external monitoring programs. Changes were made to the program based on changing workplace 

conditions and resulting changes in the character of the potential exposures. Changes were also made 

to take advantage of new technology in order to obtain more accurate measurements. Finally, changes 

were required over the years to ensure compliance with contractual radiation safety requirements and, 

later, with federal radiation safety regulations. Data are available in archived records and, in most 

cases, electronic databases containing transcription of the archived records. Information sources 

include film badge and TLD readings, air monitoring data, and results from bioassay programs, nose 

swipes, fecal analyses, whole-body counts, and chest counts. There have been concerns expressed by 

numerous former workers about whether the bioassay requirements matched the exposure potential to 

workers during the D&D era. In addition, there were several Price Anderson Act violations and fines 

during this period. NIOSH continues to investigate whether these occurrences compromise its ability 

to perform dose reconstructions with sufficient accuracy. 

7.4.1.2 Incident Occurrence and Reporting 

75 of 95 
 

SEC-00090 12-19-07 Mound Plant 

SEC-00090: Incident occurrence and critique reporting will show a pattern of one incident after 

another of radioactively contaminated materials in non-controlled areas for storage and shipment. 

Incidents at the Mound Site were reported in the Corrective Action Reporting System (CARS) and 

could potentially have been reported in the ORPS (DOE) system, as discussed in Section 5.4.5. 

Undetected or unmonitored intakes occur at many DOE facilities, and dose estimates can be 

completed using any number of methods. Estimates of the unmonitored dose can be made by using 

either co-worker data or by using the approximated recorded doses for a specific worker of interest 

occurring prior to or following a period of unmonitored dose. OCAS-PR-004 describes several 

different options for calculating unmonitored dose in various situations. A definitive intake date, 

while helpful, is not necessary for dose reconstruction. In cases where a definite intake date cannot be 

ascertained, claimant-favorable assumptions may be made in lieu of specific information. Claimantfavorable assumptions may include using the absorption type that results in the highest dose when the 

type associated with the intake is not known; use of an intake rate (acute or chronic) based on the 

higher dose; or assignment of an arbitrary date for an assumed acute intake based on a date that results 

in the maximum dose. 

7.4.1.3 Employees Prohibited from Receiving Monitoring 

SEC-00090: Employees working in non-controlled areas were prohibited from receiving monitoring. 

The basic principle of dose reconstruction is to characterize the occupational radiation environment to 

which a worker was exposed using available worker and/or workplace monitoring information. In 

cases where radiation exposures in the workplace environment cannot be fully characterized based on 

available data, default values based on reasonable, claimant-favorable scientific assumptions are used 

as substitutes. EEOICPA recognized that the process of estimating radiation doses would require 

dealing with uncertainties and limited data, and thus, methods were established for arriving at 

reasonable, claimant-favorable estimates of radiation dose received by an individual who was not 

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

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

uncertainties are typically handled to the advantage, rather than to the detriment, of the claimant. 

NIOSH has used the best available science to develop the methods and guidelines for dose 

reconstruction. 

For unmonitored individuals, on-site ambient doses or claimant-favorable dose estimates derived from 

co-worker dose distributions are assigned as appropriate. 

7.4.1.4 Mound Documentation 

SEC-00090: Mound Lab documentation was very closely guarded by management and procedure(s). 

They even went so far as to send Mound security to the home of [employee’s name removed] to 

retrieve documents that he took home in an attempt to provide himself defense in the case of future 

health issues. Therefore any documentation is only within Dept. of Energy Records. 

In an interview with the Records Manager at the time of this incident, she was told by the employee 

that he had taken records from the site to his home. The Records Manager told him that he needed to 

bring the records back to the site where he could copy them so he could take home the copies. After 

76 of 95 
SEC-00090 12-19-07 Mound Plant 

several days, he had not done this. At this time, the Records Manager reported the event to the 

company attorney who called Security and requested the dispatch of security personnel to the 

employee’s home to retrieve the records. This is not an SEC issue. 

77 of 95 
SEC-00090 12-19-07 Mound Plant 

7.4.1.5 Occurrence Reporting 

SEC-00090: The (DOE) (ORPS) Occurrence reporting and processing system will contain some 

historic data. It is of course “not” an open record. These records were removed from the Mound site 

to the desert due to being radioactive. 

Incidents at the Mound Site were reported in the Corrective Action Reporting System and could 

potentially have been reported in the ORPS (DOE) system. In addition, incident reports were filed 

with the employee dosimetry records. Regarding the buried records, refer to Section 7.4.1.7 for a 

complete discussion on the buried records. 

7.4.1.6 The “Rad” Database 

SEC-00090: The “rad” data base which did exist was not a well designed software and the integrity 

of the data that does exist has no value. 

The Mound Site has used several databases over the course of its history to record both internal and 

external employee doses. Databases such as PORECON and PURECON for internal exposures, and 

the External Exposure Analysis System (EXAS) and External Radiation Analysis Data (ERAD), were 

all merged into the Mound Environmental, Safety, and Health system (MESH) database as of 

September 1989. Data input to MESH is accomplished either via manual entry of data using 

application forms or via a number of automated data upload procedures within the application. MESH 

contains the following information: 

• Employee data (HR): 1944 - present (in various levels of detail) 

• External exposure data (ES&H): 1947 – present (in various levels of detail) 

• Internal exposure data (ES&H): 1946 – present (in various levels of detail) 

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

• Safety data (ES&H): 1979-2003 

• Environmental data (ES&H): 1992-1995 only 

See Section 6.0 for a full discussion on data integrity. 

