PETITION SEC-00256, Pinellas Plant

SPECIAL EXPOSURE COHORT (SEC) 

PETITION EVALUATION REPORT (ER)

Aerial photo of the Pinellas Plant [Gueretta 2015]
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SPECIAL EXPOSURE COHORT PETITION EVALUATION REPORT

Petition SEC-00256

Report Rev Number: 0 

Report Submittal Date: October 13, 2021

Subject Expert(s): Joseph Guido, Roger Halsey, Monica HarrisonMaples, Toshihide Ushino 

Site Expert(s): N/A

Oak Ridge Associated Universities 

Team (ORAUT)

– Lead Technical Evaluator: Monica Harrison-Maples 

– Peer Review Completed By: Pat McCloskey, CHP

Division of Compensation Analysis 

and Support (DCAS)

National Institute for Occupational 

Safety and Health (NIOSH)

– Peer Review Completed By: [Signature on File] 

Megan Lobaugh, Ph.D., CHP

October 13, 2021

– SEC Petition Evaluation

Reviewed By:

[Signature on File]

Timothy Taulbee, Ph.D., CHP

October 13, 2021 

– SEC Petition Evaluation

Reviewed By:

[Signature on File]

Grady Calhoun, CHP

October 13, 2021
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EVALUATION REPORT SUMMARY

Petition under Evaluation

Petition Number: SEC-00256

Petition Type: 83.13

Petition Receipt Date(s): December 16, 2019; May 20, 2020; August 17, 2020

Qualification Date: October 20, 2020

DOE Facility Name: Pinellas Plant

Petition Class

Petitioner-Requested Class

Definition:

All employees who worked in any area of the Pinellas 

Plant in Largo, Florida from January 1957 through 

December 1997 (August 17, 2020 version). 

Class Defined by NIOSH for 

Further Evaluation:

All employees of the Department of Energy, its 

predecessor agencies, and their contractors and 

subcontractors who worked at the Pinellas Plant in 

Clearwater, Florida for the period from January 1, 1957 

through December 31, 1990.

NIOSH-Proposed Class to be 

Added to the SEC: 

None 

Related Petition Summary Information

SEC Petition Tracking 

Number(s) and Type(s):

SEC-00111 (83.13), SEC-00130 (83.13), SEC-00176 (83.13), 

SEC-00184 (83.13), SEC-00231 (83.13), SEC-00233 (83.13), 

and SEC-00242 (83.13)

DOE/AWE Facility Name(s): Pinellas Plant

Petition Status(s): SEC-00111, SEC-00130, SEC-00176, SEC-00184, SEC00231, SEC-00233, and SEC-00242 - Petitions did not 

qualify for evaluation

Related Evaluation Report Information

Report Title(s) and 

DOE/AWE Facility Name(s):

N/A
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EVALUATION REPORT SUMMARY: SEC-00256, PINELLAS PLANT

The National Institute for Occupational Safety and Health (NIOSH) prepared this 

evaluation report in response to a petition to add a class of workers at the Pinellas Plant

to the Special Exposure Cohort (SEC). The Energy Employees Occupational Illness 

Compensation Program Act of 2000, as amended, 42 United States Code (U.S.C.) Section

7384 et seq. (EEOICPA) and 42 Code of Federal Regulations (C.F.R.) Part 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 [42 C.F.R. 83,

2018], describe the process for adding classes of workers to the SEC. 

Petitioner-Requested Class Definition

NIOSH received the original SEC-00256 petition on December 16, 2019. The petitioners 

revised the petitioner-requested SEC class definition twice, following discussions during 

consultation calls. The original petition (December 16, 2019 version) requested that 

NIOSH consider the following class: Employees of the Department of Energy (DOE), DOE 

contractors and/or subcontractors who were employed by General Electric Neutron 

Devices including all names of this company listed in Part C, Martin Marietta Specialty 

Components, and/or Lockheed-Martin Specialty Components, Inc. (also known as the 

Pinellas Plant) during the period from August 1957 through December 1997. In addition, 

the petition submission included employment dates relevant to the petition as 

September 4, 1956 to May 19, 1957 at the Temporary Plant and May 19, 1957 to 

December 1997 at Pinellas Plant [[redacted] 2019].

The revised petition (May 20, 2020 version) included a narrative providing justification for 

including the “Temporary Plant,” a transitional facility in St. Petersburg, Florida, and 

extending the covered period. This petition requested the following class: Employees of 

the Department of Energy (DOE), DOE contractors and/or subcontractors who were 

employed by General Electric Neutron Devices including all names of this company listed 

in Part C, Martin Marietta Specialty Components, and/or Lockheed-Martin Specialty 

Components, Inc. (also known as the Pinellas Plant) during the period from June 1956 

through December 1997 [[redacted] 2020a]. 

NIOSH received a final revised petition (August 17, 2020 version) and qualified it for 

further evaluation on October 20, 2020. The petitioner requested that NIOSH consider 

the following class: Employees of the Department of Energy (DOE), DOE contractors 

and/or subcontractors who were employed by General Electric Neutron Devices including 

all names of this company listed in Part C, Martin Marietta Specialty Components, and/or 

Lockheed-Martin Specialty Components, Inc. (also known as the Pinellas Plant) during the 

period from January 1957 through December 1997 [[redacted] 2020b]. 
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Class Defined by NIOSH for Further Evaluation

Based on its preliminary research, NIOSH modified the petitioner-requested class to 

include: All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Pinellas Plant in Clearwater, Florida 

for the period from January 1, 1957 through December 31, 1990.

Following a comprehensive review of the documentation associated with the petition for 

support of all accepted bases, E.5 and F.1 through F.4, NIOSH qualified the petition

(August 17, 2020 version) for evaluation under the F.4 basis. The 1990 Tiger Team 

Assessment of the Pinellas Plant found that during 1989, workers did not submit bioassay 

samples in accordance with General Electric Neutron Devices Department procedures 

[DOE 1990a, PDF p. 224]. The Tiger Team report focused on the 1988–1989 period and is 

not directly applicable to the time period that followed it because documentation shows 

that the Pinellas Plant responded to the finding. After the Tiger Team assessment, the 

Pinellas Plant began tracking individual compliance with bioassay sampling and had 

success in improving bioassay compliance. The Pinellas Plant documented this success in 

improving compliance in site As Low As Reasonably Achievable (ALARA) reports. Prior to 

these tracking efforts, it was unclear how widespread the non-compliance might have 

been. 

Based on a professional review of the supporting documents provided, NIOSH 

determined there was adequate support for further evaluation of non-compliance with 

bioassay sampling procedures from 1957 through 1990, when the Pinellas Plant began 

reporting bioassay compliance. NIOSH evaluated the following class: All employees of the 

Department of Energy, its predecessor agencies, and their contractors and subcontractors 

who worked at the Pinellas Plant in Clearwater, Florida for the period from January 1, 

1957 through December 31, 1990.

NIOSH Determination about Adding a Proposed Class to the SEC

NIOSH has access to internal and external exposure data for individual workers in the 

form of personal dosimetry data, summary information in the form of routine ALARA 

reports, and tritium dose summary data for most years. General area exposure conditions 

are available in routine health physics reports, incident and occurrence reports, routine 

ALARA reports, and air sampling data. However, the air sampling data are not 

comprehensive of the entire Pinellas Plant history. NIOSH also has access to safety work 

permit (SWP) summary log information, administrative program information, radiation 

protection procedures, and radiation protection survey protocols used at the Pinellas 

Plant. Finally, NIOSH has obtained a significant amount of environmental monitoring data, 

including emissions and environmental sampling. Based on its analysis of these available 

resources, NIOSH finds 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 be incurred in plausible circumstances by any member of the 

class under evaluation [42 C.F.R. 83, 2018, PDF p. 10]. Consequently, NIOSH concludes 

that it is feasible to estimate the radiation dose that the evaluated class of workers 

received.
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Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. 83.13(c)(1), 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 be incurred in plausible 

circumstances by any member of the class under evaluation. Information available from 

the site profile and additional resources is sufficient to estimate the maximum internal 

and external potential exposure to members of the evaluated class under plausible 

circumstances during the specified period [42 C.F.R. 83, 2018, PDF p. 10]. 

NIOSH bases the dose reconstruction feasibility findings on the following:

 The principal source of internal radiation for members of the NIOSH-evaluated class 

was tritium used in various production and development processes associated with 

the production of neutron generators. Internal exposure would have occurred 

through intake of tritium gas, tritium oxide, or metal tritides. The predominant 

internal radiation hazards were from tritium oxide and tritium gas.

 NIOSH reviewed the internal radiation exposure potential from other radionuclides 

used at the Pinellas site including plutonium, uranium, carbon-14, nickel-63, and 

krypton-85. NIOSH confirmed previous discussions by the Advisory Board on Radiation 

and Worker Health (ABRWH) Pinellas Plant Work Group that these radionuclides were 

not internal exposure concerns for the Pinellas Plant workers. 

 NIOSH has access to the in vitro urinalysis monitoring records for Pinellas Plant 

workers with the potential for internal exposures including tritium urinalysis results, 

termination bioassay sample results, bioassay tabulation forms, exposure record 

cards, dose adjustment forms, bioassay dose summary reports, dosimetry cards for 

individuals, and individual plutonium in vitro bioassay results. NIOSH reviewed the 

NIOSH DCAS Claims Tracking System (referred to as NOCTS) claimant files and found 

over 20,000 tritium bioassay results for 230 individuals. 

 NIOSH reviewed the DOE Tiger Team reported non-compliance with Pinellas Plant 

urine sampling procedures for tritium and determined there are approaches for 

assigning tritium dose to workers who have gaps in dosimetry, as would be the case 

for workers on routine-monitoring schedules that may have not been compliant with 

bioassay sampling schedules. NIOSH will update the site profile document, Pinellas 

Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5 to further explain 

unmonitored, internal tritium dose approaches.

 The principal sources of external radiation for members of the NIOSH-evaluated class 

include exposures to beta and photon radiation emitted from radiation-generating 

devices used onsite and the use of krypton gas. Testing neutron generators built at 

the Pinellas Plant could have exposed workers to neutrons. Photon and neutron 

radiation exposures were possible near the plutonium-oxide sources used for the 

radioisotope-powered thermoelectric generators’ heat sources. Leak testing of 

neutron-generator components could have exposed workers to beta radiation from 

krypton-85.
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 NIOSH has access to whole body and extremity dosimetry records, as well as neutron 

dosimetry results for potentially-exposed workers. NIOSH uses established protocols 

to reconstruct beta, photon, and neutron doses for Pinellas Plant workers. 

 NIOSH finds that it has access to sufficient information to estimate the occupational 

medical dose for Pinellas Plant workers. 

 Pursuant to 42 C.F.R. 83.13(c)(1), NIOSH determined that there is sufficient 

information to estimate the maximum radiation dose, for every type of cancer for 

which radiation doses are reconstructed, that could be incurred in plausible 

circumstances by any member of the class under evaluation [42 C.F.R. 83, 2018, PDF 

p. 10]. 

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. 83.13(c)(3), a health endangerment determination is not 

required because NIOSH has determined that it has sufficient information to estimate the 

radiation dose received by the members of the evaluated class [42 C.F.R. 83, 2018, PDF p. 

11].
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TABLE OF CONTENTS

EVALUATION REPORT SUMMARY: SEC-00256, PINELLAS PLANT .......................................... 5

TABLE OF CONTENTS ............................................................................................................. 9

ACRONYMS AND ABBREVIATIONS .......................................................................................13

1 SEC Petition Class under Review.................................................................................17

2 Introduction ................................................................................................................18

3 SEC-00256, Pinellas Plant Class Definitions ................................................................19

3.1 Petitioner-Requested Class Definition and Basis...............................................19

3.2 Class Defined by NIOSH for Further Evaluation.................................................20

3.3 NIOSH Determination about Adding a Proposed Class to the SEC....................20

4 Data Sources Reviewed by NIOSH to Evaluate the Class............................................22

4.1 Site Profile and Technical Basis Documents (TBDs)...........................................22

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures........................23

4.3 Facility Employees and Experts..........................................................................23

4.4 Previous Dose Reconstructions..........................................................................26

4.5 NIOSH Site Research Database ..........................................................................26

4.6 Documentation Provided by Petitioners ...........................................................26

5 Radiological Operations Relevant to the Class Evaluated by NIOSH..........................30

5.1 Pinellas Plant and Process Descriptions.............................................................30

5.2 Internal Radiological Exposure Sources from Pinellas Plant Operations...........32

5.2.1 Tritium....................................................................................................32

5.2.2 Plutonium ...............................................................................................34

5.2.3 Uranium..................................................................................................35

5.2.4 Carbon-14...............................................................................................36

5.3 External Radiological Exposure Sources from Pinellas Plant Operations..........37

5.3.1 Photon....................................................................................................37

5.3.2 Beta ........................................................................................................38

5.3.3 Neutron ..................................................................................................39

6 Summary of Available Monitoring Data and Data Sufficiency for the NIOSHEvaluated Class.....................................................................................................................41

6.1 Available Pinellas Plant Internal Monitoring Data and Data Sufficiency ...........41

6.1.1 In Vitro Analysis Data and Data Sufficiency ...........................................42

6.1.2 Air Monitoring Data Sufficiency.............................................................47

6.1.3 Alternative Data Source and Sufficiency................................................47

6.2 Available Pinellas Plant External Monitoring Data and Data Sufficiency ..........48

6.2.1 Employee Dosimetry Data Sufficiency ...................................................48

6.2.2 Area Monitoring Data and Data Sufficiency ..........................................52

6.2.3 Alternative Data Sources and Data Sufficiency......................................53

6.3 Available Pinellas Plant Ambient Environmental Monitoring Data and Data 

Sufficiency ...................................................................................................................53

6.3.1 Internal Environmental Data and Data Sufficiency................................53

6.3.2 External Environmental Data and Data Sufficiency ...............................55

6.4 Available Pinellas Plant Occupational Medical X-ray Data and Data 

Sufficiency ...................................................................................................................55

7 Feasibility of Dose Reconstruction..............................................................................57
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7.1 Internal Radiation Doses at the Pinellas Plant...................................................57

7.1.1 Evaluation of Bounding Operational Internal Radiation Doses.............57

7.1.1.1 Tritium.....................................................................................57

7.1.1.2 Plutonium ................................................................................63

7.1.1.3 Uranium...................................................................................63

7.1.1.4 Carbon-14................................................................................63

7.1.2 Evaluation of Bounding Ambient Environmental Internal Radiation 

Doses......................................................................................................64

7.1.2.1 Tritium.....................................................................................64

7.1.2.2 Plutonium ................................................................................64

7.1.2.3 Carbon-14 ................................................................................65

7.1.3 Internal Dose Reconstruction Feasibility Conclusion.............................65

7.2 External Radiation Doses at the Pinellas Plant ..................................................67

7.2.1 Evaluation of Bounding Operational External Radiation Doses ............67

7.2.1.1 Photon.....................................................................................67

7.2.1.2 Beta .........................................................................................69

7.2.1.3 Neutron ...................................................................................70

7.2.2 Evaluation of Bounding Ambient Environmental External Radiation 

Doses......................................................................................................72

7.2.3 External Dose Reconstruction Feasibility Conclusion ............................72

7.3 Occupational Medical X-ray Doses at the Pinellas Plant ...................................73

7.4 Evaluation of Petition Basis for SEC-00256........................................................73

7.4.1 Unmonitored Exposures to Sr-90, Co-60, Tl-204, and Uranium............73

7.4.2 Radiological Incidents ............................................................................74

7.4.3 Plutonium ...............................................................................................76

7.4.4 Duplicate Samples..................................................................................77

7.4.5 Radioactive Materials in Building 100....................................................78

7.4.6 Employer-required Chest X-rays............................................................79

7.4.7 Lack of Radiological Surveys ..................................................................79

7.4.8 Environmental Monitoring Record Keeping ..........................................79

7.4.9 Missing Dosimetry Records....................................................................80

7.5 Summary of Feasibility Findings for Petition SEC-00256 ...................................82

8 Evaluation of Health Endangerment for Petition SEC-00256 .....................................83

9 Class Conclusion for Petition SEC-00256 ....................................................................84

10 References...................................................................................................................85

ATTACHMENT ONE: DATA CAPTURE SYNOPSIS................................................................. 103

ATTACHMENT TWO: REVIEW OF PETITIONER-PROVIDED DOCUMENTATION..................123
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TABLES

Table 4-1: Number of Pinellas Plant Claims Submitted Under the Dose Reconstruction 