7.4.1.7 Mound Plant Employee Health Records Removed to LANL 

SEC-00090: Mound Plant Employee Health Records are not available. These records were removed 

from the Mound Plant site in 2005 and buried in the Los Alamos, N.M. desert without the knowledge 

and permission of the Dept. of Labor (Energy Compensation Program) due to radioactive 

contamination. 

NIOSH and the ORAU Team have reviewed existing documentation relative to this concern, and 

interviewed three former workers involved with the records transfer to LANL. These workers include 

two former Mound Records Managers and a researcher who reviewed the records. In addition, 

NIOSH reviewed the Mound Records Transfer History (Long, 2007), which discusses the Mound 

Records Transfer History. Based on its investigation, NIOSH has determined that the records did not 

contain data related to employees’ health records that would prevent the reconstruction of doses with 

sufficient accuracy. 

78 of 95 
 

 

SEC-00090 12-19-07 Mound Plant 

From 1992-1995, as part of the Non-Nuclear Reconfiguration Project, all types of records were 

identified and shipped to six different DOE facilities/ Federal Records Centers. These records 

included classified, unclassified, active, and inactive records. In 1994, in preparation for the transfer 

of records, random sample radiation contamination surveys were performed on the inactive classified 

record collection located in the vault of the T-building at Mound. Some of these records were found 

to be contaminated with several different radionuclides. As a result, the entire collection in the T 

Building vault was declared contaminated and the vault subsequently designated as a Radiological 

Control Area. LANL ultimately agreed to accept the classified, contaminated records with the intent 

to image them, destroy the originals, and administer access to the imaged data. DOE Weapons 

Quality Division agreed and directed Mound to transfer the collection to LANL. Shipment occurred 

in 1995. LANL had planned to inventory the records upon their arrival because many of the boxes 

contained records supporting DOE nuclear production and would likely have been classified as DOE 

Schedule 3 (Nuclear Records). Based on the available information, NIOSH has found no evidence 

indicating that the collection contained primary, employee-specific dosimetry records. The original 

employee- specific health physics records were filed by employee name within the Mound 

Occupational Radiological Exposure (MORE) Records Center. 

In preparation for shipment, boxes from the T Building were brought to the entrance of the classified 

vault. The Records Manager at Mound identified the box contents from the affixed label and 

documented the contents on the Reconfiguration Records Transfer sheet. Each sheet represented a 

box and a copy of all completed Reconfiguration Records Transfer sheets were sent to LANL. 

Approximately 458 cubic feet of classified, contaminated records were shipped to LANL. Items in 

the boxes included production records for classified programs, industrial X-rays, classified material 

accounting, health physics log books and a substantial number of uniquely numbered research log 

books. The researcher’s laboratory notebooks were primarily filled in during the 1950s and 1960s. 

They are not believed to be the kind of files that would have recorded radiation exposure information 

in them, but instead, dealt with the details of their particular research project’s progress. (Long, 2007 

p. 164, 168) The Classified Document Control function maintained a file index that cross-referenced 

the employee name who received the log notebook. This file index was eventually scanned and is 

retrievable at OSTI. 

On May 13, 2003, LANL requested and received approval from NNSA/AL to destroy and dispose of 

(i.e., bury) the T Building collection. 

Laboratory notebooks were part of the burial that may have included information on personal 

dosimetry or bioassay results. The information in the notebooks is not believed to be the primary 

dosimetry information because all health physics-related information was kept in the MORE records 

database. Therefore, any included information would not be considered primary data. The buried 

data are not crucial to complete a dose reconstruction with sufficient accuracy. Bioassay and 

dosimetry records are routinely in the individual’s personal dosimetry file. MORE (established in the 

late 1980s) kept all employee-specific exposure records, radiological incident reports, and visitor 

exposure records. 

Approximately two years after the T Building collection was shipped to LANL (~1998), Mound 

contracted with MJW Corporation to perform a Pre-1989 Dose Reconstruction Project. A scientist 

from MJW Corporation went to LANL and reviewed a selection of the T Building records. The 

79 of 95 
SEC-00090 12-19-07 Mound Plant 

selected laboratory notebooks were thought to be potentially useful for the pre-1989 project. 

However, once the boxes were reviewed by the scientist, it was determined that bioassay data 

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

retrieved data were only used for cross-referencing existing data. As a result of the review, 43 boxes 

containing laboratory notebooks were returned from LANL to Mound for use in the dose 

reconstruction project. These boxes were incorporated into the A-basement classified scanning 

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

burial). 

In 1999, Mound Security began consolidating the classified repositories within the site as Mound 

began to work towards site closure. Eventually, all classified documents were moved to A-basement. 

The combined collections (now ~100,000 documents) were scanned using Image Alchemy software. 

Two sets of the hard drive and DVDs were created; one set was sent to NNSA/AL and the second set 

went to OSTI in 2003. 

After the Non-Nuclear Reconfiguration ended, all remaining unclassified records were transferred to 

the Dayton Federal Record Center. 

7.4.1.8 Mound Plant Employee Health Records Kept in Building 61 

SEC00090: Mound Plant Employee Health Records were removed from their storage site at Mound 

and kept in Building 61 prior to their shipment to the desert site. I was the Supervisor over the crews 

that were involved with the removal and shipments of these records (materials). These materials sat 

in Building 61 for a period of time prior to their shipment to Nevada. 