Rule .......................................................................................................................................26

Table 6-1: Pinellas Claimants with Tritium Resultsa.............................................................43

Table 6-2: Summary of Pinellas Internal Monitoring Data for Tritium 1986–1995a............45

Table 6-3: Pinellas Plant Internal Dose Record Series (Personnel Files)..............................46

Table 6-4: Summary of Pinellas External Monitoring Data for 1985–1995a........................51

Table 6-5: Pinellas Plant External Dose Record Series (Personnel Files).............................52

Table 7-1: Summary of Feasibility Findings for SEC-00256..................................................82

Table A1-1: Summary of Holdings in the SRDB for Pinellas Plant......................................103

Table A1-2: Database Searches for Pinellas Plant..............................................................121

Table A2-1: Petition SEC-00256 (August 17, 2020 version)...............................................123

Table A2-2: Supporting Documents for SEC-00256 Provided Post-Qualification..............126

FIGURES

Figure 5-1: Pinellas Plant Site Mapa,b .................................................................................. 31
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ACRONYMS AND ABBREVIATIONS

238PuO2 plutonium oxide

Abd/KUB abdominal/kidneys ureters bladder

ABRWH Advisory Board on Radiation and Worker Health

ADAMS Agency-wide Documents Access and Management (NRC)

AEC Atomic Energy Commission

ALARA as low as reasonably achievable

ANSI American National Standards Institute

ATL Advanced Technologies and Laboratories International

AWE Atomic Weapons Employer

Bq becquerel

C-14 carbon-14

CAP 88 Clean Air Act assessment package–1988

CATI computer assisted telephone interview

CDC Centers for Disease Control and Prevention

C.F.R. Code of Federal Regulations

Ci curie

cm2 square centimeter

cm3 cubic centimeter

Co-60 cobalt-60

Cs-137 cesium-137

D-D D(d,n)3He: type of fusion reaction that generates neutrons (see also D-T)

D-T T(d,n)4He: type of fusion reaction that generates neutrons (see also D-D) 

D&D decontamination and decommissioning 

DCAS Division (formerly Office) of Compensation Analysis and Support

DDRS Declassified Document Retrieval System (DOE Hanford)

DEEOIC Division of Energy Employees Occupational Illness Compensation (DOL)

DOE Department of Energy

DOELAP DOE Laboratory Accreditation Program

DOL Department of Labor

dpm disintegrations per minute

DR dose reconstruction

DTIC Defense Technical Information Center

DU depleted uranium

EECAP Energy Employees Claimant Assistance Project

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000

EPA Environmental Protection Agency

ER Evaluation Report (NIOSH-owned document)

FAB Final Adjudication Branch (DOL)

FBI Federal Bureau of Investigation
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FC-600 Bioassay Exposure Record form (Pinellas Plant)

FRC Federal Records Center

ft2 square feet

ft3 cubic feet

GE General Electric Company

GEND General Electric Neutron Devices

GENDD General Electric Neutron Devices Department

H-3 tritium

HHS (Department of) Health and Human Services

HP health physics

HSS Health Safety and Security (DOE)

HTO tritium oxide

HVAC heating, ventilation, and air conditioning system

ICRP International Commission on Radiological Protection

IMBA Integrated Modules for Bioassay Analysis software program

keV kiloelectron-volt, 1000 electron-volts

Kr-85 krypton-85

LAMB lithium ambient

LAT lateral

m2 square meters

m3 cubic meters

mCi millicurie

MeV megaelectron-volt, 1 million electron-volts

MMSC Martin Marietta Specialty Components, Inc.

mrad millirad

mrem millirem

MUL-101 Bioassay Tabulation form (Pinellas Plant)

MUL-334 Exposure Record form (Pinellas Plant)

N-14 nitrogen-14

N/A not applicable

NAP National Academies Press

NARA National Archives and Records Administration

NEPIS National Environmental Publications Information System (EPA)

NFC 1163 Personnel Monitoring Record form (Pinellas Plant)

Ni-63 nickel-63

NIOSH National Institute for Occupational Safety and Health

NNSA National Nuclear Security Administration (DOE)

NOCTS NIOSH OCAS (now DCAS) Claims Tracking System

NRC Nuclear Regulatory Commission

NSCEP National Service Center for Environmental Publication

NTA nuclear track emulsion, type A (dosimetry film)
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NTS Noncompliance Tracking System (DOE)

NV5/DMA NV5 | Dade Moeller

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

ORPS Occurrence Reporting Processing System (DOE)

OSHA Occupational Safety and Health Administration

OSTI Office of Scientific and Technical Information (DOE)

OTIB ORAU Technical Information Bulletin

PA posterior-anterior

PAD Post Approval Dosimetry Evaluation Tracker System (NIOSH)

PDF Portable Document Format

POTW publicly-owned treatment works

Pu plutonium

Pu-238 plutonium-238

Pu-239 plutonium-239

Pu-240 plutonium-240

Rb-85 rubidium-85

RBE relative biological effectiveness (neutron weighting factor)

RMMA Radioactive Materials Management Area

RTG radioisotope-powered thermoelectric generator

S&H safety and health (department)

SAIC Science Applications International Corp.

SC&A S. Cohen & Associates

SEC Special Exposure Cohort

SEM Site Exposure Matrix (DOL)

Sr-90 strontium-90

SRDB Site Research Database (NIOSH)

SWP safety work permit

TBD technical basis document

Tl-204 thallium-204

TLD thermoluminescent dosimeter

TRS Tritium Recovery System

TRU transuranic

U uranium

UNC University of North Carolina

U3O8 triuranium oxide, also known as yellowcake (used in borosilicate glass)

USACE United States Army Corps of Engineers

U.S.C. United States Code

WG Work Group – ABRWH

μCi/cc microcuries per cubic centimeter
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μCi/l microcuries per liter

μCi/mL microcuries per milliliter
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SEC PETITION EVALUATION REPORT FOR SEC-00256

1 SEC Petition Class under Review

This report contains NIOSH’s evaluation of the feasibility of reconstructing radiation doses 

for all employees of the Department of Energy (DOE), its predecessor agencies, and their 

contractors and subcontractors who worked at the Pinellas Plant in Clearwater, Florida for 

the period from January 1, 1957 through December 31, 1990. It provides information and 

analyses pertinent to considering a petition for adding a class of employees to the 

congressionally-created Special Exposure Cohort (SEC). This report does not contain the final 

determination as to whether the proposed class will be added to the SEC (see Section 2.0).

As the petition evaluation is concerned with the feasibility of reconstructing radiation dose 

for a group of employees, this report does not make any determinations concerning dose 

reconstruction for any individual energy employee. However, the fact-finding and analysis 

completed for the evaluation of an SEC petition is informative to the dose reconstruction 

efforts for individual energy employees under 42 Code of Federal Regulations (C.F.R.) Part 82

[2019]. Likewise, 42 C.F.R. Part 82 [2019] provides the methods by which NIOSH is 

conducting dose reconstructions to estimate the radiation doses incurred by covered 

employees; therefore, the dose reconstruction methods in 42 C.F.R. Part 82 [2019] will be 

directly considered by NIOSH in determining whether it is feasible to estimate with 

sufficiency accuracy the radiation dose that the class received.

This evaluation was conducted in accordance with the requirements of Energy Employees 

Occupational Illness Compensation Program Act of 2000, as amended, 42 United States Code 

(U.S.C.) Section 7384 et seq. (EEOICPA), 42 C.F.R. Part 83 [2018], and the guidance contained

in the Division of Compensation Analysis and Support’s (DCAS) Internal Procedures for the 

Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004 [NIOSH 2011a].
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2 Introduction

Both EEOICPA and 42 C.F.R. Part 83 [2018] require NIOSH to evaluate qualified petitions 

requesting that the Department of Health and Human Services (HHS) add a class of

employees to the SEC. According to 42 U.S.C. 7384q(b)(1), the evaluation is intended to 

provide a science-based determination of whether it is “feasible to estimate with sufficient 

accuracy” the radiation dose that the class of employees received. 

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 [42 

C.F.R. 83, 2018, PDF p. 10].

Under 42 U.S.C. 7384q (b)(2) and 42 C.F.R. 83.13(c)(3), if it is not feasible to estimate with 

sufficient accuracy the radiation dose that the class members received, then NIOSH must 

determine whether “there is a reasonable likelihood that such radiation doses may have

endangered the health of members of the class.” Under 42 C.F.R. 83.13(c)(3), if NIOSH has

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, then NIOSH will assume that any duration of unprotected exposure may 

have endangered the health of members of a class. If the occurrence of such an 

exceptionally high-level exposure has not been established, then NIOSH will specify a 

minimum duration of employment to satisfy the health endangerment criteria as having

been 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 one or

more other SEC classes [42 C.F.R. 83, 2018, PDF p. 11]. 

NIOSH relies upon both its own dose reconstruction expertise as well as technical support 

from its contractor, Oak Ridge Associated Universities (ORAU), to analyze information

relevant to the petition evaluation and document its findings and analyses in a report. Once 

completed, NIOSH provides the evaluation report to both the petitioner(s) and the Advisory 

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

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

information the Advisory 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. The NIOSH Director will then consider NIOSH’s evaluation, the Advisory Board’s

deliberations, report, and recommendations, and any information presented or submitted to 

the Advisory Board. The Director of NIOSH will then propose a decision to add or deny 

adding any class or classes of employees to the SEC. The Secretary of HHS will make the final 

decision after considering information and recommendations provided by the Advisory

Board and the Director of NIOSH. Petitioners may request an administrative review of a final 

decision to deny adding a class to the SEC or a health endangerment determination. See 42

C.F.R. 83 [2018] for a full description of the procedures summarized here. Additional internal

procedures are available on the NIOSH Radiation Dose Reconstruction Program webpage.

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3 SEC-00256, Pinellas Plant Class Definitions

The following subsections address the evolution of the class definition for SEC-00256, 

Pinellas Plant. When NIOSH receives a petition, NIOSH reviews the class definition as 

requested by the petitioner. Based on its review of the available site information and data, 

NIOSH will determine whether to qualify the petition for a full evaluation of all, some, or no 

part of the petitioner-requested class. If some portion of the petitioner-requested class is 

qualified, NIOSH will specify the revised class definition along with a justification for the 

modification. After a full evaluation of the qualified class, NIOSH will determine whether to 

propose a class for addition to the SEC and will specify that proposed class definition. 

3.1 Petitioner-Requested Class Definition and Basis

NIOSH received petition SEC-00256 (December 16, 2019 version) on December 16, 2019

[[redacted] 2019]. The petitioners revised the petitioner-requested SEC petition class twice

[[redacted] 2020a,b], following discussions during consultation calls. Section 4.6 presents a

more detailed discussion of the history of the petition submissions for SEC-00256. NIOSH 

received a revised petition (August 17, 2020 version) on August 17, 2020. The petitioners 

requested that NIOSH consider the following class: Employees of the Department of Energy 

(DOE), DOE contractors and/or subcontractors who were employed by General Electric 

Neutron Devices including all names of this company listed in Part C, Martin Marietta 

Specialty Components, and/or Lockheed-Martin Specialty Components, Inc. (also known as 

the Pinellas Plant) during the period from January 1957 through December 1997. A modified 

version of this class qualified for further evaluation on October 20, 2020.

The petitioners provided information, employment records, dosimetry documents, 24-hour 

heavy metal urine test reports, a bibliography of published reports, excerpts from the 

Pinellas Plant site profile, correspondence, an internal newsletter (i.e., Headliner) article, 

lists of many areas and job titles applicable to the Plant, and information on General Electric 

Neutron Devices (GEND)/General Electric Neutron Devices Department (GENDD) products in 

support of the petitioners’ belief that dose reconstruction is not feasible for the Pinellas 

Plant employees in question. The petition (August 17, 2020 version) is comprised of ten 

sections, many with multiple subsections, exhibits, and two appendices. For additional 

specifics on the petitioner-supplied documentation in support of petition SEC-00256, see 

Section 4.6 and Attachment Two: Review of Petitioner-Provided Documentation. 

When NIOSH received the third (and final) petition submission (August 17, 2020 version), the 

petitioners did not specifically identify any of the possible Form B petition bases. The 

petitioners clarified during consultation that the basis was to be an F.1 basis [[redacted] 

2020b, PDF pp. 31–36] that radiation exposures and doses potentially incurred by the 

members of the class were not monitored. NIOSH reviewed the petition and information for 

qualifying support towards all bases and determined that the petition (August 17, 2020 

version) qualified for evaluation under the F.4 basis. The F.4 basis relates to a scientific or 

technical report, issued by a government agency of the Executive Branch of Government or 

the General Accounting Office, the Nuclear Regulatory Commission, or the Defense Nuclear 

Facilities Safety Board, or published in a peer-reviewed journal, that identifies dosimetry and 

related information that are unavailable (due to either a lack of monitoring or the 
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destruction or loss of records) for estimating the radiation doses of energy employees 

covered by the petition. The petitioners provided the report Tiger Team Assessment of the 

Pinellas Plant [DOE 1990a] under the heading “F.4 Bibliographic of Scientific or Technical 

Reports.” NIOSH reviewed all of the excerpts submitted from the DOE Tiger Team 

Assessment of the Pinellas Plant for applicability to an F.4 basis [DOE 1990a]. NIOSH then 

reviewed the Tiger Team report in its entirety and determined that the following 

information is sufficient to qualify SEC-00256 for evaluation:

 The report states “... compliance with the rules on providing bioassay samples at 

specified frequencies has not been satisfactory” [DOE 1990a, PDF p. 216] and “... In 1989, 

bioassay samples were not submitted in accordance with GEND procedures. Seventy 

percent of the required monthly samples and 35 percent of the required weekly samples 

were not submitted” [DOE 1990a, PDF p. 224].

The finding identified by the DOE Tiger Team Assessment of the Pinellas Plant provides 

sufficient documentation that some dosimetry information (i.e., uncollected bioassay 

samples) may not be available for the period prior to 1990. 

3.2 Class Defined by NIOSH for Further Evaluation

Based on its preliminary research, NIOSH modified the petitioner-requested class. NIOSH 

qualified the petition for evaluation under the F.4 basis because the 1990 Tiger Team 

Assessment of the Pinellas Plant finding that 1989 bioassay samples were not submitted in 

accordance with GEND procedures [DOE 1990a, PDF p. 224] satisfies the criteria for the 

basis. The Tiger Team report focused on assessing the 1988–1989 period; therefore, this 

assessment does not directly apply to the time period that followed it. During the 

qualification assessment, NIOSH reviewed available documentation and information related 

to the site follow-up to determine if the issue identified in the report continued. In response 

to the Tiger Team assessment, the Pinellas Plant Health Physics Department began tracking 

individual compliance with bioassay sampling and had success in improving the compliance. 

The Pinellas Plant ALARA reports document the Plant’s success in improving compliance. The 

1990 Annual ALARA Program Report for Ionizing Radiation [Weaver 1991, PDF p. 38] shows 

the bioassay program average participation was 78%, which is 2% short of the 80% target. 

NIOSH concluded, based on the bioassay compliance published in the 1990–1995 ALARA 

reports, that it is reasonable and prudent to consider 1990 a transition year to a more 

rigorous program. Therefore, NIOSH defined the following class for further evaluation: All 

employees of the Department of Energy, its predecessor agencies, and their contractors and 

subcontractors who worked at the Pinellas Plant in Clearwater, Florida for the period from 

January 1, 1957 through December 31, 1990.

3.3 NIOSH Determination about Adding a Proposed Class to the SEC

NIOSH has obtained internal and external exposure data for individual workers in the form of 

personal dosimetry data, including routine and termination tritium bioassay results, a limited 

amount of plutonium bioassay results collected by the Pinellas Plant, Landauer dosimetry 

reports, external film work sheets, personnel exposure records, and termination exposure 

reports (both internal and external). NIOSH has summary information in the form of routine 
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ALARA reports, routine health physics reports, radiation exposure reports, and tritium dose 

summary data for the NIOSH-evaluated period (i.e., 1957 through 1990). Radiation work

permit summary log information is also available. General area exposure conditions are 

available in routine health physics reports, incident and occurrence reports, routine ALARA 

reports, and air sampling data. However, the air sampling data are not comprehensive of the 

entire Plant history. NIOSH also has access to SWP summary log information, administrative 

program information, radiation protection procedures, and radiation protection survey 

protocols used at the Pinellas Plant. Finally, NIOSH has obtained a significant amount of 

environmental monitoring data, including emissions and environmental sampling.