1,639 potentially-contaminated lab notebooks were buried at NTS after they were electronically 

imaged using Image Alchemy Software. These lab notebooks were indexed as part of the Classified 

Document Consolidation Project (CDCP) to a Searchable Classified Records Database (SCRD). 

Emergency disposal approval was granted by NARA in August 1999. Images were transferred to CDROMs which then became the official record, and the contaminated notebooks were destroyed per an 

approved DOE method. 

In the affidavit provided by the petitioner, she also states: Building 61 was a non radiological building 

controlled building [sic]. Dosimetry and other monitoring processes were systematically reduced and 

eventually eliminated for most employees stationed in this building. When contaminated equipment 

was discovered in this building, no follow-up monitoring was provided to employees working in the 

area. 

At the time of this writing, NIOSH has not yet been able to verify a contamination incident for 

Building 61 that would impact NIOSH’s ability to bound the dose for the proposed class. Attempts 

were made to contact the SEC-00090 petitioner. NIOSH was able to contact another person listed in 

Petition SEC-00091 to discuss this incident; however, this person could not remember the details or 

the approximate date of this issue. 

Air concentration measurements can be used to assign internal doses from radioactive material in the 

general environment, in accordance with the Mound Occupational Environmental Dose TBD 

(ORAUT-TKBS-0016-4), as discussed in Section 6.3 of this evaluation. While this is an important 

80 of 95 
 

 

SEC-00090 12-19-07 Mound Plant 

issue, NIOSH believes that this issue does not have SEC implications. NIOSH does not consider this 

exposure scenario an example of a maximum or bounding-exposure scenario. In the case of an 

unmonitored worker who had the potential for radiation exposure, NIOSH could provide a bounding 

dose estimate (i.e., assign dose based on the air sample data or based on the maximally-exposed, 

monitored worker groups) for the proposed worker class definition. 

7.4.2 Evaluation of Specific Petitioner Statements in SEC-00090 

This subsection presents specific affidavit statements made by workers on behalf of petition 

SEC-00090. The italicized statements are from the petition; the comments that follow are from 

NIOSH. 

7.4.2.1 Employee badges 

SEC-00090: 1) When I joined Mound in 1981all employees were give [sic] dosimeter badges. The 

badges were read on a periodic basis and all employees were also given a periodic whole body count. 

2) Shortly after Babcok [sic] and Wilcox assumed control of Mound they, as a cost savings effort, 

removed dosimeters from all personnel who did not immediately work in radiological areas. As an 

attempt to provide some minimal of [sic] radiological monitoring dosimeters were hung around the 

plant, but no effort was made to track or monitor the movement of individuals into those various 

areas, so any attempt to tie those reading to individuals was impossible. 3) If an employee made a 

special request for a dosimeter badge, it was denied out of hand, as an unnecessary expense. 

Historical documents exhibit an on-going program of evaluation and modification of the internal and 

external monitoring programs. Changes were made to the program based on changing workplace 

conditions and resulting changes in the character of the potential exposures. Changes were also made 

to take advantage of new technology in order to obtain more accurate measurements. Finally, changes 

were required over the years to ensure compliance with contractual radiation safety requirements and, 

later, with federal radiation safety regulations. Data are available in archived records and, in most 

cases, electronic databases containing transcription of the archived records. Information sources 

include film badge and TLD readings, air monitoring data, and results of bioassay programs, nose 

swipes, fecal analyses, whole-body counts, and chest counts. 

7.4.2.2 Contamination Incidents 

SEC-00090: I have specific recollection of several instances of radiological materials moving outside 

of the controlled areas. In one instance contaminated computers were moved through Building 61 

and actually sold on the public market only to have Mound personnel have to go into the buyer’s 

warehouse and recover those computers after they had left the Mound site. In addition, I have a 

specific recollection of handling an incident report where a worker in the dosimeter processing lab 

was contaminated by radiological material that accidentally got into her lab. 

Although no specifics are given in this example, it is clear that contamination incidents occurred 

throughout the operating history of Mound. It has been demonstrated that the doses resulting from 

such incidents can be estimated. Doses from internally-deposited radionuclides are estimated from 

bioassay results, and external doses are measured using film badges or TLDs. While this is an 

important issue, NIOSH believes that such issues do not have SEC implications. In the case of an 

81 of 95 
SEC-00090 12-19-07 Mound Plant 

unmonitored worker who had the potential for radiation exposure, NIOSH could estimate 

unmonitored dose based on co-worker data. This does not prevent NIOSH from bounding the dose 

for the proposed class. 

7.4.2.3 Plutonium through Ventilation Ducts 

SEC-00090: [Employee name removed], now deceased, told me that he had a full body burden as a 

result of an accident where a failure to properly control radiological material allowed plutonium to 

move through ventilation ducts and into his office, contaminating him. He also told me of one 

particularly hot area where he worked where the dosimeter badges were always completely exposed. 

No effort was ever made to determine of [sic] the badges were just barely fully exposed or if they had 

been exposed to ten times the radiation necessary to fully expose the film. He went on to relate that 

despite his complaints, management never made any effort to adjust the dosimeter reading schedule 

or to determine by other means the actual exposure. 

There were certainly incidents throughout the operational history of Mound. However, the occurrence 

of such incidents does not prevent NIOSH from conducting dose reconstructions of sufficient 

accuracy. Film badge dosimeters in use at the Mound site contained both a sensitive and an 

insensitive element. Occupational-range measurements were made on the sensitive element, and the 

insensitive element had a much higher-response range. It is unlikely that any occupational exposure at 

Mound would fully expose the insensitive element. On the other hand, neutron film emulsions, which 

measure neutron doses by accumulating damage tracks, can also be darkened by gamma radiation to 

the extent that the damage tracks are difficult to read. When this occurs, the dose is very likely to be 

estimated by the health physics program personnel; for any such occurrence in the record, the neutron 

dose may be estimated by a proportional neutron dose based on the recorded photon dose. 

7.4.2.4 Reports 

SEC-00090: As a quality engineer and a member of the Mound audit staff, I constantly handled 

reports relating to people being exposed to radioactive materials because of system and management 

failures. Through I do not have any specific details, all these reports were carefully submitted to the 

Department of Energy and, in theory, corrective actions were taken, but exposure incidents were a 

constant occurrence. 

Although no specifics were given in this example, incidents did occur throughout the operating history 

of Mound. It has been demonstrated that the doses resulting from such incidents can be estimated. 

Doses from internally-deposited radionuclides are estimated from bioassay results, and external doses 

are measured using film badges or TLDs. While this is an important issue, such issues do not have 

SEC implications. In the case of an unmonitored worker who had the potential for radiation exposure, 

NIOSH could estimate unmonitored doses. This does not prevent NIOSH from bounding the dose for 

the proposed class. 

82 of 95 
 

SEC-00090 12-19-07 Mound Plant 

7.4.2.5 Documents taken from Mound 

SEC-00090: I am intimately familiar with the story of the documents that [employee name removed] 

took from Mound and that Babcock and Wilcox so desperately wanted to recover, as those documents 

were stored, for some period, in my basement because of [employee name removed] concerns about 

how Babcock and Wilcox would react to those documents, which clearly demonstrated their 

mis-management would be perceived and received by responsible regulatory authority. 

In an interview with the Records Manager at the time of this incident, she was told by the employee 

that he had taken records from the site to his home. The Records Manager told him that he needed to 

bring the records back to the site where he could copy them and take home the copies. After several 

days, he had not done this. At this time, the Records Manager reported the event to the company 

attorney who called Security and requested the dispatch of security personnel to the employee’s home 

to retrieve the records. This is not an SEC issue. 

7.4.3 Evaluation of General Concerns 

7.4.3.1 Various Contamination Incidents 

SEC-00091 presented a list of general statements by a former worker. She listed many concerns 

which included: use of special clothing while mixing MOCA and not always wearing a radiation 

badge, repeated showering, work with Be, travel from building to building for different jobs, death of 

a young man from radiation in the T Building in the medical facility, persistent contamination in her 

hair, radiation in her right arm so she could not touch her husband for three weeks, chemical storage 

areas, and a resume of some of her job duties. 

The substance MOCA is a polyurethane elastomer used in fabricating weapons components and is not 

a radioactive material. Personnel working with non-radioactive weapons components (sometimes 

called “small parts workers”) were often not monitored for radiation dose due to the lack of radiation 

fields in these workplaces. Although no specifics are given in this example, it is clear that 

contamination incidents occurred throughout the operating history of Mound. It has been 

demonstrated that the doses resulting from such incidents can be estimated. Doses from internallydeposited radionuclides are estimated from bioassay results, and external doses are measured using 

film badges or TLDs. While this is an important issue, such issues do not have SEC implications. In 

the case of an unmonitored worker who had the potential for radiation exposure, NIOSH can estimate 

unmonitored dose based on co-worker data. Regarding the concern about a young man who died from 

radiation in the T Building, current research has not, to date, resulted in the discovery of a record of 

such an incident. 

Approximately 400 NOCTS files were reviewed for incident reports. Approximately one-third of the 

files contained incident reports describing the incident, the date of the incident, and what measures 

were taken (e.g., nose swipe, urine samples). The bioassay results are also found in the individual 

employee’s file. The dates of the incidents spanned the entire period under evaluation and included 

spills, contamination of personnel and equipment, glovebox issues, and elevated air samples. 

83 of 95 
SEC-00090 12-19-07 Mound Plant 

7.4.3.2 Inadequate Monitoring and Protection 

The SEC-00091 petitioner presented several non-specific concerns, including inadequately monitored 

and inadequately protected radiation workers, large quantities of several radionuclides that were 

processed without engineering controls or protection as would be expected by today’s standards, 

non-uniformity of radiation monitoring, manufacture of Po-Be neutrons, and research and 

development of radionuclides, including Ra-226, Ac-227, Th-228, Th-230, Pa-231, and U-233. The 

claimant clearly states that these comments can be referred to as radiation exposures and radiation 

doses were not monitored, either through personal monitoring or through area monitoring. 

NIOSH is aware that the engineering controls of the past can be quite different from the standards of 

today. In addition, NIOSH is aware of the processes that occurred at Mound during its operational 

history and can estimate doses based on internally-deposited radionuclides from bioassay results. The 

other radionuclides, as mentioned above, have been discussed in Section 6.1. 

7.4.3.3 Actinium-227 Urine Samples 

During interviews with former Mound workers, a concern was raised regarding Ac-227 urine bioassay 

samples collected from employees involved in a 1991 R-Building Corridor 5 D&D job. These 

samples were not analyzed for a number of years, and there were apparently quality control issues 

with them once they were analyzed. This situation resulted in Price-Anderson Act violations (PAAA, 

2006). NIOSH is continuing to investigate this issue for impact on our ability to conduct dose 

reconstructions with sufficient accuracy for this situation. 