Based on the analysis of these available resources, presented in the later sections of this 

document, NIOSH concludes 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 be incurred in plausible circumstances by any member of the class 

under evaluation. Therefore, NIOSH does not recommend adding the NIOSH-evaluated class 

to the SEC.
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4 Data Sources Reviewed by NIOSH to Evaluate the Class

NIOSH completed an extensive database and Internet search for information regarding the 

Pinellas Plant. The database search included the DOE Legacy Management Considered Sites 

database, the DOE Office of Scientific and Technical Information (OSTI) SciTech Connect 

database, and the Hanford Declassified Document Retrieval System. In addition to general 

Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, the 

Nuclear Regulatory Commission (NRC) Agency-wide Documents Access and Management 

(ADAMS) web searches, and the DOE-National Nuclear Security Administration-Nevada Site 

Office-search. Attachment One includes a summary of Pinellas Plant documents. The 

summary specifically includes data capture details and general descriptions of the 

documents retrieved.

In addition to the database and Internet searches listed above, NIOSH identified and 

reviewed numerous data sources to determine information relevant to determining the 

feasibility of dose reconstruction for the class of employees under evaluation. 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 and Technical Basis Documents (TBDs)

A site profile or Technical Basis Document (TBD) provides specific information on the 

documented historical practices for a specified site. Dose reconstructors can use TBDs to 

evaluate internal and external dosimetry data for monitored and unmonitored employees, 

and to supplement, or substitute for, individual monitoring data. For a large site, there can 

be a full site profile consisting of six TBDs that cover process history, personal and area 

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

the radiological operations.

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

into Pinellas Plant operations or related topics/operations at other sites:

 TBD for the Pinellas Plant – Introduction, ORAUT-TKBS-0029-1; Rev. 01; April 18, 2011; 

SRDB Ref ID: 99872 [ORAUT 2011a] 

 TBD for the Pinellas Plant – Site Description, ORAUT-TKBS-0029-2; Rev. 02; April 1, 2011; 

SRDB Ref ID: 99874 [ORAUT 2011b] 

 TBD for the Pinellas Plant – Occupational Medical Dose, ORAUT-TKBS-0029-3; Rev. 01; 

October 13, 2011; SRDB Ref ID: 102290 [ORAUT 2011c] 

 TBD for the Pinellas Plant – Occupational Environmental Dose, ORAUT-TKBS-0029-4; Rev. 

01; July 15, 2011; SRDB Ref ID: 99867 [ORAUT 2011d] 

 TBD for the Pinellas Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5; Rev. 03; 

July 18, 2016; SRDB Ref ID: 158070 [ORAUT 2016a] 
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 TBD for the Pinellas Plant – Occupational External Dose, ORAUT-TKBS-0029-6; Rev. 02; 

December 11, 2017; SRDB Ref ID: 168436 [ORAUT 2017a] 

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

August 11, 2004; SRDB Ref ID: 19791 [ORAUT 2004a]

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 projectlevel activities, including preparation of dose reconstructions at particular sites or categories 

of sites. NIOSH reviewed the following OTIBs as part of its evaluation:

 OTIB: Tritium Calculated and Missed Dose Estimates, ORAUT-OTIB-0011, Rev. 00; 

effective June 29, 2004; SRDB Ref ID: 19430 [ORAUT 2004b] 

 OTIB: Dose Reconstruction from Occupational Medical X-Ray Procedures, ORAUT-OTIB0006, Rev. 06; effective September 27, 2019; SRDB Ref ID: 178310 [ORAUT 2019]

 OTIB: Guidance on Assigning Occupational X-Ray Dose Under EEOICPA for X-Rays 

Administered Off Site, ORAUT-OTIB-0079, Rev. 02; effective June 15, 2017; SRDB Ref ID: 

166967 [ORAUT 2017b] 

 Procedure: Special Exposure Cohort, ORAUT-PROC-0044, Rev. 01; effective October 19, 

2017; SRDB Ref ID: 181580 [ORAUT 2017c]

4.3 Facility Employees and Experts

To obtain additional information, NIOSH reviewed four previous sets of interview notes

[ORAUT 2007a,b; ORAUT 2013a,b] and interviewed and/or re-interviewed 16 former Pinellas 

Plant employees or DOE oversight staff. The ORAU Team and Advanced Technologies and 

Laboratories International (ATL) identified potential interview candidates by reviewing 

Pinellas Plant outreach meeting minutes [NIOSH 2012a], through communications with a 

petitioner representative [[redacted] 2020], and from reviewing documentation that listed 

former workers. NIOSH also reached out to anyone identified by an interviewee as someone 

likely to have additional information. By March 5, 2021, all interview notes had completed 

the classification review and NIOSH had returned the notes to the interviewees for their 

review and concurrence. Of the 16 individuals interviewed in 2020 and 2021, 15 concurred 

with the accuracy of the notes and with NIOSH citing them in the evaluation report. A single 

interviewee did not respond to requests for their final approval of the interview notes; 

therefore, NIOSH did not cite that set of interview notes. The following interviews 

contributed to this report:

 Documented Communication with [redacted] on technical basis document Pinellas Plant 

– occupational medical dose; telephone interview by ORAU Team; November 13, 2007; 

SRDB Ref ID: 37343 [ORAUT 2007a]
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 Documented Communication with [redacted] on Technical Basis Document Pinellas Plant 

- Occupational External Dose: Inquiring About Potential Radiation Exposures from the Kr85 Gas that is Used in the Radiflo Leak Detection Systems; Telephone interview by ORAU 

Team and NIOSH; November 20, 2007; SRDB Ref ID: 37342 [ORAUT 2007b] 

 Documented Communication with [redacted] on Past Radiological Control Practices at 

the Pinellas Plant with an Emphasis on the Controls for Metal Tritides; Telephone 

interview by ORAU Team; June 18, 2013; SRDB Ref ID: 127111 [ORAUT 2013a] 

 Documented Communication with [redacted] and [redacted] on Analyzing Tritium 

Contamination Smears at Pinellas Plant; Telephone interview by ORAU Team; November 

12, 2013; SRDB Ref ID: 129125 [ORAUT 2013b]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990; Telephone interview 

by ORAU Team and NIOSH; October 23, 2020; SRDB Ref ID: 185745 [ORAUT 2020a]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

November 30, 2020; SRDB Ref ID: 185748 [ORAUT 2020b]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

December 2, 2020; SRDB Ref ID: 185752 [ORAUT 2020c]

 Documented Communication with [redacted] on Ability to Perform Radiation Dose 

Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those Not 

Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; December 

7, 2020; SRDB Ref ID: 185809 [ORAUT 2020d]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

December 7, 2020; SRDB Ref ID: 185753 [ORAUT 2020e]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

December 9, 2020; SRDB Ref ID: 185749 [ORAUT 2020f]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

December 9, 2020; SRDB Ref ID: 185754 [ORAUT 2020g] 
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 Documented Communication with [redacted] on Ability to Perform Radiation Dose 

Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those Not 

Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; December 

16, 2020; SRDB Ref ID: 185929 [ORAUT 2020h]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH;

December 22, 2020; SRDB Ref ID: 185747 [ORAUT 2020i] 

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH;

December 22, 2020; SRDB Ref ID: 185813 [ORAUT 2020j] 

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

January 14, 2021; SRDB Ref ID: 185751 [ORAUT 2021a] 

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

January 27, 2021; SRDB Ref ID: 185810 [ORAUT 2021b]

 Documented Communication SEC-00256 with [redacted] on Ability to Perform Radiation 

Dose Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those 

Not Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; 

January 28, 2021; SRDB Ref ID: 185812 [ORAUT 2021c]

 Documented Communication with [redacted] on Ability to Perform Radiation Dose 

Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those Not

Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; February 1, 

2021; SRDB Ref ID: 185811 [ORAUT 2021d] 

 Documented Communication with [redacted] on Ability to Perform Radiation Dose 

Reconstructions for Pinellas Workers Between 1957 and 1990, Particularly Those Not 

Returning Bioassay Samples; Telephone interview by ORAU Team and NIOSH; February 2, 

2021; SRDB Ref ID: 185814 [ORAUT 2021e] 
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4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH DCAS 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. (NOCTS data available as of May 3, 2021) 

Table 4-1: Number of Pinellas Plant Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 503

Total number of claims submitted for energy employees who worked during the 

period under evaluation (January 1, 1957 through December 31, 1990)

496

Number of dose reconstructions completed for energy employees who worked during 

the period under evaluation (i.e., the number of such claims completed by NIOSH and 

submitted to the Department of Labor for final approval)

456

Number of claims for which NIOSH obtained internal dosimetry records for the time 

period in the evaluated class definition

279

Number of claims for which NIOSH obtained external dosimetry records for the time 

period in the evaluated class definition

277

Claimants submitted 496 claims for energy employees who worked during the period under 

evaluation; these include 456 completed dose reconstructions, 29 claims that DOL pulled or 

administratively closed, four that are eligible for SEC inclusion, and seven that are currently 

active.

4.5 NIOSH Site Research Database

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. NIOSH identified 2,163 documents in this database that 

pertain to the Pinellas Plant. The documents include historical background on the 

radiological work plans and procedures, occupational dosimetry information (i.e., bioassay 

data, exposure investigations, radiological incidents, environmental and work area radiation 

surveys), air monitoring data, and radiation work permits (also known as safety work permits

or special work permits) associated with specific tasks. NIOSH evaluated these documents 

for their relevance to this petition. 

4.6 Documentation Provided by Petitioners

NIOSH received an 83.13 (Form B) petition application on December 16, 2019 from two 

petitioners and one representative [[redacted] 2019]. The petitioner-requested class 

included employment dates relevant to the petition as September 4, 1956 to May 19, 1957 

at the Temporary Plant and May 19, 1957 to December 1997 at Pinellas Plant. NIOSH 

responded to petition SEC-00256 (December 16, 2019 version) by conducting a consultation 

call with one of the two petitioners and the petitioner representative on January 21, 2020 
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[NIOSH 2020a]. During the consultation call, NIOSH and the petitioner discussed the 

employment dates relevant to the petition. NIOSH informed the petitioner that this program 

does not cover employment at the interim manufacturing facility in St. Petersburg, Florida. 

The petitioner and representative confirmed that the worker class definition should include 

all employees who worked in any areas of the Pinellas Plant, in Largo, Florida from May 19, 

1957 through December 31, 1997. They also confirmed during the consultation call that they 

filed the petition under the F.1 and F.2 bases, and that they were still in the process of 

obtaining supporting scientific reports.

On May 20, 2020, NIOSH received a revised petition requesting a petition period of June 

1956 through December 1997 [[redacted] 2020a, PDF p. 5]. This revision included operations 

that occurred at the temporary plant in St. Petersburg, Florida. The temporary plant 

operated while the Pinellas Plant was under construction; however, it is not a covered 

facility.

NIOSH responded to this revised petition (May 20, 2020 version) by scheduling and 

conducting another consultation call with the petition representative on June 17, 2020. 

During this second consultation call, NIOSH again clarified that requested site facilities and 

time frames are limited to those as defined in the DOE Covered-Facility Database [NIOSH 

2020b, PDF p. 3; NIOSH 2020c, PDF p. 3; NIOSH 2020d, PDF p. 3]. Also during the second 

consultation call, the petition representative indicated that heavy-metals testing results 

were intended to have been included and would be, that an F.1 basis is desired, and that 

additional information would be provided to indicate how the (previously-provided) “F.4 

Bibliographic of Scientific or Technical Reports” documents indicate the limitations of 

existing DOE records regarding radiation exposures at the Pinellas Plant. On June 23, 2020, 

NIOSH sent a consultation call letter to the petitioners’ representative and both petitioners 

summarizing the June 17, 2020 consultation call (i.e., second consultation call) [NIOSH 

2020b,c,d].

On August 17, 2020, NIOSH received a second revised petition (August 17, 2020 version)

containing a title page with the note “Replaces Document Submitted on January 21, 2020 

and May 20, 2020” [[redacted] 2020b]. This second revised petition (August 17, 2020

version) had 10 parts, including lists of many areas and job titles applicable to the Pinellas 

Plant, and requested a petition period of January 1957 through December 1997; the 

petitioners removed previous references to the interim facility. Other additions included

information for items identified in section F.4, an appendix (Historical Report of Radiation 

Protection at GEND), and urine results (heavy metals analysis) that were inadvertently 

excluded previously.

In qualifying and evaluating the petition (August 17, 2020 version), NIOSH reviewed the 

following documents submitted by the petitioners:

 Exhibit 1: Lists 28 radioactive materials used in the Plant [[redacted] 2020b, PDF p. 37]

 Exhibit 2: Presents the activity and dates of four strontium-90 check sources [[redacted] 

2020b, PDF p. 38]
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 Exhibit 3: Presents various sampling results from five Pinellas County environmental 

sampling locations collected between April 1976 and July 1993 [[redacted] 2020b, PDF 

pp. 39–40]

 Exhibit 4: Summarizes the designation, use, power output, weight, size, isotopic fuel, 

design life, and operational dates (ranging from 1959–1966) of isotopic-power systems

for use in space [[redacted] 2020b, PDF p. 41]

 Exhibit 5: A single-page excerpted table that lists emissions, half-lives, specific power, 

and melting points for 28 isotopes useful for power generation [[redacted] 2020b, PDF p. 

42]

 Appendix 1: “24-Hour Urine Heavy Metals Tests” includes urine test results (with patient 

information redacted) for eight EEOICPA claimants [[redacted] 2020b, PDF pp. 43–59]. 

Commercial laboratories performed the testing.

 Appendix 2 Health Physics Report: “Historical Report of Radiation Protection at GEND” 

describes GEND operations, significant HP activities, unusual events, and environmental 

releases of radioactivity over the 30-plus year period since the Pinellas Plant start-up in 

1957 [[redacted] 2020b, PDF pp. 60–76]. 

 “Bibliographic of Scientific or Technical Reports” includes a list of five documents 

provided under Section F.4 [[redacted] 2020b, PDF pp. 31–36]. NIOSH reviewed the five 

documents in the bibliographic listing along with explanatory text describing each 

document’s perceived applicability. Two of the five documents, as noted below, are 

specific to the Pinellas Plant: the Review of the Department of Labor's Site Exposure 

Matrix Database [Institute of Medicine 2013] and the Tiger Team Assessment of the 

Pinellas Plant [DOE 1990a]. The DOL publishes the Site Exposure Matrix Database in 

support of Subpart E of EEOICPA; it is not directly applicable to Subpart B, which governs 

this petition. The five documents listed includes: 

 Review of the Department of Labor’s Site Exposure Matrix Database [Institute of 

Medicine 2013] Note: This document is specific to the Pinellas Plant.

 Tiger Team Assessment of the Pinellas Plant [DOE 1990a] Note: This document is

specific to the Pinellas Plant.

 Dosimetry is Key to Good Epidemiology: Workers at Mallinckrodt Chemical Works had 

Seven Different Source Exposures [Ellis et al. 2018]

 The NIOSH Radiation Dose Reconstruction Program: Managing Technical Challenges

[Moeller et al. 2008] 

 Scientific Issues in Radiation Dose Reconstruction [Toohey 2008] 
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Following qualification on October 20, 2020, NIOSH received additional documents from the 

petitioners in support of SEC-00256.

 On November 11, 2020, NIOSH received copies of three memos: (1) correspondence 

between DOE Oak Ridge Operations and ORAU [Jelinek 1990], (2) correspondence from 

ORAU [Fry 1990], and (3) correspondence between DOE Headquarters and Pinellas Area 

Office [Goldsmith 1990], all regarding the implementation of an epidemiological study of 

Pinellas Plant employees conducted by ORAU.

 On November 17, 2020, NIOSH received two tables listing Neutron Devices Department 

(NDD) products [NDD product 1980; NDD product 1990], a flow-chart for neutron 

generator production [NDD generator 1986], and a table of electronic units specifying

work units [Gurley 1968].

 On November 17, 2020, NIOSH also received a copy of a page from the Headliner, Martin 

Marietta’s internal newspaper, with an article discussing the Pinellas Plant 908 operation 

as an early name for the neutron generator project [Martin Marietta 1994a]. The article 

states the project began in 1956 with 285 employees in a temporary site in St. 

Petersburg [Martin Marietta 1994a]. Also, NIOSH received a copy of a notice from the 

DOL Final Adjudication Branch (FAB). Under Findings of Fact, the FAB lists work at the 

Pinellas Plant, a covered DOE facility, from October 1, 1956 to April 30, 1962 [Newton, no 

date].

 On December 9, 2020, NIOSH received a copy of the technical report Case Control Study 

of Multiple Myeloma Among Workers Exposed to Ionizing Radiation and Other Physical 

and Chemical Agents [University of North Carolina 1997].

 On January 25, 2021, NIOSH received a copy of a 1967 memo from AEC Headquarters

providing examples of types of cases identifying accidents or occupationally-related 

disease that could result in a workman’s compensation claim or civil suit [Doran 1967].

The petitioners provided all of the documents listed above after NIOSH qualified Pinellas 

Plant SEC-00256 for further evaluation. NIOSH reviewed the documents for information that 

would support adding a class of workers to the SEC.

In December 2020, NIOSH forwarded the Headliner internal newspaper article and the letter 

from the FAB to DOL requesting a site clarification review. The petitioner provided these 

documents as support for changing the SEC petition period to include 1956, which is prior to 

the covered period for the Pinellas Plant. DOL confirmed the Pinellas Plant covered period of 

January 1, 1957 through December 31, 1997 [DOL 2020].

In addition to the documents listed above, the petitioners made NIOSH aware of several 

documents they had requested from DOE. NIOSH attempted to locate these requested 

documents to review as part of the evaluation. NIOSH reviewed the documents received 

from the petitioner and those retrieved by NIOSH for information relevant to the evaluation

(See Attachment Two). 
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5 Radiological Operations Relevant to the Class Evaluated by NIOSH

While the NIOSH-evaluated class spans Pinellas Plant operations from January 1, 1957 

through December 31, 1990, for the sake of context, Section 5 includes site history 

information through 1997. The following subsections summarize both radiological 

operations at the Pinellas Plant from January 1, 1957 through December 31, 1997 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 processes through which radiation exposures may have occurred and 

the physical environment in which they may have occurred. NIOSH intends for the 

information included within this evaluation report only to be a summary of the available 

information. 

5.1 Pinellas Plant and Process Descriptions

The Pinellas Plant, located near the geographic center of Pinellas County, Florida was 

originally built to manufacture neutron generators (containing small amounts of tritium), a 

principal component in nuclear weapons. In addition to the manufacturing facility, the Plant

maintained uniquely specialized areas of competence to develop equipment and processes 

used in weapons-component production. General Electric (GE) constructed the Pinellas Plant

in 1956 and operated the Plant until May 31, 1992. In June 1992, Martin Marietta Specialty 

Components, Inc. (MMSC) assumed operation of the Plant. In September 1994, the facility 

stopped producing weapons-related components, and its mission changed to environmental 

restoration of the facility [DOE, no date-a]. DOE relocated the work to the Kansas City plant 

in Missouri and the Sandia National Laboratory in New Mexico. Decontamination and 

decommissioning (D&D) work, including disconnecting the equipment and transferring some 

employees to New Mexico occurred between 1994 and 1997 when DOE D&D operations 

were complete. The Pinellas County Industrial Council purchased the Plant in March 1995

[Patenaude 1997, PDF p. 2]. 

The Plant has been known by several names throughout its history including the 908 Plant, 

Pinellas Peninsula Plant, GE X-Ray Division-Florida, GENDD, GEND GE Pinellas Plant, and the 

Pinellas Plant [ORAUT 2011b, PDF p. 9; [redacted] 2019, PDF p. 3]. The Plant is located 

midway between the cities of Largo and Pinellas Park, Florida, on a 99.9-acre site, with one 

large building (Building 100) surrounded by 17 smaller buildings and structures, including 

two small school buildings equipped with a specialized heating, ventilation, and air condition 

(HVAC) system to allow the schools to be isolated from the environment. Though NIOSH has 

not located dates of school operation, the Environmental Assessment Operation of the 

Pinellas Plant Child Development Center/Partnership School [GE 1990, PDF p. 6] discusses the 

proposed joint venture to operate a Partnership School and Child Development Center and 

indicates that facilities were not in place or occupied before July 1990. The school buildings

are located approximately 150 feet east of Building 100, surrounded by a 4-foot high chainlink fence and a 10-foot wide landscaped buffer zone, which separated them from the

Pinellas Plant operations buildings.
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The main Neutron Generator Production Area was Building 100. Building 100 (with its annex, 

Building 300) was over 625,000 square feet and included offices, production space, and 

laboratory space [ORAUT 2011b, PDF p. 29; DOE 1995a, PDF p. 29]. The building had 

separate “Areas” for manufacturing, engineering, and administrative support services. By 

1991 the Plant had grown to 728,729 square feet total, including 68,106 square feet of 

mezzanines [Martin Marietta 1993a, PDF p. 20]. At its peak, the Plant employed 

approximately 2,000 people [GE 1987, PDF p. 269]. Figure 5-1 shows a map of the Pinellas 

Plant.

Figure 5-1: Pinellas Plant Site Mapa,b

a. Source: [Martin Marietta 1993a, PDF p. 33] 

b. Although not shown in the Pinellas site map, Building 100 contains Building 300.

Pinellas manufactured only neutron generators for its first ten years of operation [GE 1986, 

PDF p. 13], then DOE expanded the original mission to include the production of multiple 

electronic and support components for other DOE programs. These components included: 

neutron detectors, specialty capacitors, thermal batteries, electromagnetic devices, vacuum 

switch tubes (containing small amounts of plated nickel-63), lithium ambient (LAMB) 

batteries, frequency control devices, resonant accelerometers, lightning arrestor connectors, 

foam support pads, product testers, alumina ceramics, alumina ceramic feedthroughs, 

ferroelectric ceramics, glass ceramics, optoelectronics, shock transducers, and radioisotopepowered thermoelectric generators (RTGs).
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In December 1991, DOE Secretary Watkins identified Pinellas as one of the plants slated for 

closure as part of Complex 21 [Pope 2007]. Documents indicate that the work continued 

using on-hand inventory to produce neutron generators and tubes; however, Pinellas did not

acquire new radiological material [Inventory of radionuclides, no date]. In September 1994, 

DOE initiated the phase-out of production and began transitioning operations under Defense 

Programs to Environmental Management [DOE, no date-b, PDF p. 8]. 

The final mission for the Pinellas Plant was to clean up from the past radiological uses and 

transition to commercial uses [Martin Marietta 1996, PDF p. 12]. As workers came across the 

last war-reserve products (i.e., an asset amassed in peacetime to meet military requirements 

if war were to start), they calibrated the equipment (when required), disconnected, 

packaged, and shipped the equipment to Sandia National Laboratories in New Mexico [Pope 

2007, PDF p. 36]. The employees finished disconnecting the fabrication equipment in 

September 1995 [Pope 2007, PDF p. 28]. 

5.2 Internal Radiological Exposure Sources from Pinellas Plant 

Operations

The Pinellas Plant’s mission was small-volume production of selected high-technology 

nuclear weapon components, which required strict control of materials and processes in an 

ultra-clean environment [Martin Marietta 1993a, PDF p. 19]. NIOSH’s review of the nuclides 

handled over the history of the Pinellas Plant indicates that tritium was the only radionuclide 

handled in sufficient quantity and form to present a significant internal exposure for the 

Pinellas Plant workers. While the Pinellas Plant used krypton-85 (Kr-85) in substantial 

quantities, it is not a significant internal radiation dose concern. Kr-85 is a noble gas; it does 

not have a reaction within the body. It decays via beta decay to stable rubidium-85, which 

means there are no daughter products to decay and contribute internal dose. For a person 

surrounded by Kr-85, the effective (i.e., whole body) dose is primarily from the external 

exposure [ICRP 1994a, PDF p. 38]. Therefore, this report only addresses Kr-85 as an external 

exposure concern. Radionuclides other than the tritium and Kr-85 were mostly limited to 

sealed and plated check sources, static meter sources, sources used in instruments to detect 

combustible gasses, heat sources, calibration sources (Cs-137 was the most common sealed 

source) [Weaver 1995, PDF p. 2], thickness gauges, gas chromatograph sources, dew point 

measurement sources, and static eliminator sources. NIOSH considered plutonium because 

the Pinellas Plant implemented a bioassay program to ensure there was no internal exposure 

resulting from RTG work with the triply-encapsulated plutonium sources. The program 

confirmed there was no internal exposure resulting from plutonium at the Pinellas Plant. 

NIOSH also does not consider uranium, nickel-63, and carbon-14 significant internal dose 

concerns because of their physical containment and quantity at the Pinellas Plant. The 

Advisory Board on Radiation and Worker Health (ABRWH) Pinellas Plant Work Group

considered these other radionuclides during their site profile discussions and agreed that 

none were internal dose contributors [NIOSH 2012b; NIOSH 2016].

5.2.1 Tritium

Tritium is a radioactive isotope of hydrogen. Chemically it behaves very similarly to nonradioactive hydrogen. The tritium half-life is 12.3 years, and decay results in the production 
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of a stable helium-3 atom. The emitted beta particles have an average energy of 5.7 keV 

[ICRP 2008, PDF p. 33]. Because electrons below 15 keV do not have sufficient energy to 

penetrate the epidermal layer of the skin [NIOSH 2007, PDF p. 7], NIOSH does not consider 

tritium an external radiation hazard.

The Pinellas Plant had tritium present in the forms of tritiated water (also known as tritium 

oxide or HTO), tritium gas, organically bound tritium, and certain metal tritides. Based on 

available records, the predominant tritium exposure hazard to Pinellas workers was from

tritiated water and tritium gas. Between 1957 and 1993, annual tritium inventories at the 

Pinellas Plant ranged from 5.44 g (5.24 × 104 Ci) to 53.27 g (5.14 × 105 Ci) [Biedermann 1994, 

PDF p. 3].

The Pinellas Plant used tritium gas in various production and development processes 

associated with neutron generators. These processes involved transferring controlled 

amounts of tritium between a reservoir and a receiver material such as a plated metal 

surface. Pinellas controlled the exposure to tritium gas mainly through containment, process 

design, and ventilation. The Plant placed room air monitors in all areas where there was a 

potential to release tritium gas into the work area. The monitoring systems included a 22-

liter Kanne ionization chamber connected to a Beckman linear picoammeter. Each 

monitoring system had an alarm with a visual indicator set to alert at 80 μCi/m3 [Ward 1973, 

PDF p. 2]. A worker exposed to tritiated water at a rate of 80 μCi/m3 for an hour would 

receive a dose of approximately 9.6 mrem. This dose rate includes the International 

Commission on Radiological Protection (ICRP) recommended factor of 1.5 to account for 

potential skin absorption [ICRP 1994a, PDF p. 90; ICRP 1994b, PDF p. 20; DOE 2007, PDF p. 

117].

During the production process at the Pinellas Plant, workers only handled tritium as a gas or 

solid. However, tritiated water forms whenever quantities of gaseous tritium come into 

contact with air containing water vapor because the tritium exchanges with non-radioactive 

hydrogen in airborne water vapor. This soluble form of tritium was the form measured in 

urine bioassay for internal doses reported by the Pinellas Plant. Based on NIOSH’s research 

into the records, the predominant exposure hazard to workers was from tritiated water and 

tritium gas. The primary means of protection against exposure to tritiated water are the 

same as for tritium gas: containment, process design, and ventilation.

In some circumstances within the tritium areas, there was an exposure potential from 

organically-bound tritium compounds to those working with materials such as pump oils and 

organic solvents. Turbo and vacuum pumps used in systems at the Pinellas Plant periodically 

required maintenance, including changing the oil. For pumps located in tritium areas, the 

tritium could contaminate the pump oil. After workers drained the oil from a pump, they 

collected a sample of the oil for tritium analysis. Oils and solvents in tritium areas were 

handled, accumulated, and stored for disposal as if contaminated [Burkhart 1990, PDF pp. 

19, 29, 30, 32, 33, 35, 37, 39; Pinellas Plant 1993].

At the Pinellas Plant, both soluble forms of tritium and insoluble tritium compounds (i.e., 

certain metal tritides) were present as a source of potential exposure in the same areas.

During the production process, the tritium reacts with metal surfaces, coatings, and powders 
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for various purposes [Burkhart 1995, PDF p. 2]. Metal tritides, formed during production 

processes, could have escaped into the work environment as particulate aerosols.

The Pinellas Plant used titanium tritide in the original tritium storage beds, sealed inside a 

glass cylinder [Burkhart 1990, PDF p. 10]. The glass cylinders broke on occasion, resulting in 

release of tritium. In 1968, Pinellas replaced the original glass tritium storage beds with 

uranium hydride in stainless-steel cylinder tritium storage beds [Historical report of 

radiation, no date, PDF p. 7; Phillips 1975, PDF p. 2]. The stainless-steel tritium storage beds 

utilized depleted uranium tritide [Burkhart 1990, PDF p. 10; Eichman 1979, PDF p. 3].

5.2.2 Plutonium

The Pinellas Plant used triply-encapsulated plutonium when producing RTGs. Plutonium is a 

reactive, metallic, transuranic element. The Pu-238 radioisotope decays by alpha particle 

emission with a half-life of 87.8 years. Pu-238 emits alpha particles with an energy of 5.50 

MeV in approximately 72% of decays, while the remainder have an energy of approximately 

5.46 MeV [ICRP 2008, PDF p. 90]. Pu-238 has a relatively high specific activity and an 

energetic decay alpha (5.50 MeV), making it the choice for a compact, inherent heat source

[IT/Radiological Sciences Laboratory 1986, PDF p. 17]. The radioisotope Pu-239 also decays 

by alpha particle emission with a half-life of 24,131 years and three possible energies: 5.10 

MeV, 5.14 MeV, and 5.16 MeV with a relative abundance of 11.5%, 15.1%, and 73.1% 

respectively.

The first known receipt of plutonium at the Pinellas Plant was in January 1957. It was a 7g 

Pu-239 calibration source used for health physics monitoring equipment [First plutonium 

delivered, no date, PDF p. 2]. Triply-encapsulated plutonium oxide (238PuO2) heat sources for 

the RTGs began arriving in November 1975, when Pinellas received seven heat sources 

totaling 54.4 grams of Pu-238 from Sandia Laboratories [First plutonium delivered, no date, 

PDF p. 2]. There were two different sizes of the 238PuO2 heat sources: 8.75 g and 10 g 

sources. The typical composition was 11.8% oxygen and 88.2% plutonium (80.2% of which is 

Pu-238) by weight [GE 1982a, PDF p. 39]. The small, sealed plutonium capsules were always 

produced at another DOE site [Internal dosimetry practices 1983] and were not altered by 

operations or destructively tested at the Pinellas Plant [HRS 1995; NIOSH 2012b, PDF p. 28]. 

The triple-encapsulations ensured complete containment of the plutonium under the most 

extreme potential accident conditions. Design criteria for the units included the ability to 

withstand exposure to a 1,000-degree Centigrade fire for one hour and withstand impact on 

an unyielding steel surface at a velocity of 150 meters/second without losing structural 

integrity [GE 1989a, PDF p. 76].

The Pinellas Plant received the triply-encapsulated plutonium sources at Building 400, which 

housed the RTG facility [GE 1982a, PDF p. 34]. Pinellas Plant staff conducted work area 

monitoring for plutonium in Building 400 using continuous air monitors with alpha 

spectrometers and a strip-chart recorder. The Plant also utilized discrete air sampling using 

filters to determine the airborne levels of plutonium in the workplace; the filters were 

changed monthly and analyzed [IT/Radiological Sciences Laboratory 1986, PDF p. 19].
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The Pinellas Plant conducted RTG assembly and test operations in the eastern portion of 

Building 400. NIOSH has not located information regarding the annual inventories of the RTG

heat sources beyond the initial shipment in 1975. Except for the unpacking procedure, the 

source-cleaning operation, and the actual assembly operation, the Pinellas Plant kept the 

triply-encapsulated sources in stainless-steel source storage containers. In 1990, the RTG 

product line was discontinued [Martin Marietta 1992, PDF p. 20], and DOE removed the

plutonium from the site. The Pinellas Plant Annual Site Environmental Report for Calendar 

Year 1992 specifically states "All plutonium, with the exception of calorimeter sources and 

small instrument calibration check sources, was removed from the plant in February 1991” 

[Martin Marietta 1993a, PDF p. 54]. A 1993 survey documented the removal of all 

radioactive materials from Building 400 and that there was no plutonium contamination 

present [Pharo 1993, PDF p. 2]. 