7.4.3.4 Neutrons 

The workers associated with polonium research and neutron source production during the very early 

years of Monsanto (1943-1949) were not monitored for neutrons. SEC-00049 qualified as a Special 

Exposure Cohort based on insufficient data available to support internal dose construction. 

The potential for exposure to neutrons existed for workers during the early years of Mound, and 

personal monitoring for neutrons started in September 1949 (Meyer, 1994; ORAUT-TKBS-0016-6). 

NIOSH can now estimate the potential neutron exposures with sufficient accuracy. The 

Documentation of Variables in the Assessment of Neutron Doses at Mound Laboratory (Variables, 

1977), discusses track fading and NTA film sensitivity to low-energy neutrons. According to that 

document: 

Prior to the production of Radioisotopic Thermoelectric Generators (RTG) at Mound Laboratory, 

polonium-beryllium (PoBe) neutron sources were used for film calibration. The energy spectrum 

from these neutron sources, having an average energy of about 4.5 MeV, corresponded to the 

spectrum of neutrons in the radiation areas. (Variables, 1977, pdf page 3). 

84 of 95 
 

SEC-00090 12-19-07 Mound Plant 

In addition, the document goes on to say: 

Since track fading is of significance in deriving dose determinations for personnel working in our 

areas with low energy neutron spectrums, calibration procedures utilizing the PuF4 sources were 

devised to incorporate corrections for track fading. Dosimeter badges of personnel have always 

been exchanged on varying frequencies based on the employee’s degree of involvement and 

potential exposure. Exchanges have been made for periods of one or more days, one week, two 

weeks, and four weeks. Predominantly, most badges are routinely exchanged on either a two week 

or four week basis. The calibration procedure involves the exposure of film in badges to determine 

film response to known exposure for any increment of time up to four weeks. Each calibration 

exercise involves exposing different sets of badges to the same total dose, but at different rates 

over a four week period. All badges are processed at the same time on the Monday following the 

four week period. We typically expose 5 sets of badges to total dose of 1.0 rem. The badges, 

assuming we expose all to 1.0 rem, are exposed as follows: 

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

Set 2 - Exposed to 333 rem per week for 3 consecutive weeks prior to process date 

Set 3 - Exposed to 500 rem per week for 2 consecutive weeks prior to process date 

Set 4 - Exposed to 1.0 rem during the week prior to the process date. 

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

The response for each batch in tracks is plotted versus time and appropriate factors derived for 

dose evaluation for any segment of time up to four weeks. In routine operations, the assumption is 

made that exposures have been uniformly received by the employee during the time period the 

badge was worn. Health Physics survey groups closely review scheduled operations for nonroutine special operational activities. Personnel performing special operations are monitored with 

badges for the exact period of the activity and appropriate factors are used for evaluating dose 

received. (Variables, 1977, pdf pages 5-6) 

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

issues at Mound. 

7.4.3.5 D&D Era Bioassay 

There have been concerns expressed by numerous former workers about whether the bioassay 

requirements matched the exposure potential to workers during the D&D era. In addition, there were 

several Price Anderson Act violations and fines during this period. NIOSH continues to investigate 

whether these occurrences compromise its ability to perform dose reconstructions with sufficient 

accuracy. 

85 of 95 
 

 

 

 

 

 

 

 

SEC-00090 12-19-07 Mound Plant 

7.5 Summary of Feasibility Findings for Petition SEC-00090 

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

Plant from February 1, 1949 through August 17, 2007. NIOSH found that the available monitoring 

records, process descriptions and source term data available are sufficient to complete dose 

reconstructions for the proposed class of employees, with the exceptions listed below. 

Table 7-3 summarizes the results of the feasibility findings at the Mount Plant for each exposure 

source during the time period February 1, 1949 through August 17, 2007. 

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

February 1, 1949 through August 17, 2007 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal 1 

Actinium-227 X (Mar 1, 1959 – Aug 17, 2007) X (Oct 1,1949 – Feb 28, 1959) 2

 Americium-241 x 

 Curium-244 x 

 Plutonium-238 x 

 Plutonium-239 x 

 Plutonium-240 x 

 Polonium-210 x 

 Protactinium- 241 x 

 Radium-223 x 

 Radium-224 x 

Radium-226 X (Mar 1, 1959 – Aug 17, 2007) X (Oct 1,1949 – Feb 28, 1959) 2

 Radon-220 x

 Radon-222 x 

Thorium-228 X (Mar 1, 1959 – Aug 17, 2007) X (Oct 1,1949 – Feb 28, 1959) 2

 Thorium-230 x

 Thorium-232 x

 Uranium-233 x

 Uranium-234 x

 Uranium-235 x

 Uranium-238 x 

External 

 - Gamma x 

 - Beta x 

 - Neutron x 

 - Occupational Medical x-ray x 1 “Internal” includes an evaluation of urinalysis (in vitro), airborne dust, and lung (in vivo) data
 2

 K-65 sludge (the source of Ac-227, Ra-226, and Th-228 concerns) did not arrive on site until October 1949; therefore, 

these radionuclides are not relevant from the beginning of the evaluation period (February 1, 1949) until October, 1949. 

The related area of work was decontaminated and decommissioned on February 28, 1959; sufficient monitoring was in
 

place from that time forward. 