Even though the encapsulations ensured complete containment and the plutonium was in 

shard form to minimize the potential for respirable-size particles, Pinellas began an 

Environmental Monitoring Program because of the presence of the encapsulated material 

on the plant site [Internal dosimetry practices 1983, PDF p. 2]. Out of an abundance of 

caution, workers assigned to the RTG project submitted a pre-operational 24-hour urine 

sample [Internal dosimetry practices 1983, PDF p. 2]. Those working with RTG sources 

submitted annual samples while assigned to the work [Internal dosimetry practices 1983, 

PDF p. 2]. The plutonium urine sampling program concluded in 1992. During meeting 

discussions [NIOSH 2011b; NIOSH 2012b; NIOSH 2016], the ABRWH Pinellas Plant Work 

Group determined there was no credible potential for personnel internal dose from activities 

involving plutonium [ORAUT 2016a, PDF p. 12; NIOSH 2016]. The weight of evidence, 

including the process knowledge, the confirmatory measurements, and the modeling 

calculations demonstrate a low exposure potential [NIOSH 2011b, PDF p. 72–84].

5.2.3 Uranium

Both depleted and natural uranium were present at the Pinellas Plant. Uranium isotopes 

emit alpha particles and X-rays; however, some of the radioactive progeny emit beta 

particles and gamma rays. Beginning in 1968, the Pinellas Plant used depleted uranium in

the tritium storage beds. The U-238 radioisotope, the predominant isotope in both depleted 

and natural uranium, decays by alpha particle emission with a half-life of about 4.5 billion 

years. The U-238 radioisotope decays with the emission of 4.3 MeV alpha particles in 

approximately 77% of decays, while the remainder have an energy of approximately 4.1 

MeV [ICRP 2008, PDF p. 88].

The Pinellas Plant used uranium-hydride flasks as a “hydrogen-isotope reservoir to hold gas 

at essentially zero pressure in a solid state, release the gas to a processing vacuum system by 

application of heat, and resorb the gas to a pressure in the microns-of-mercury range” 

[Ward 1973, PDF pp. 30–31]. The flasks were stainless-steel cylinders, sealed with a 

stainless-steel gold sealed valve. The occluding material was 50 grams of depleted uranium 

powder [Ward 1973, PDF p. 31]. Since the uranium is sealed in the stainless-steel cylinders, it 

did not pose a significant internal dose hazard. The Pinellas Plant reported that the surveys 

conducted at the time showed no uranium contamination [ORAUT 2013a, PDF p. 5]. There 

were no reported incidents for the Pinellas Plant relating to a uranium release or uranium 
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fire incidents, which would be an indicator of uranium release from the cylinders. The 

uranium at Pinellas was contained when used for tritium storage. 

NIOSH is aware of accidental tritium release incidents from the smaller uranium-tritide 

storage beds requiring Pinellas to take the beds out of service; one example resulted in a 

tritium contamination incident [Phillips 1975, PDF pp. 2–4]. A May 1975 memo states “the 

contamination incident which occurred on January 31, 1975 to our knowledge is the first

such incident in the seven year usage of uranium beds...” [Phillips 1975, PDF p. 2], indicating 

the Pinellas Plant began using uranium in the storage beds in 1968. None of the reported 

incidents at the Pinellas Plant were uranium-release or uranium-fire incidents, supporting 

NIOSH’s understanding that the Pinellas Plant stored uranium in containers. Based on the 

available information, NIOSH has determined that the depleted uranium in the uraniumtritide storage beds was not an internal exposure concern at the Pinellas Plant.

The Pinellas Plant used borosilicate glass doped with natural uranium (1.5% by weight) in the 

form of U3O8 [Pinellas Plant 1992–1994, PDF p. 2]. The uranium would have been

encapsulated in the glass at the manufacturer before it arrived at the Pinellas Plant; 

therefore, the glass is considered a sealed source on arrival and would have posed little to 

no internal radiation dose hazard.

Neither the depleted nor the natural uranium used at Pinellas Plant was available as a 

routine, occupational internal exposure source and presented little to no internal dose 

hazard. 

5.2.4 Carbon-14

Pinellas Plant’s Radioactive Waste Implementation Plan stated that “Small quantities of 

carbon-14 labeled solvents are used in a laboratory operation which evaporates the solvent 

to the Plant's east exhaust stack” [GE 1984a, PDF p. 9]. The Pinellas Plant Environmental 

Monitoring Report 1983 also describes the Pinellas Plant using carbon-14 as a solvent label in 

laboratory operations [GE 1980, PDF p. 13; GE 1984b, PDF p. 15]. Carbon-14, a naturally 

occurring radioisotope, decays by beta particle emission into stable nitrogen-14 and has a 

half-life of 5,730 years. The beta particles have an average energy of 49.5 keV [ICRP 2008, 

PDF p. 33].

The only indications of carbon-14 use at the Pinellas Plant come from the gaseous effluent 

monitoring. The Pinellas Plant reported carbon-14 airborne effluent from the Building 100 

laboratory stack between 1979 and 1984 [HRS 1994, PDF p. 37]. There were no other 

indications of carbon-14 in use at the Pinellas Plant, nor any other occupational exposure 

pathways identified for plant workers.

The ABRWH Work Group discussed carbon-14 handing at the Pinellas Plant during their 

review of the site profile, saying the quantity of material was considered “negligible” and 

contributed less than a mrem per year dose when modeled by the Integrated Modules for 

Bioassay Analysis (IMBA) software program [NIOSH 2009, PDF pp. 57–58].
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5.3 External Radiological Exposure Sources from Pinellas Plant 

Operations

The activities with a potential for external radiation exposure at the Pinellas Plant included 

testing the neutron tubes and neutron generators, working near the plutonium oxide heat 

sources, using other radiation-generating devices, and in rare instances, external exposure 

to Kr-85 gas leaks. The radiological materials with potential for external exposure included 

Kr-85, carbon-14, and plutonium. The depleted uranium used in the tritium storage beds 

presented no significant external radiation hazard due to the low specific-activity and the 

non-penetrating radiation emitted. Processing uranium-doped borosilicate glass at the 

Pinellas Plant involved both cutting and chemically etching the glass. Pinellas assessed 

worker exposures during these processes and estimated worst-case whole body exposures 

were well below the U.S. DOE annual limits (i.e., 5,000 mrem/year whole body). The 

calculated highest dose would have been 15 mrem/year whole body [Pinellas Plant 1992–

1994, PDF p. 27]. The Pinellas Plant used other radionuclides; however, they were mostly 

limited to sealed and plated check sources such as static meter sources, sources used in the 

instruments to detect combustible gasses, heat sources, calibration sources, thickness 

gauges, gas chromatograph sources, dew point measurement sources, and static eliminator 

sources [Pinellas Plant radioactive, no date].

While radioactive materials and radiation-generating devices were necessary to the product 

manufacturing, the majority of the work performed at the Pinellas Plant did not involve 

exposures to external sources of radiation. This lack of external radiation exposure potential 

is why the Pinellas Plant did not monitor many workers for external doses.

5.3.1 Photon

The majority of the photon radiation exposures in the Neutron Generator Production Areas 

would have been from testing neutron tubes and neutron generators. The neutron 

generators also produce some X-rays by interactions within the accelerator [NCRP 1983, PDF 

p. 8].

In the RTG Production Areas (Building 400), the majority of the photon radiation exposures 

were from 238PuO2 heat sources. The 238PuO2 heat sources emitted gamma radiation, with a

typical neutron to gamma ratio of about 2.5 (at approximately 2 feet) [Weaver 1989, PDF p. 

7]. These plutonium heat sources accounted for the majority (approximately 67%) of the 

Plant’s photon dose in 1990 [Harder 1991, PDF p. 4].

Before its relocation to Building 800, the Chemistry laboratory in Building 100 used a Model 

200 HP Ion Implanter accelerator.

Specific photon-energy distribution information is available for only the Component Testing 

Area of Building 100 (Area 109), where Pinellas used Kr-85. Kr-85 is a radioactive

(beta/gamma emitting) noble gas with a maximum beta energy of 687 keV and a low yield 

500 keV gamma. The Plant used Kr-85 in two leak-detection systems, as described more 

completely in Section 5.3.2. For all other areas, NIOSH assumes 100% of the photons are 30 

to 250 keV photons.
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5.3.2 Beta

The potentially significant sources of electron radiation with sufficient energy to penetrate 

the skin were Kr-85 and radiation-producing devices such as X-ray diffraction and electron 

beam devices.

Krypton-85 is a noble gas with a radioactive half-life of 10.7 years that emits beta particles 

with an average energy of 251.4 keV [ICRP 2008, PDF p. 42]. Kr-85 decays into stable 

rubidium-85 through beta particle emission 99.57% of the time. The maximum energy of the 

beta particle is 687 keV with an average energy of 251 keV. The alternative Kr-85 decay 

mode is 0.43% of the time by beta emission with a maximum energy of 173 keV, followed by 

514 keV gamma emission [IT/Radiological Sciences Laboratory 1986, PDF p. 14].

External radiation exposure to Kr-85 gas occurs only while a person is exposed to a cloud of 

the gas, causing the possibility of a skin dose [Weaver, no date, PDF p. 2]. It was used in 

relatively small quantities in two leak-detection systems (Radiflo and TRACER-flo) at the 

Pinellas Plant, operating from September 1963 until 1996 [Burkhart 1990, PDF pp. 14–15; 

Forest 1959–1962, PDF p. 253]. Pinellas used the systems to pressurize hermetically-sealed 

components under known time, pressure, and gas concentration conditions to detect leaks 

in the components [Detlefs 1993, PDF p. 4]. An April 1963 Health Physics Report states, “The 

radionuclide, krypton 85, was introduced into the Radiflo unit on September 24. Leaks in the 

unit resulted in a loss of 2.0 curies” [Forest 1963a, PDF p. 4]. The Pinellas Plant recovered

most of the Kr-85 gas after each use but lost small amounts through the tested components. 

Pinellas received the Radiflo leak-detection system preloaded with 10 to 40 Ci of krypton 

gas. A service technician from the manufacturer typically added 5 to 10 Ci once each year 

after the initial delivery [ORAUT 2007b, PDF p. 3]. Pinellas placed the Radiflo and TRACER-flo 

leak-detection systems in separate rooms in Building 100, Area 109 (the Component Testing 

Area) [IT/Radiological Sciences Laboratory 1986, PDF p. 4; DOE 1987, PDF p. 216] and 

surrounded them with ventilation shrouds [DOE 1983, PDF p. 35; DOE 1987, PDF p. 216]. 

Each shroud connected to ductwork exhausting 3,300 ft3/minute to the east main exhaust 

stack. Kr-85 submersion exposures would only have occurred during incidents involving gas 

leaks from either the Radiflo or the TRACER-flo systems, rather than from small amounts 

leaking from the components tested during normal operation. During such incidents, beta

radiation fields would have been temporarily present in the rooms housing the systems, and 

non-routine external exposures may have occurred. Pinellas removed all Kr-85 gas from the 

site by the end of 1996 [Martin Marietta 1997a, PDF p. 12].

The Pinellas Plant used X-ray diffraction and electron-beam devices to analyze samples and 

to produce heat to either evaporate or weld material in the beam. It was possible for 

workers to receive electron radiation exposures from such devices if the beam containment 

was compromised. The Pinellas Plant located these radiation-generating devices in Building 

100, Building 300, Building 800, and in the 1200 Area [Martin Marietta 1994–1995; Pinellas 

Plant 1976–1987]. However, it was more probable that any exposures from these devices 

would have been from scattered X-rays or bremsstrahlung production and not from a freeelectron beam.

The Pinellas Plant did not normally assess electron exposures in Building 800, where they 

calibrated portable radiation dose-rate instruments, unless there was an accident with the 
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sealed 120 Ci Cs-137 calibration source. The sealed source was in a shielded cabinet in the 

concrete Building 800 [ORAUT 2017a, PDF p. 11; GE 1971–1984, PDF pp. 81–86].

Carbon-14 is a beta-emitting radionuclide with a half-life of 5,730 years. The average and 

maximum beta particle energies are 49.5 keV and 156.5 keV, respectively [ICRP 2008, PDF p. 

33; Kocher 1981, PDF p. 79]; therefore, they are above the 15 keV threshold and are an 

external dose concern. A 1979 and a 1983 environmental assessment indicate that small 

quantities of carbon-14 labeled solvents were used in a laboratory testing operation [GE

1980, PDF p. 13; DOE 1983, PDF p. 26]. A 1980 reference describes the quantities used as 

exempt [Pinellas Plant 1980, PDF p. 3]. NIOSH has not found any documentation to indicate 

any other uses of carbon-14. The Gaseous Effluent Release Reports and an Environmental 

Assessment between 1979 and 1983 are the only indicators that carbon-14 was used and 

monitored in the effluent releases at the Pinellas Plant [DOE 1983, PDF p. 27; GE 1980, PDF 

p. 16; GE 1981, PDF p. 17; GE 1982b, PDF p. 17; GE 1983a, PDF p. 17; GE 1984b, PDF p. 17].

The Pinellas Plant reported the average maximum ground-level concentration to be

significantly less than 0.1 percent of the recommended guidelines for continuous nonoccupational exposure [GE 1980, PDF p. 16; GE 1981, PDF p. 17; GE 1984b, PDF p. 17]. Based 

on the reported gaseous effluent releases for the years 1979 through 1983, the Pinellas 

Plant used carbon-14 in much smaller quantities than tritium. During their review of the 

Pinellas Plant site profile, the ABRWH discussed carbon-14 handing at the Pinellas Plant and 

asked that carbon-14 be addressed in the site profile documents though the quantities of 

carbon-14 handled were considered “negligible” (less than a mrem per year dose 

contribution) [NIOSH 2009, PDF pp. 57–58].

The predominant, though not significant external exposure concern, source of electron 

radiation at the Pinellas Plant was tritium [ORAUT 2017a, PDF p. 10; DOE 1983, PDF p. 25].

The average beta particle energy from tritium is 5.7 keV and the maximum is 18.5 keV. The

maximum range of the beta particle is less than 5 millimeters in air. The range of this beta 

radiation is about 0.6mg/cm2 [Weaver 1989, PDF p. 7], which is less than the thickness of the 

epidermal layer of the skin [NIOSH 2007]; therefore, NIOSH does not consider tritium to be 

an external radiation hazard.

5.3.3 Neutron

There were two distinct sources of neutrons at the Pinellas Plant: (1) the neutrons produced 

by radiation-generating devices, and (2) those produced by the sealed 238PuO2 heat sources 

used for the RTGs.

The neutron generator was the Pinellas Plant’s primary product and the most common type 

of radiation-generating device at the site. Such devices generate neutrons with either the 

T(d,n)4He fusion reaction or the D(d,n)3He fusion reaction (also notated as D-T and D-D 

reactions, respectively) and only produce neutrons when electrically activated. Most units 

produced at the Pinellas Plant were the D-T type that produced 14 MeV neutrons. There 

were reportedly a few 2.5 MeV neutron (D-D reaction) units [Weaver 1989, PDF p. 7]. These 

sources produce a distribution of neutrons at various energies versus neutrons at a single 

discrete energy. Neutron generators are miniaturized linear ion accelerators with a pulsed 

electric power supply. They do not produce neutrons unless they are energized (similar to 
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other accelerators) such as when the neutron tubes or the completed neutron generators

are being tested. These tests were conducted as benchtop operations and were controlled

from a short distance (i.e., 5-feet) away. Test stations were set up in multiple areas within

Building 100 and operated according to the workloads that changed each year. These 

locations sometimes changed over the years. Plexiglas shielding was used along with 

distance to reduce worker exposure. The neutron generators at the Pinellas Plant produced

radiation exposure for less than 60 seconds [Weaver 1996a] when the Plant conducted test 

shots and workers were not allowed within three feet of the device. These test shots do not 

produce large amounts of neutrons for extended periods of time and there was neutron 

monitoring at each station [SC&A/Salient 2006, PDF p. 51].

The Pinellas Plant also used an ion accelerator, a Model 200 HP Ion Implanter [Malbrough 

1983, PDF p. 5]. It was a Cockroft-Walton-type linear ion accelerator, first installed in 1975 in 

Area 161 of Building 100 for use by the Chemistry Laboratory [GE 1977, PDF p. 6; Malbrough 

1983, PDF p. 5]. In 1979, Pinellas relocated the accelerator to Building 800, where they used 

it for a larger variety of activities that included target assessment and material analysis work 

[Malbrough 1983, PDF p. 5].