As of December 6, 2007, a total of 491 claims have been submitted to NIOSH for individuals who 

worked at Mound and are covered by the proposed class definition evaluated in this report. Dose 

reconstructions have been completed for 348 of those individuals (71%). 

86 of 95 
SEC-00090 12-19-07 Mound Plant 

8.0 Evaluation of Health Endangerment for Petition SEC-00090 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has insufficient information regarding internal Ra-Ac-Th exposures at Mound from the arrival 

of K-65 sludge in October 1949 through February 28, 1959, when the related area of work was 

decontaminated and decommissioned and sufficient monitoring was in place. NIOSH’s evaluation 

determined that it is not feasible to estimate radiation dose for members of the proposed class with 

sufficient accuracy based on the sum of information available from available resources. Modification 

of the class definition regarding health endangerment and minimum required employment periods, 

therefore, is required. 

9.0 NIOSH-Proposed Class for Petition SEC-00090 

Based on its research, NIOSH reduced the petitioner-requested class to define a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all employees of the Department of Energy (DOE), its predecessor agencies, 

and DOE contractors and subcontractors, who were monitored or should have been monitored, for 

internal Ra-Ac-Th exposures while working in all areas of the Mound site for a number of work days 

aggregating at least 250 work days from October 1, 1949 through February 28, 1959, or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB) and 

several Mound databases, for information relevant to SEC-00090. In addition, NIOSH reviewed its 

NOCTS dose reconstruction database to identify EEOICPA-related dose reconstructions that might 

provide information relevant to the petition evaluation. 

87 of 95 
SEC-00090 12-19-07 Mound Plant 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH has complied with these standards of 

performance in determining that it would be feasible to reconstruct the dose for the class proposed in 

this petition. 

88 of 95 
SEC-00090 12-19-07 Mound Plant 

This page intentionally left blank 

89 of 95 
SEC-00090 12-19-07 Mound Plant 

10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

OCAS-IG-001, External Dose Reconstruction Guideline, Rev. 2; National Institute for Occupational 

Safety and Health (NIOSH); Cincinnati, Ohio; August 25, 2006; SRDB Ref ID: 29929 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

ORAUT-OTIB-0002, Maximum Internal Dose Estimates for Certain DOE Complex Claims, Rev. 02; 

Oak Ridge Associated Universities; February 7, 2007; SRDB Ref ID: 29947 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities; December 21, 2005; SRDB Ref ID: 

20220 

ORAUT-OTIB-0017, Interpretation of Dosimetry Data for Assignment of Shallow Dose, Rev. 01; 

Oak Ridge Associated Universities; October 11, 2005; SRDB Ref ID: 19434 

ORAUT-OTIB-0018, Internal Dose Overestimates for Facilities with Air Sampling Programs, Rev. 

01; Oak Ridge Associated Universities; August 9, 2005; SRDB Ref ID: 19436 

ORAUT-OTIB-0049, Estimating Doses for Plutonium Strongly Retained in the Lung, Rev. 00; Oak 

Ridge Associated Universities; February 6, 2007; SRDB Ref ID: 29975 

ORAUT-OTIB-0060, Internal Dose Reconstruction, Rev. 00, Oak Ridge Associated Universities; 

February 6, 2007, SRDB Ref ID: 29984 

ORAUT-OTIB-0061, Internal Dosimetry Coworker Data for the Mound Site, Rev. 00, Oak Ridge 

Associated Universities; June 22, 2007; SRDB Ref ID: 32524 

90 of 95 
SEC-00090 12-19-07 Mound Plant 

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Rev. 00; Oak 

Ridge Associated Universities; April 26, 2007; SRDB Ref ID: 31421 

ORAUT-PROC-0006, External Dose Reconstruction, Attachment A; Rev. 0, Oak Ridge Associated 

Universities; June, 27, 2003; SRDB Ref ID: 20211 

ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Rev. 01; 

Oak Ridge Associated Universities; June 28, 2006; SRDB Ref ID: 29986 

ORAUT-PROC-0061, Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 01; Oak Ridge 

Associated Universities; July 21, 2006; SRDB Ref ID: 29987 

ORAUT-TKBS-0003, Technical Basis Document for the Savannah River Site, Rev. 01, Oak Ridge 

Associated Universities; August 21, 2003; SRDB Ref ID: 20178 

ORAUT-TKBS-0016-1, Technical Basis Document for the Mound Site – Introduction, Rev. 00; Oak 

Ridge Associated Universities; September 9, 2004; SRDB Ref ID: 19784 

ORAUT-TKBS-0016-2, Technical Basis Document for the Mound Site – Site Description, Rev. 00 

PC-1; Oak Ridge Associated Universities; July 7, 2006; SRDB Ref ID: 30057 

ORAUT-TKBS-0016-3, Technical Basis Document for the Mound Site – Occupational Medical Dose, 

Rev. 01 PC-2; Oak Ridge Associated Universities; March 31, 2006; SRDB Ref ID: 30059 

ORAUT-TKBS-0016-4, Technical Basis Document for the Mound Site – Occupational Environmental 

Dose, Rev. 00; Oak Ridge Associated Universities; October 6, 2004; SRDB Ref ID: 19789 

ORAUT-TKBS-0016-5, Technical Basis Document for the Mound Site – Occupational Internal 

Dosimetry, Rev. 00; Oak Ridge Associated Universities; September 9, 2004; SRDB Ref ID: 19790 

ORAUT-TKBS-0016-6, Technical Basis Document for the Mound Site – Occupational External 

Dosimetry, Rev. 00; Oak Ridge Associated Universities; August 11, 2004; SRDB Ref ID: 19791 

ORAUT-TRNG-0051, Dose Reconstruction Training, Rev. 03; Oak Ridge Associated Universities; 

March 1, 2007; SRDB Ref ID: Not currently in SRDB 

Ac-227, 1952, Report for Research on Substitute Materials, October 1, 1951 to December 31, 1951 

(Actinium-227), Mound Laboratory; MLM- 650; February 4, 1952; SRDB Ref ID: 24671 

Bismuth, 1952, Bismuth Recovery Process, Engineering Research Final Report; Mound Laboratory; 

MLM-734, August 5, 1952; SRDB Ref ID: Not currently in SRDB 

BWXT, 2000, Radon Study Summary Report; 2000; Document search underway; SRDB Ref ID: Not 

currently in SRDB 

Decon, 1951, Decontamination of Process Waste Solutions Containing Fission Products by 

Adsorption and Coprecipitation Methods (Information Report), Mound Laboratory; C. S. Lowe, et al.; 

MLM-621; November 13, 1951; SRDB Ref ID: 24668 

91 of 95 
SEC-00090 12-19-07 Mound Plant 

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

of Energy; Washington, D.C.; SRDB Ref ID: 8073 

Evaluation, 1970, Evaluation of Accidental Personnel Exposures to Plutonium-238: Whole Body 

Counting and Bioassay Results, H. F. Anderson; W. E. Sheehan; J. R. Mann; R. W. Bistline; Health 

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

Guido, J., 2003, Response to Beverly Long Concerning A Response To NIOSH Request for 

Additional Personnel Exposure Information and personnel communication with Wes Proctor, May, 

2004; SRDB Ref ID: Not currently in SRDB 

ICRP, 1959, Recommendations of the International Commission on Radiological Protection, 

Publication 2; International Commission for Radiological Protection; Pergamon Press; Oxford, 

England; SRDB Ref ID: 11106 

ICRP, 1975, Report of the Task Group on Reference Man, Publication 23, International Commission 

for Radiological Protection; Pergamon Press; Oxford, England; 1975: SRDB Ref ID: 22735 

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

Commission for Radiological Protection; Pergamon Press; Oxford, England; 1982: SRDB Ref ID: 

22733 

ICRP, 1987, Lung Cancer Risk from Indoor Exposure to Radon Daughters, Publication 50, 

International Commission for Radiological Protection; Pergamon Press; Oxford, England; Commonly 

available 

Incident Reports, 1973-81, Monsanto Research Corporation; SRDB Ref ID: 25502 

King, 1995, Mound Site Radionuclides by Location, W. King; MD-22153 Issue 1; U.S. Department of 

Energy; Miamisburg, Ohio; 1995; SRDB Ref ID: 3240 

Kirby, 1952, Tentative Procedure for the Analysis of Mixtures Containing Radium-226, Actinium-227 

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

Laboratory, Miamisburg, Ohio; 1952; SRDB Ref ID: 1962, page 512. 

Kirby, 1954, Determination of Radium-226, Actinium-227 and Thorium-228 in Human Urine (Ad 

Interim Report), H. W. Kirby and R. M. Brodbeck; AEC Research and Development Report 

MLM-1003; Mound Laboratory; Miamisburg, Ohio; 1954; SRDB Ref ID: 1962, page 522 

Kirby, 1959, The Radiochemistry of Protactinium, H. W. Kirby; U.S. Energy Commission Report 

NAS-NS 3016; Subcommittee on Radiochemistry; National Academy of Sciences-National Research 

Council; Washington, D.C.; December, 1959; Commonly available 

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

Meyer, 1992, History of Mound Bioassay Programs, H. E. Meyer; MLM-MV-93-93-0003; EG&G 

Mound Applied Technologies; Miamisburg, Ohio; 1992; SRDB Ref ID: 1962 

92 of 95 
SEC-00090 12-19-07 Mound Plant 

Meyer, 1994, History of Personnel External Dosimetry Program at the Dayton Project and Mound 

Laboratory 1946-1993; H. E. Meyer; Mound Laboratory; SRDB Ref IDs: 3268, 3276, 3281, 3297, 

3299, 3303, 3315 

Meyer and Reeder, 1992, Plutonium Historical Dose Reconstruction Program, Herbert E. Meyer and 

Dianne L. Reeder; Mound Laboratory; July 31, 1992; SRDB Ref ID: Not currently in SRDB 

Meyer, date unknown, Enclosure #6: Thorium 232 - Mound Facility, by H. E. Meyer; Mound 

Laboratory; historical overview; date unknown; SRDB Ref ID: 12700 

MJW, 1998, Pre-1989 Dose Assessment Project, Phase I Interim Report, Volume I; MJW 

Corporation, Inc.; June 15, 1998; SRDB Ref ID: 8667 

MJW, 2002, Phase I, Pre-1989 Dose Assessment Project, Phase I Final Report, Volume I; MJW 

Corporation, Inc.; April 2002; SRDB Ref ID: 8745 

MJW, 2002, Phase II, Pre-1989 Dose Assessment Project, Phase II Final Report, MJW Corporation, 

Inc.; June, 2002; SRDB Ref ID: 8738 

Monex, 1955, Development of the Monex Thorium Refining Process through the Pilot Plant Stage, 

Final Report, by F. C. Mead, et al.; MLN-1072; Mound Laboratory; December 31, 1955; SRDB Ref 

ID: 12798 

Mound, 1999, Work Plan for Environmental Restoration of the DOE Mound Site, The Mound 2000 

Approach, Final, Rev. 0; Feb 1999; SRDB 12624 

Mound, 2002, Mound External Dosimetry Data, Cincinnati Operations Center Terminal Server, 

O:\DOE Site Images\Mound\07-25-03-Data Capture\010000993.pdf, downloaded September 9, 2003, 

ORAU Cincinnati Operations Center, Cincinnati, Ohio. 