From 1975 through 1990, Building 400 produced RTGs that contained small, sealed 238PuO2

heat sources [First plutonium delivered, no date; Martin Marietta 1992, PDF p. 20]. The 

plutonium oxide generated neutron radiation from the alpha-n reaction and spontaneous 

fission. These plutonium heat sources were the only sources of measurable neutron 

exposures at the Pinellas Plant in 1990 [Harder 1991, PDF p. 4]. The neutrons from the heat

sources fell into two energy groups: (1) 0.1-2 MeV and (2) 2-20 MeV with equal frequency. 

NIOSH assumes the typical workload to have been 50 generators per month for perhaps 

three personnel [ORAUT 2017a, PDF p. 28; Holliday 1983, PDF p. 3; Proposed increase 1988, 

PDF p. 6].
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6 Summary of Available Monitoring Data and Data Sufficiency for the 

NIOSH-Evaluated Class

The subsections below provide the following information for the Pinellas Plant class under 

evaluation:

 Overviews of the state of the available internal and external monitoring data, 

environmental monitoring data, and occupational medical X-ray data. 

 Evaluations of the sufficiency of the specified data. Data sufficiency addresses the 

background, history, and origin of the data. This includes 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.

6.1 Available Pinellas Plant Internal Monitoring Data and Data 

Sufficiency

Potential internal exposures at the Pinellas Plant between 1957 and 1990 were primarily 

associated with the inhalation of radionuclides. NIOSH’s review of the Pinellas Plant internal 

monitoring program procedures shows that managers were required to direct employees 

whose work assignments had a potential for intakes to tritium to submit urine samples. The 

Pinellas Plant Internal Dosimetry Program included using tritium bioassay daily, weekly, or 

monthly, depending on the workers’ recent tasks [GE 1984c, PDF p. 3; Burkhart 1995, PDF p. 

10]. The Pinellas Plant determined the routine sampling frequency based on the likelihood of

exposure. NIOSH reviewed monitoring data from 1957–1972 and determined that the urinesampling frequency was usually weekly.

Beginning about 1986, the Pinellas Plant based their bioassay program on ANSI standard 

N13.14-1983 [Burkhart 1995, PDF p. 9; ANSI 1981]. Participation was determined based on 

the recommendations in the standard and included:

 Anyone with the potential to receive 100 mrem/year from tritium

 Declared pregnant workers likely to receive more than 50 mrem/gestation period

 All personnel who worked with or handled tritium contaminated systems or equipment

In later years, the frequency generally followed the criteria as described in the Pinellas Plant 

site profile documentation as follows [Burkhart 1995, PDF p. 10]: 

Daily or on each performance:

 Work on open neutron generator tubes or tube processing equipment 

 Maintenance on vacuum pumps, glove boxes, or exhaust systems including the Tritium 

Recovery System (TRS)

 Instances of area contamination
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 Packaging and disposal of radioactive waste

Weekly: 

 Operation of contaminated processing or analysis equipment

 Decontamination of materials and facilities

 Packaging and disposal of radioactive wastes

Monthly: 

 Handling processed tubes (slight potential of measurable exposure)

The following subsections summarize the in vitro bioassay data, air data, and alternative 

data available to help evaluate internal doses. There was no in vivo monitoring performed at 

the Pinellas Plant. The subsections also present evaluations of the sufficiency of the specified 

data. The Technical Basis Document, Pinellas Plant – Occupational Internal Dose [ORAUT 

2016a], presents the various analyses used and the associated minimum detectable 

activities.

6.1.1 In Vitro Analysis Data and Data Sufficiency

The Pinellas Plant’s general operating procedures clearly defined the required frequencies 

and participation criteria for tritium monitoring through urine bioassay [GE 1969–1983, PDF 

pp. 64, 83]. Depending on the location and probability of tritium uptake, Pinellas assigned 

workers to different bioassay frequencies. For example, in 1984 GE Operating Procedure 

G.1.12, Assignment of Personnel to Work in Radioactive Material, Contamination or 

Radiation Areas stated that workers handling contaminated equipment were to provide 

samples daily; workers operating contaminated equipment were to provide samples weekly; 

and workers with a slight potential for uptake such as those handling processed tubes were 

to provide samples monthly [GE 1984c].

NIOSH has primary radiation exposure reports including tritium urinalysis results, 

termination bioassay sample results, bioassay tabulation forms (1957–1958), exposure 

record cards (1959–1965), dose adjustment forms (1957–1982), bioassay dose summary 

reports, dosimetry cards for individuals, and individual plutonium in vitro bioassay results for 

the years 1976 through 1986 [Pinellas Plant 1975–1986; Pinellas Plant 1976–1986]. Annual 

dose summary reports are also available as electronic records from 1967 through 1975. Early 

in the Pinellas Plant’s operational history (i.e., from 1959–1963), monthly health physics 

reports presented only the total number of personnel monitored, either for external dose, 

for internal dose, or both for the month, with a maximum exposure and average exposure in 

mrem [Forest 1959–1962]. These reports generally characterized the personnel as 

manufacturing, engineering, employee and community relations, quality control, or 

laboratory workers. The reports also generally documented the number of bioassay samples 

collected, but there is no way to directly correlate the number of samples to the number of 

individuals monitored until the ALARA reports began reporting the number of individuals. 

NIOSH’s review of ALARA reports indicates that the Pinellas Plant monitored approximately 

12% of workers for tritium intakes from 1986 through 1995. (In November 1993, DOE 
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initiated the phase-out of production and transition to Environmental Management began. 

The number and percentage of workers internally monitored increased for 1994 and 1995.) 

See Section 7.4.9 of this report for additional discussion of the percentage of monitored 

workers. Because Pinellas Plant workers often changed jobs at the site throughout their 

employment (which could have changed their potential to receive a dose), when looking at 

general monitoring trends, NIOSH must rely on the Pinellas Plant’s reported numbers of 

individuals monitored. Fortunately, many Pinellas Plant dosimetry records for individuals 

include cards or notations regarding the start and stop dates for internal dose monitoring. 

For this evaluation, NIOSH looked at the number of monitored workers and the potential for 

unmonitored workers. Table 6-1 below provides the number of NOCTS claimants as of May 

3, 2021, employed at the Pinellas Plant each year, and the number of those who had at least 

one tritium urine sample result in that year. In their report, Review of the NIOSH Site Profile 

for the Pinellas Plant Site, SC&A included a finding regarding “Missing Internal Dose 

Estimation Methods for Unmonitored Workers, such as Maintenance and Support 

Personnel, Not Provided” [SC&A/Salient 2006, PDF p. 14]. Table 6-1 also indicates the 

number of maintenance workers within the claimant pool. NIOSH counted a worker as a 

maintenance worker if the job title included the word “maintenance,” as reported by them 

or their survivors during Computer Assisted Telephone Interview (CATI) calls with NIOSH. 

The final column of the table indicates the number of those maintenance workers with 

tritium results that year.

Table 6-1: Pinellas Claimants with Tritium Resultsa

Year

Number of 

Pinellas 

Claimants (all job 

titles) in NOCTSb

Number of Pinellas 

Claimants with 

Tritium Results

Number of 

“Maintenance”

Claimants (by job 

title) 

Number of 

“Maintenance” 

Claimants with 

Tritium Results

1957 110 12 10 1 

1958 162 21 14 5 

1959 178 42 19 9 

1960 199 52 19 15

1961 212 56 20 12

1962 218 54 20 11

1963 218 45 21 10

1964 224 52 22 15

1965 219 47 21 12

1966 241 60 22 16

1967 248 57 22 16

1968 260 56 24 14

1969 259 56 24 11

1970 263 47 26 9 
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Year

Number of 

Pinellas 

Claimants (all job 

titles) in NOCTSb

Number of Pinellas 

Claimants with 

Tritium Results

Number of 

“Maintenance”

Claimants (by job 

title) 

Number of 

“Maintenance” 

Claimants with 

Tritium Results

1971 264 41 26 12

1972 268 38 26 9 

1973 271 32 25 8 

1974 267 44 25 11

1975 264 37 24 7 

1976 274 40 26 10

1977 282 29 29 8 

1978 297

29

33 31 11

1979 314 32 9 

1980 320 35 31 11

1981 329 34 35 10

1982 343 31 34 10

1983 345 38 36 8 

1984 349 35 37 8 

1985 354 25 37 6 

1986 343 26 36 7 

1987 330 21 36 6 

1988 310 8 34 1 

1989 299 3 0 0 

1990 288 10 32 1 

1991 280 14 32 2 

1992 268 37 34 4 

1993 190 9 0 0 

1994 162 19 17 4 

1995 127 1 0 0 

1996 89 12 6 1 

a. Source: [ORAUT 2021f]

b. Based on NOCTS start and end dates (i.e., number employed within that year)

Table 6-2 below shows the reported total assigned internal dose, the number of monitored 

individuals, and the average individual internal dose reported by the Pinellas Plant in the 

ALARA reports. The Pinellas Plant ALARA reports from 1988 through 1995 are available. The 

1988 ALARA report includes data from 1986 and 1987. Both the total internal dose and the 

average individual internal dose generally followed a downward trajectory from 1986 
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through 1990 (reported years within the evaluated period) and continued in the same 

direction until the employees finished disconnecting the fabrication equipment in 1995. 

1995 Annual ALARA Program Report for Ionizing Radiation reports information on site-wide 

exposure to tritium for the period from 1988 through 1995, during which time the average 

exposure was between 0.08 and 4.38 mrem with an annual maximum value of between 6 

and 130 mrem [Weaver 1996b, PDF p. 15]. The maximum value is the highest individual dose 

for the year. This indicates tritium exposures were low throughout the facility during this 

period. These averages and maximums each year include incident precipitated bioassay 

sampling. Examples of such incident-precipitated bioassay sampling are available throughout 

the facility's history in the health physics summary reports.

Table 6-2: Summary of Pinellas Internal Monitoring Data for Tritium 1986–1995a

Year Number

Monitored

Total Dose

(person-mrem)

Average Dose 

(mrem)

Highest Individual 

Dose (mrem)

1986 194 699 3.60 86

1987 139 358 2.58 105

1988 129 565 4.38 130

1989 201 557 2.77 97

1990 177 184 1.04 31

1991 202 390 1.93 101

1992 164 150 0.91 35

1993 134 103 0.77 21

1994 217 17 0.08 6.3

1995 215 224b 1.04 93b

a. Sources: [Weaver 1993a, PDF pp. 20, 23; Weaver 1996b, PDF p. 15] 

b. Includes dose from a single incident in which one individual received an exposure of 93 mrem. 

The total site dose and highest individual dose (excluding this one individual) were 131 and 23 

mrem, respectively.

The NOCTS claimant files and the SRDB include a significant quantity of in vitro bioassay data 

for monitored Pinellas Plant employees, including 50 self-identified maintenance workers (as 

of May 3, 2021). Individual urine sample results for tritium are available for all years, 1957–

1996, in primary data form. These are sometimes in dose adjustment forms, radiation 

exposure reports, urinalysis cards, etc. (see Table 6-3 below). NIOSH also has access to 

personal exposure summary (secondary) data, including tritium dose summary data 

(available in SRDB documents) for all years except 1959–1962, 1967–1974, 1980, 1982–

1983, and termination occupational exposure reports with internal and external total 

occupational assigned doses [Pinellas Plant 1960–1978; Pinellas Plant 1978]. Table 6-3 below 

lists the forms used to document internal dose at different times during operations at the 

Pinellas Plant. The forms include individual bioassay results as concentrations of tritium in 

urine in μCi/l, doses calculated from these results in mrem, photon and neutron exposures 
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measured in mrem, or rem in the case of the Annual Occupational Radiation Exposure form, 

and summary data. 

The Bioassay Tabulation (MUL-101), Exposure Record (MUL-334), and Bioassay Exposure 

Record (FC-600) forms were very similar and contained handwritten tritium bioassay results 

and doses. These forms were individual to each worker and included their name and badge 

number with an entry for each bioassay sample, including the date, concentration in μCi/l, 

and dose in mrem, although the Bioassay Tabulation labeled these as millirad. The Personnel 

Monitoring Record (FC-600) and Personnel Monitoring Record (NFC 1163) recorded external 

dosimetry data on the front of the form and tritium bioassay date, concentration in μCi/l, 

and the dose in mrem on the back of the form. The back of the form also repeated the badge 

number. These forms include detailed bioassay results and NIOSH considers them primary 

data. 

The Annual Occupational Radiation Exposure form was a computer printout that 

summarized the worker’s external and internal exposure. This form listed tritium dose in 

rem. The Dose Report form was a summary printout for all workers and listed external and 

internal dose with tritium dose reported in mrem. Both of these forms include summary 

data and NIOSH considers them secondary data. 

Table 6-3: Pinellas Plant Internal Dose Record Series (Personnel Files)

Form Name or Description Applicable 

Years

Summary Dataa

(Yes or No)

Detailed Datab

(Yes or No)

Bioassay Tabulation (MUL-101) 1957–1958 Yes Yes

Exposure Record (MUL-334) 1959–1965 Yes Yes

Annual Occupational Radiation Exposure for 

Calendar Year

1964–1970 Yes No

Bioassay Exposure Record (FC-600) 1964–1970 Yes Yes

Personnel Monitoring Record (FC-600) 1970–1979 No No

Urinalysis Data (backside of Personnel 

Monitoring Record FC-600)

1970–1979 Yes Yes

Personnel Monitoring Record (NFC 1163) 1980–1987 Yes No

Urinalysis Data (backside of Personnel 

Monitoring Record NFC-1163)

1980–1987 Yes Yes

Dose Report 1988–1995 Yes Yes

a. NIOSH considers internal summary data (e.g., compiled spreadsheets) as secondary data.

b. NIOSH considers internal detailed data (e.g., individual monitoring results) as primary data.

NIOSH reviewed all Pinellas Plant claims to determine whether internal and/or external 

personal monitoring records were available for each year evaluated (i.e., to ensure there 

were no outstanding temporal gaps in the records). NIOSH’s review showed that internal 

and external monitoring results for the evaluated period, 1957 through 1990, are available in 

the NOCTS claimant files. NIOSH reviewed the data that it has recovered from different 
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record holdings (contained in the SRDB) and then compared the results to data provided by 

DOE in response to NIOSH requests for claim data. There was very good agreement between 

the two sources of dosimetry results, meaning that data received from DOE mirrored the 

NIOSH records in the SRDB. Section 7.4.9 of this report describes this review in more detail. 

6.1.2 Air Monitoring Data Sufficiency

NIOSH has not found any indications of the Pinellas Plant conducting personal air monitoring 

or breathing-zone sampling during the evaluated period. From as early as April 1957, Pinellas 

performed routine area monitoring for airborne tritium radioactivity [Pinellas Plant 1957–

1973, PDF p. 2]. The Pinellas Plant located fixed-room monitors in all areas where there was 

a potential for the release of tritium. As described previously in Section 5.2.1, the airborne 

tritium monitoring systems consisted of 22 L Kanne ionization chambers connected to a 

picoammeter and an alarm panel. In 1973, there were 40 sampling ports and 20 monitors. A 

Kanne ionization chamber monitor was capable of detecting tritium below the U.S. Atomic 

Energy Commission (AEC) 40-hour level of 2 × 10-5 μCi/mL (i.e., the derived air concentration 

agreed to by DOE and the NRC) [ORAUT 2016a, PDF p. 16; Ward 1971a; Weaver 1990a, PDF 

p. 2].

A May 3, 1957 Health Physics Summary Report describes a mobile monitor designed and 

fabricated for use as an operational air monitor [Pinellas Plant 1957–1973, PDF p. 3]. The 

Pinellas Plant used portable tritium gas monitors/ion chambers as temporary monitors in 

areas where fixed-room monitor probes were not located [DOE 1991, PDF pp. 125–126]. The 

Pinellas Plant also set up portable samplers using silica-gel collection media or silica-gel 

stations in some areas.

Various “check sheets” capture routine survey data at the Pinellas Plant. Pinellas specifically 

captured air monitoring results on the “Air Monitor Check Sheet” and “General Atmosphere 

Monitor” forms found in the Pinellas Plant records. These forms accompany dose records, 

incident investigations, and routine in-plant survey reports and are available to NIOSH for 

use as needed. These secondary air monitoring results exist in documents collected from the 

site, but NIOSH has not compiled and analyzed them because primary tritium and bioassay 

results are sufficient. NIOSH has found examples of these worksheets for the early years of 

operation, 1958–1960. These Air Monitor Check Sheets provide the location, date, and 

result, often notated as “OK” or with a concentration. The Pinellas Plant generally reported 

instances of airborne radioactivity levels exceeding the maximum permissible concentration 

in the health physics monthly reports up to 1962, including an air monitoring summary of 

the concentrations measured in μCi/cc (μCi/mL) [Pinellas Plant 1957–1973]. Beginning in 

1962, reports often simply reported airborne radioactivity as “effectively controlled 

throughout the report period.” In 1970, the reporting period changed from monthly to 

quarterly. These reports are available in the SRDB.

6.1.3 Alternative Data Source and Sufficiency

The Pinellas Plant had a radioactive contamination monitoring and control program, as 

described in GEND Standard #5.2. The procedure defined types of contamination, the 

contamination limits of the different classifications of contamination areas, and 
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contamination controls including the general area monitoring of areas for loose surface 

contamination [GE 1989b, PDF p. 11]. Areas were monitored (smear surveyed) on a schedule 

determined by the work in the area on a daily, weekly, monthly, or semi-annual basis 

[Pinellas Plant 1995]. A smear survey procedure, circa 1960s, indicates the tritium 

contamination limit for uncontrolled areas was 220 dpm/100 cm2 [Tritium smear surveys, no 

date; Burkhart 1989, PDF p. 2; ORAUT 2016a, PDF p. 22]. NIOSH has routine surface 

contamination monitoring results and special survey results for the various areas of the 

Pinellas Plant over the span of operations. NIOSH also has obtained Environmental, Safety 

and Health summary reports from 1957 through 1973, which provide information on the 

maximum tritium surface contamination levels. NIOSH documented additional information 

regarding available tritium-contamination survey data in Pinellas Plant –– Occupational 

Internal Dose [ORAUT 2016a, PDF pp. 22–23].

6.2 Available Pinellas Plant External Monitoring Data and Data 

Sufficiency

The Pinellas Plant started an External Dosimetry Program in 1957 to monitor individual 

employees working in Neutron Generator Production Areas. Pinellas used photographic 

(beta-gamma) film dosimeters from the start of operations through June 1974. From July 

1974 through March 1990, the Pinellas Plant primarily used the Type G film emulsion 

package dosimeter. Then in April 1990, Pinellas used Landauer Type Z/F dosimeter [ORAUT 

2017a, PDF p. 20; Ward 1974; Hall 1989, PDF p. 2]. From 1974 through 1997, Landauer also 

supplied extremity dosimeters, including finger rings or wrist badges to monitor beta, X-ray, 

and gamma exposure as required [Weaver 1995; ORAUT 2017a, PDF p. 22]. Throughout the 

Pinellas Plant’s operational history, Pinellas used Nuclear Track A (NTA) film, Landauer, and 

Mound dosimeters for neutron dosimetry.

The following subsections summarize the employee dosimetry, area monitoring, and 

alternative data sources available to help evaluate external doses in Section 7.2. The 

subsections also present evaluations of the sufficiency of the specified data. The Technical 

Basis Document, Pinellas Plant – Occupational External Dose [ORAUT 2017a] presents details 

regarding the various analyses NIOSH used and the associated minimum detectable 

activities. 

6.2.1 Employee Dosimetry Data Sufficiency

Primary records, including quarterly personnel exposure reports (individual dosimetry data) 

and individual dose files for the entire history of Pinellas Plant operations, are available to 

NIOSH in the SRDB. Secondary records such as annual summary reports (external whole

body data for shallow doses, photons, neutrons, and some extremity dose reports) are also 

in the SRDB. Based on the available claim records, the Pinellas Plant routinely recorded an 

individual’s cumulative career dose. Pinellas reported monthly, annual, cumulative, and 

lifetime dose totals for the Pinellas Plant as whole body doses, which would include any 

internal tritium doses that the worker received. ALARA reports are available for 1988–1995. 

The Pinellas Plant data files include dose information for 1,694 workers. 
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The Pinellas Plant did not monitor all employees for external doses because most of the 

work performed at the Pinellas Plant did not involve radiological exposure to external 

sources of radiation and because most personnel did not have routine access to Radiation 

Areas. Personnel working with radiation-generating devices, such as the Model 200 HP Ion 

Implanter accelerator, were required to wear dosimeters capable of measuring photon and 

neutron dose [ORAUT 2017a, PDF p. 13; Barclay 1995, PDF p. 5]. NIOSH’s review of the 1960 

to 1973 AEC annual exposure summary reports indicates that 27.5% of the Pinellas Plant 

workers wore dosimetry badges. Based on a comparison of Pinellas Plant operating 

procedures to historical guidelines and regulations, the Plant monitored significantly more 

workers for external dose than was necessary [ORAUT 2017a, PDF p. 26; Weaver 1990b, PDF 

p. 14]. Section 6.2.5.1 of Pinellas Plant – Occupational External Dose [ORAUT 2017a, PDF p. 

25] provides more information on historical guidelines and regulations for radiation 

protection and worker dose monitoring requirements that were effective throughout the 

Plant’s operational history. For example, 10 C.F.R. 835 requires workers, who have the 

potential to receive 100 mrem/year of external dose, to be monitored [DOE 1994a, PDF p. 

13]. Nearly 80% of the monitored workers at the Plant received an annual whole body dose 

of less than or equal to 20 mrem on average [ORAUT 2017a, PDF p. 25; ORAUT 2017d]. 

Personnel exposures were routinely very low. In 1991, Pinellas assessed worker exposures 

related to the uranium-doped borosilicate glass cutting and etching processes and calculated 

the worst-case exposure to extremities from the operations as 75 mrem/year [Pinellas Plant 

1992–1994, PDF p. 27-30], which is well below the U.S. DOE annual limits (i.e., 50,000 

mrem/year extremities).

Pinellas Plant workers often changed jobs throughout their employment, which then 

changed their potential to receive radiation dose. Fortunately, many Pinellas Plant dosimetry 

records include cards or notations regarding the start and stop dates for external and 

internal dose monitoring. For the majority of the operational period, the Pinellas Plant 

exchanged and analyzed external dosimetry on a monthly basis. Beginning in January 1990, 

external dosimetry was exchanged and analyzed quarterly [ORAUT 2017a, PDF p. 25; Weaver 

1989, PDF p. 3; Weaver 1990c, PDF p. 3].

Table 6-1 of the site profile document Pinellas Plant – Occupational External Dose [ORAUT 

2017a, PDF p. 14] lists only Pinellas Plant’s Building 100, Area 109 as having electrons greater 

than 15 keV energy and consequently, an external beta-exposure concern. From 1957 

through June 1974, the Health Physics Department processed the film dosimeters at the 

Pinellas Plant site [Burkhart 1987, PDF p. 2]. The available film worksheets indicate the use 

of only the open-window film for the dosimeters; thus, Pinellas did not separately report 

non-penetrating beta doses during this period. The Plant reported any beta doses received 

by workers as photon doses. In 1974, the Pinellas Plant began using dosimetry provided by 

R.S. Landauer Jr. & Co. (Landauer) [Ward 1974, PDF p. 2] who processed the dosimetry and 

reported both deep and shallow exposures for the reporting period (i.e., beta dose for the 

month). Landauer also reported the cumulative totals for the calendar quarter, year-to-date, 

and lifetime exposure history at the Pinellas Plant for workers. In April 1990, the Pinellas 

Plant changed from using Landauer film to using TLDs [Hall 1989, PDF pp. 2, 4]. Pinellas used 

the TLDs through the end of nuclear development and testing operations. More detail 

regarding the specific dosimeter configurations used over time at the Pinellas Plant can be 

found in Tables 6-4 through 6-7 of Pinellas Plant – Occupational External Dose [ORAUT 
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2017a, PDF pp. 20–23]. In 1990, Table 1 of the annual ALARA report [Harder 1991, PDF p. 8] 

shows the total dose and average dose in mrem as skin dose monitoring for photon and beta 

combined.

The Pinellas Plant used Mound TLDs to measure photon exposures in Building 400 from 

October 1979 through September 1987. Starting in the third quarter of 1981, the Pinellas 

Plant processed Mound TLDs to avoid signal fading, a loss of information that caused an 

underestimate of up to 30% of the dose recorded [Meyer 1993, PDF pp. 309–310, 344]. To 

compensate for this potential underestimate, NIOSH applies a correction factor of 1.43 for 

Mound TLD photon results from October 1979 through June 1981.

With the exception of the Mound TLDs, NIOSH applies no adjustments or bias corrections to 

photon doses. NIOSH described signal fading dose reconstruction adjustments for the 

Mound TLD dosimeters in Pinellas Plant — Occupational External Dose [ORAUT 2017a, PDF 

p. 28].

The Health Physics Department processed neutron-sensitive photographic films at the 

Pinellas Plant from 1957 through 1978. In mid-1978, Pinellas began using R.S. Landauer for 

monitoring exposures to 14 MeV neutrons produced during neutron-generator testing. 

Information on the whole body neutron and beta-gamma-neutron dosimeters used over 

time at the Pinellas Plant is in Table 6-5 of Pinellas Plant – Occupational External Dose

[ORAUT 2017a, PDF pp. 21–22].

In October 1979, Pinellas started using Mound Laboratory dosimeters to evaluate exposures 

to neutrons during RTG handling at Building 400 [Burkhart 1987, PDF p. 2]. The RTG heatsource neutron spectrum was most likely adopted from Mound Laboratory and used by the 

Pinellas Health Physics Department to analyze the effectiveness of various Landauer Neutrak 

CR-39 film [Burkhart 1987]. Pinellas determined that the Landauer dosimeters responded to 

only about 67% of the dose equivalent for the RTG heat-source spectrum. The Plant 

monitored RTG workers using these separate dosimeters for neutron dosimetry. The 

workers were required to leave their badges in the RTG areas [ORAUT 2013a, PDF p. 6]. The 

Pinellas Plant used individual dosimetry data for RTG worker neutron doses and would only 

estimate neutron dose if an individual lost their dosimeter. The Pinellas Plant stopped using 

Mound Laboratory neutron dosimeters in October 1987 [Burkhart 1987].

Using information available from the Pinellas Plant ALARA reports, Table 6-4 below shows 

the reported total assigned external dose, the number of monitored individuals, and the 

average individual external dose for the period from 1985 through 1995. Pinellas did not 

report the average individual external dose for 1985 through 1987, and no trend is evident 

for 1988 through 1990. Both the total and average individual dose generally dropped each 

year through 1995. RTG operations, which moved offsite in early 1991, caused most external 

exposures [Weaver 1993b, PDF p. 16]. In 1990, the Pinellas Plant switched from a monthly 

dosimeter period to a quarterly dosimeter period [Weaver 1993b, PDF p. 16].
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Table 6-4: Summary of Pinellas External Monitoring Data for 1985–1995a

Year Number

Monitored

Total Dose

(person-mrem)

Average Dose 

(mrem)

Highest Individual 

Dose (mrem)

1985 Not Reported 5,525 Not Reported 411

1986 Not Reported 2,837 Not Reported 550

1987 Not Reported 2,102 Not Reported 321

1988 171 1,712 6.7 170

1989 187 1,847 4.9 180

1990 185 2,104 8.3 280

1991 107 830b 3.9 40

1992 117 350 1.7 30

1993 88 270 2.3 50

1994 80 60 0.5 20

1995 72 243 0.28 10

a. Sources: [Weaver 1992, PDF pp. 9, 15, 50; HRS 1995; Pinellas Plant 1996; Weaver 1996b, PDF pp. 

12–13] 

b. Most external exposures were from RTG operations which moved offsite in early CY1991.

NIOSH compiled exposure monitoring data between 1960 and 1985 for the site profile. The 

data indicate that the Pinellas Plant monitored between 225 and 588 individuals each year. 

Individual radiation exposure was generally between 0 and 1,000 mrem/year for the period 

1960–1973 (the lowest reported category for that period) and between 0 and 100

mrem/year for the period 1974–1985 [ORAUT 2017d]. The maximum annual radiation 

exposure was less than 2,000 mrem for 1960–1973, and less than 1,000 mrem for 1974–

1985 [ORAUT 2017d]. For the period 1988–1995, the Pinellas Plant monitored between 72 

and 171 individuals for external exposure, with individual external radiation doses averaging 

between 0.28 and 8.3 mrem (maximum values ranged from 10 to 280 mrem) [Weaver 

1996b, PDF p. 13].

Table 6-5 lists the types of external exposure monitoring records found in personnel files and 

indicates the years the Pinellas Plant used those forms. The forms include photon and 

neutron exposures measured in mrem except for the Annual Occupational Radiation 

Exposure form, which reports the summary data and detailed data results.
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Table 6-5: Pinellas Plant External Dose Record Series (Personnel Files)

Form Name or Description Applicable 

Years

Summary Data

(Yes or No)

Detailed Data

(Yes or No)

Personnel Exposure Record 1957–1958 Yes Yes

Exposure Record 1959–1965 Yes Yes

Annual Occupational Exposure for Calendar 

Year

1964–1970 Yes Yes

Personnel Monitoring Record (FC-600) 1970–1979 Yes Yes

Personnel Monitoring Record (NEC 1163) 1980–1987 No No

Dose Report 1988–1995 Yes Yes

6.2.2 Area Monitoring Data and Data Sufficiency

The Pinellas Plant had a Health Physics Program, including general operating procedures and 

routine surveillance activities that included conducting area monitoring and surveys to 

assure worker safety by monitoring contamination and radiation fields. The Health Physics 

Program included routine radiation and contamination surveys, work support surveys (i.e., 

pre-work surveys, waste-box loading surveys, item-release surveys, sample analysis results 

for contaminated pump oil, and area surveys), SWPs, and surveys of radioactive materials for 

transit. Pinellas conducted contamination surveys to detect any spread of radiological 

materials in use at the site. In the Neutron Generator Production Areas, Pinellas conducted 

tritium contamination surveys on a routine basis, checking both work areas and personnel; 

Pinellas documented the results in the health physics monthly reports when a result 

exceeded the contamination control limits. In Building 400, where the RTGs program 

involving triply-encapsulated plutonium sources occurred, Pinellas conducted surveys to 

detect potential plutonium contamination. NIOSH has not found the survey reports 

associated with plutonium contamination surveys but has summary reports indicating that

the Plant did not detect plutonium contamination. The Plant documented routine, directradiation surveys (either with portable instruments or fixed-area badges) within the Pinellas 

Plant every six months and on request to measure radiation levels. Pinellas installed area 

badges in a fixed position and used them to monitor radiation fields around test equipment 

and “large” radioactive sources [DOE 1991, PDF p. 22]. Additional information on the 

specifics of contamination surveys is in the Pinellas Plant – Site Description [ORAUT 2011b] 

and Pinellas Plant – Occupational Internal Dose [ORAUT 2016a, PDF pp. 14–16].

NIOSH has access to area film monitoring work sheets, radiation survey sheets, radiationproducing equipment survey reports, material-transport survey reports, weekly routine 

smear surveys, area film-monitoring worksheets, contamination surveys, and health physics 

data summary reports that provide monthly summaries of contamination status and data in 

the form of primary records.

The available area monitoring data for Pinellas Plant span the site history and adequately 

represent the exposure scenarios to support dose reconstruction. Area monitoring data are 

secondary in the hierarchy of dose reconstruction information; that is, the information 

priority in the order of precedence is individual monitoring data, group or workplace (area) 
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monitoring data, and then process and source term description information [ORAUT 2017c, 

PDF p. 9]. Considering the available monitoring data and exposure-scenario information, 

NIOSH has sufficient Pinellas Plant area monitoring data to represent the NIOSH-evaluated 

class adequately. 

6.2.3 Alternative Data Sources and Data Sufficiency 

The Pinellas Plant used a safety work permit program for some jobs (e.g., maintenance on 

the recovery system or the transport line). Safety work permits (SWPs) identified bioassay 

and air-monitoring requirements, as well as any additional requirements. Pinellas tracked 

SWPs using pressure copy sheets. The tracking method assured that one copy was with the 

worker, one copy was on file, and one copy went to the Health Physics Department. Pinellas 

posted a copy in the work area. The Pinellas Plant often assigned groups of workers to a 

single SWP [ORAUT 2020a, PDF p. 5].

6.3 Available Pinellas Plant Ambient Environmental Monitoring Data 

and Data Sufficiency

The following subsections summarize the environmental monitoring data available to help 

evaluate bounding doses. The subsections also present evaluations of the sufficiency of the 

specified data.

6.3.1 Internal Environmental Data and Data Sufficiency

NIOSH has access to documentation including environmental assessments, environmental 

monitoring reports, health physics reports, annual stack emissions data reports, and internal 

correspondence regarding radiological emissions.