Mound Laboratory, 1968, Bioassay Group Analytical Procedures, Technical Manual MD, Issue 1 

(TM-20736); Miamisburg, Ohio; 1968; SRDB Ref ID: 4097 

Mound Laboratory, 1981, Tritium in Water, Technical Manual PD-80030, Issue 1 (TM-80030), 

Environmental Analytical Procedures; Miamisburg, Ohio; 1981; SRDB Ref ID: 1962, page 688 

Mound Laboratory, 1996, Internal Dosimetry Technical Basis Manual-Appendix D, Technical Manual 

MD-10435, Issue 4, (TM-10435), Miamisburg, Ohio; 1996; SRDB Ref ID: 2537 

Mound Po, various dates, Information File #2: Misc. Po-210 Documents; various authors; various 

dates; Mound Laboratory; SRDB Ref ID: 8746 

NBS, 1953, Maximum Permissible Amounts of Radioisotopes in the Human Body and Maximum 

Permissible Concentrations in Air and Water, Handbook 52; National Bureau of Standards; U.S. 

Department of Commerce, Washington, D.C.; SRDB Ref ID: 12332 

93 of 95 
SEC-00090 12-19-07 Mound Plant 

Neutron, 2001, Validation of Personnel Neutron Dosimeters in the Workplace at Mound, R. I. 

Scherpelz, et al; Pacific Northwest National Laboratory; PNWD-3118; September, 2001; SRDB Ref 

ID: 35720 

ORAU, 2003a, Processes and Characteristics of Major Isotopes Handled at Mound, ORAU file 

locator, DOE Site Images, Mound Laboratory, Data Capture 11-18-03, Folder 2311, pp. 65-126; Oak 

Ridge Associated Universities for NIOSH Office of Compensation Analysis and Support; Cincinnati, 

Ohio; SRDB Ref ID: 12328 

ORAU, 2003b, Appendix A: Detectable Amounts for Urinalysis, ORAU file locator, DOE Site 

Images, Mound Laboratory, Data Capture 11-18-03, Folder 2311, p.1; Oak Ridge Associated 

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

ID: 8641 pg 2 

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

Laboratory, Data Capture 11-18-03, Folder 2311; Oak Ridge Associated Universities for NIOSH 

Office of Compensation Analysis and Support; Cincinnati, Ohio; SRDB Ref ID: 8641 

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

Laboratory, Data Capture 09-24-03, Folder 1805; Oak Ridge Associated Universities for NIOSH 

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

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

Images, Mound Laboratory, Data Capture 09-24-03, Folder 1806; Oak Ridge Associated Universities 

for NIOSH Office of Compensation Analysis and Support; Cincinnati, Ohio; SRDB Ref ID: 8757 

PAAA, 2006, Price Anderson Amendments Act (PAAA) Documents Regarding Fines Levied Against 

Mound from 1990 to Present, Department of Energy, Office of Legacy Management; SRDB Ref ID: 

37733 

Personal Communication, 2007, ORAU interview with Joyce Massie, S. M. Stoller Corporation, 

October 25, 2007; SRDB Ref ID: 37339 

Polonium, 1956, Polonium, book by H. V. Moyer of The Ohio State University for the U. S. Atomic 

Energy Commission; July 1956; SRDB Ref ID: 12703 

Spitz, 1989, Retrospective Analysis of Polonium-210 Urinalysis Data Collected as Part of a Routine 

Occupational Monitoring Program Between 1943 and 1965, H. B. Spitz; Quality Assurance Report; 

EG&G, Mound Technologies, Radiological Science; Miamisburg, Ohio; February 28, 1989; SRDB 

Ref ID: Not currently in SRDB 

Ten-Year Plan, 1977, Ten-Year Plan for Decontamination and Decommissioning for Mound 

Laboratory, Sam S. Freeman; Monsanto Research Corporation; MLM-MU-77-66-0001; June 30, 

1977; SRDB Ref ID: 33360 

UNC Geotech, 1990, DOE Indoor Radon Study, Office of Projects and Facilities Management, UNC 

Geotech; Grand Junction, Colorado; April 12, 1990; SRDB Ref ID: 13191 

94 of 95 
SEC-00090 12-19-07 Mound Plant 

Variables, 1977, Documentation of Variables in the Assessment of Neutron Doses at Mound 

Laboratory, W. A. Bigler; Mound Laboratory; June 17, 1977; SRDB Ref ID: 3144 

White Paper T, 2002, T Building Structural History and Process History Summary Background 

Document (unpublished) BWXT of Ohio, November 2002; SRDB Ref ID: 25941 

Yt-90, Preparation of Carrier-Free Yttrium-90, Document search underway; SRDB Ref ID: Not 

currently in SRDB 

95 of 95