Radioactive Airborne Effluents

NIOSH can assess potential onsite environmental internal exposures and subsequent doses 

to workers at the Pinellas Plant using airborne effluent data, liquid effluent data, and onsite 

air monitoring data. NIOSH has located documentation and records describing both the 

radiological conditions in the onsite environment and the Environmental Monitoring 

Program at the Pinellas Plant. This documentation includes environmental monitoring data.

From the beginning of plant operations, Pinellas performed environmental air monitoring for 

tritium gas and oxide. NIOSH has access to a compiled summary of annual stack releases, 

with total release activity for tritium gas, tritiated water, and carbon-14 for the Pinellas Plant 

[ORAUT 2011e] for the years 1957 through 1997.

The earliest background monitoring for radioactivity was performed in April 1957, when four 

samples from areas around the Pinellas Plant were taken to establish background counts 

before operations began [HRS 1994, PDF p. 44]. The monitoring program was informal until 

the mid-1970s. There were no permanent air monitoring stations, and the Plant performed 

some monitoring activities on an irregular basis. During the mid-1970s, the Pinellas Plant 

installed six permanent onsite air monitoring stations for monitoring tritium [HRS 1994, PDF 
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p. 56]. From 1975 through 1992, the Pinellas Plant performed regular environmental 

monitoring for radioactive tritium releases [HRS 1994, PDF p.12].

Pinellas monitored for radioactive airborne effluent primarily at the exhaust stacks. 

Approximately 82% of the total airborne effluent releases at the Pinellas Plant occurred 

during the first four years of operation, 1957 through 1960, primarily tritium gas and 

tritiated water [ORAUT 2011d, PDF p. 12; HRS 1994, PDF p. 12]. Information regarding the 

location, stack dimensions, and potential nuclides within the effluent is available. Buildings 

100, 200, 400, and 800 had stacks and areas that used radiological materials. The Pinellas 

Plant monitored radioactive emissions from all of these stacks. Pinellas never detected 

radioactive emissions from the Building 400 stack. Until 1974, Pinellas determined airborne 

tritium gas and tritiated water effluent discharges using a combination of continuous stacksampling systems and “real-time” stack monitoring systems. Starting in 1974, Pinellas 

determined airborne effluent discharges of both tritium gas and tritiated water using 

continuous stack-sampling systems. NIOSH documented the technical details of the 

continuous stack monitoring system used to monitor tritium gas concentrations in Pinellas 

Plant – Occupational Environmental Dose [ORAUT 2011d, PDF pp. 9–13].

Starting in 1975, the Pinellas Plant monitored for plutonium because of the encapsulated 

plutonium related to the RTG operations conducted in Building 400 [HRS 1994, PDF p. 60]. 

Pinellas performed stack sampling for airborne effluents from Building 400 using a 

continuous stack-sampling system. However, after reviewing the incident reports and the 

environmental monitoring reports for 1975–1990, NIOSH could not find any evidence of

plutonium releases reported at the Pinellas Plant.

The Pinellas Plant determined airborne effluent discharges of carbon-14, discharged from 

the Building 100 laboratory stack from 1979 to 1984 [HRS 1994, PDF p. 37] from the volumes 

of carbon-14 labeled solvent used during each year [GE 1980, PDF p. 13; GE 1984b, PDF p. 

15].

Radioactive Liquid Effluents

The Pinellas Plant directed effluents into a county drainage system from the East pond until 

December 1982, when Pinellas directed effluents to the Publicly Owned Treatment Works 

(POTW). Tritiated water was the only radioisotope in the Plant’s liquid effluents. Pinellas 

Plant personnel analyzed composite samples of releases to the POTW using liquid 

scintillation techniques. Discharges were generally several orders of magnitude less than the 

DOE 5480.1 standards [GE 1984b, PDF pp. 18–21].

The Pinellas Plant – Occupational Environmental Dose contains supporting technical data to 

evaluate the total Pinellas occupational environmental radiation dose that can reasonably be 

associated with a worker’s radiation exposure [ORAUT 2011d].
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6.3.2 External Environmental Data and Data Sufficiency

NIOSH has not located evidence of environmental external dose monitoring at the Pinellas 

Plant. It is likely that the Pinellas Plant did not perform environmental external monitoring 

due to the low potential for workers to encounter significant sources of external radiation 

outdoors at the Plant. 

Beginning in 1963 when the Pinellas Plant first used Kr-85 on site, Pinellas performed stack 

sampling for discharges of Kr-85. Pinellas housed commercially-available models of two leakdetection systems containing Kr-85 gas in separate rooms of Area 109 in Building 100. Kr-85 

was released from the Radiflo or TRACER-Flo leak-detection units during purge cycles into 

shrouds connecting the two units to an exhaust system from the enclosed testing area 

[IT/Radiological Sciences Laboratory 1986, PDF p. 15]. The Pinellas Plant monitored the 

concentration of Kr-85 in the exhaust duct using partial bypass of the stream into a Kanne 

ionization chamber connected to a picoammeter and a strip chart recorder. Pinellas read the 

Kanne ionization chambers daily [DOE 1987, PDF p. 216]. The Pinellas Plant only expected Kr85 emission to occur from the Building 100 main stack [Martin Marietta 1994b, PDF p. 17].

NIOSH has access to a compiled summary of annual stack releases showing total release 

activity for Kr-85 for the Pinellas Plant [ORAUT 2011e] for the years Kr-85 was in use, 1963 

through 1996.

6.4 Available Pinellas Plant Occupational Medical X-ray Data and Data 

Sufficiency

This section summarizes the occupational medical X-ray data available to help evaluate 

bounding external doses in Section 7.4. This section also presents an evaluation of the 

sufficiency of these data. NIOSH has not found any indication that the Pinellas Plant 

monitored the medical X-ray dose for individuals receiving occupational X-rays. There is a 

report discussing a radiation protection survey of the diagnostic X-ray installation at Pinellas 

Plant performed by the Pinellas County Health Department in December 1972 [McCall 1973, 

PDF pp. 3–12]. This report does not give information related to the dose received by workers 

from the medical X-ray diagnostic procedure, but it indicates that the Pinellas Plant made 

efforts to ensure the equipment was functioning as expected by asking for an outside, 

objective survey.

The Pinellas Plant operations contractors (i.e., GE and Martin Marietta/Lockheed Martin 

Specialty Components) required pre-employment and routine medical examinations as part 

of their Occupational Health and Safety Programs. The pre-employment examinations and 

some of the periodic medical examinations required X-ray screening.

At the Pinellas Plant, the X-ray screening procedures typically included posterior-anterior 

(PA) and infrequent lateral (LAT) chest X-rays [ORAUT 2007a, PDF p. 3; ORAUT 2011c, PDF p. 

8]. NIOSH does not have site documents reporting the examination frequency protocols; 

however, Pinellas Plant workers’ medical X-ray files contain information about the X-rays 

taken, including the numbers and types of projections and the frequencies at which they 

occurred. Pinellas Plant workers’ NOCTS claim file records indicate that Pinellas administered

PA chest X-rays on a semi-regular basis with infrequent LAT or oblique chest X-rays
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throughout the Pinellas Plant’s history. The Pinellas Plant medical records show that it was 

relatively common for a worker to have received a lumbar spine X-ray, an

abdominal/kidneys ureters bladder (Abd/KUB) X-ray, or both, along with the chest X-rays, 

especially between 1969 and 1974. Specifically, one of the most common combinations of Xray examinations during the years from 1969 through 1974 included an anteroposterior (AP) 

Abd/KUB, lateral (LAT) lumbar spine, and PA chest X-rays.
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7 Feasibility of Dose Reconstruction

The feasibility determination for the class of employees under evaluation in this report is 

governed by both EEOICPA and 42 C.F.R. 83.13(c)(1). Under the SEC regulation, 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. If NIOSH has access to sufficient information for either case, NIOSH would 

then determine that it would be feasible to conduct dose reconstructions [42 C.F.R. 83,

2018, PDF p. 10]. 

In determining feasibility in the light of new information identified in this petition (August 

17, 2020 version), NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating the potential radiation dose

received by individual workers who are members of the class. NIOSH also evaluates whether 

any new information supplied in this petition (August 17, 2020 version) calls into question 

either the NIOSH dose reconstruction methods or their underlying assumptions. 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 class. NIOSH’s SEC Petition Evaluation Internal Procedures, which 

are available on the NIOSH Radiation Dose Reconstruction Program webpage, discuss this 

approach. 

7.1 Internal Radiation Doses at the Pinellas Plant

The principal source of internal radiation exposures to members of the class under 

evaluation was from inhalation of dispersible radiological materials used at the Pinellas

Plant. As discussed in Section 5.2, tritium and Kr-85 were the dispersible radionuclides most 

widely used at the Pinellas Plant and only tritium could contribute significantly to internal 

dose [ORAUT 2011b, PDF p. 14]. The following subsections address the ability to bound 

internal doses, methods for bounding doses, and the feasibility of internal dose

reconstruction. 

7.1.1 Evaluation of Bounding Operational Internal Radiation Doses

The following subsections summarize the extent and limitations of information available for 

bounding operational internal doses of the members of the class under evaluation.

7.1.1.1 Tritium

The Pinellas Plant used tritium in multiple forms for the development and production 

associated with neutron generators. Potential exposures to both soluble (i.e., tritium gas,

tritium oxide, and organically-bound tritium compounds) and insoluble forms of tritium (i.e.,

metal tritides) were possible during the transfer of tritium between the reservoirs and 

receiver materials, during routine cleaning and maintenance of equipment, as a result of
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contamination, and during any tritium-related incidents. The Pinellas Plant performed in 

vitro sampling for tritium internal exposure, routine area air monitoring for airborne tritium, 

environmental emissions monitoring, and tritium surface contamination surveys, as 

described in Sections 6.1 and 6.3 of this report. 

From January 15 to February 2, 1990, DOE performed an audit of the Pinellas Plant site. In 

the resulting report, Tiger Team Assessment of the Pinellas Plant, DOE stated that 20 percent 

of the workers who terminated in 1989 did not provide termination samples [DOE 1990a, 

PDF p. 224]; this was taken to mean tritium urine samples. This indicates that the Pinellas 

Plant did collect termination samples for 80 percent of workers who terminated in 1989. The 

Pinellas Plant responded that the only bioassay requirement upon employment termination 

was limited to those who had worked with radioactive materials and that all personnel 

leaving a tritium area for any reason were required to submit bioassay samples and also 

implemented a new termination checklist [DOE 1990b, PDF pp. 281–282].

In 2004, NIOSH captured a sampling of employee termination records for employees with 

last names beginning with “E-G” [Pinellas Plant 1948–1985] and employees with last names 

beginning with “S” [Pinellas Plant 1942–1985] from the Atlanta Federal Records Center. That 

same year, NIOSH initiated a process (called SPEDELite) to link any energy employee data 

collected in the NIOSH SRDB to the dose reconstruction claim for the employee. During this 

evaluation, NIOSH searched the Pinellas claimant files for monitored employees and 

identified the 10 with the most data within the SRDB to determine if claim records routinely

included tritium termination samples. Of the 10 claims reviewed, seven of the DOE records 

responses contained the termination tritium sample information. This gives NIOSH a degree 

of confidence that the termination samples are available to NIOSH within the claimant files. 

As stated earlier, NIOSH has termination records available in the SRDB for use in performing 

dose reconstructions. However, due to the short half-life of tritium, termination samples 

collected at the end of employment rather than after an indication of exposure, are not able 

to detect tritium exposures as effectively as samples collected immediately after the 

potential exposure. The termination samples provide an indication of any tritium exposure 

that occurred just preceding the sample collection, and so are of limited value. NIOSH 

believes that any missing termination bioassay samples would have a minimal impact on 

dose reconstruction.

The Tiger Team report also stated as part of the same finding, “In 1989 bioassay samples 

were not submitted in accordance with GEND procedures. Seventy percent of the required 

monthly samples and 35 percent of the required weekly samples were not submitted” [DOE 

1990a, PDF p. 224]. The level of worker participation in the bioassay program had been an 

ongoing concern for the site [ORAUT 2021e, PDF pp. 7–8]. A memo dated March 1, 1971, 

describes procedure changes the Pinellas Plant initiated to ensure bioassay samples were 

submitted on time [Ward 1971b, PDF p. 2]. In response to the Tiger Team assessment, the 

Plant noted the weekly and daily sampling requirements and listed several steps to improve 

worker participation [DOE 1990b, PDF pp. 281–282]. In 1990, the Pinellas Plant set a goal of 

an overall participation rate of 80% [Harder 1991, PDF p. 2]. Pinellas began tracking 

individual compliance with bioassay sampling requirements. The actions taken by the 

Pinellas Plant, in response to the Tiger Team finding, increased the average participation rate 

of workers in the tritium monitoring program to 78% in 1990 [Harder 1991, PDF p. 4]; in 
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1991 it was above 85% [Weaver 1992, PDF p. 4]; and in 1992 it was above 90% [Weaver 

1993a, PDF p. 11]. The 1990 Annual ALARA Program Report for Ionizing Radiation describes 

updating the ALARA goal to have all employees in the tritium monitoring program “maintain 

at least 80% participation during the year, not just an average” [Harder 1991, PDF p. 6]; 

NIOSH assumes this means the 1991 participation rate (reported as above 85%) was for all 

employees in the urine-sampling program. 

As discussed in Section 6.1.1, both the total internal dose and the average individual tritium 

dose generally followed a downward trajectory from 1986 through 1990 and continued in 

the same direction through the end of reporting in 1995 when the Pinellas Plant was 

undergoing D&D work. Therefore, the increase in bioassay compliance achieved in response 

to the DOE Tiger Team findings did not lead to an increase in the Pinellas Plant’s total 

measured internal dose or the average individual internal dose, as might be expected if the 

bioassay program had missed identifying significant exposures.

In addition to the idea that the Pinellas Plant had not missed identifying significant 

exposures due to the bioassay compliance issue, NIOSH finds that because of this issue the 

overall tritium dataset available from the Pinellas Plant would likely be biased high. The 

Pinellas Plant monitored those workers with the highest internal-exposure potential for 

tritium the most often, i.e., on a daily or weekly frequency. According to the findings of the 

1990 Tiger Team report, this group of workers was more compliant with the sampling 

program than the workers with lower exposure potential, who were sampled on a monthly 

frequency. This indicates that the monitoring data that is available would likely be biased 

high due to the larger fraction of missing data from the workers with lower exposure 

potential. In turn, any unmonitored dose approach based on the monitored workers would 

also be biased high.

To further assess the potential impact of the bioassay compliance for the period before 

1990, NIOSH looked at the data in the NOCTS claimant files to represent the monitoring 

conducted at the Pinellas Plant. While there are significantly more dose records available to 

NIOSH than the claim records, only the claim records are consistently associated with the 

worker’s job description, as self-reported in the CATI reports. NIOSH searched for and found 

broad titles like operator, maintenance, manager, engineer, secretary, and draftsman in the 

claimant files. NIOSH found that the claimant files included workers with one or more of the 

construction trade titles for all years of Pinellas Plant operation. During its review, NIOSH 

confirmed that the workers it expected to have had a potential for internal tritium exposure 

(e.g., those with hands-on tritium work or tritium-equipment or systems-maintenance 

responsibilities) were in fact monitored, as these are the categories of workers seen in the 

claims. Job categories included: engineers (101), operators (93), maintenance (60), 

technician (41), chemist (15) manager (33), secretary (13), stock clerk (11), janitor (22), nurse 

(1), and quality control (17). This list is not exhaustive and will contain duplication as the job 

titles are self-reported and an individual may have held numerous positions. 

The Pinellas Plant determined worker urine-sample requirements based on their assigned 

work/tasks. While Pinellas was aware of the tasks of each employee, the tasks are not clearly 

indicated anywhere in the records available to NIOSH, making it necessary for NIOSH to use 

contextual clues such as job description, job change notations, history of urine samples, or 
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other indications in the records to determine the worker’s exposure potential for any longerthan-expected period (generally between 30 and 60 days) between samples. NIOSH found 

that this lack of any clear indication of when a urine sample had to be submitted made it 

impossible to quantify the degree of compliance with bioassay schedules for each former 

worker. However, NIOSH analyzed the number of urinalysis results each year for each 

claimant to identify indications of volatility in the numbers of samples submitted across 

years. This analysis of the data from 1957 through 1989, identified only four claims that 

seemed to be more variable than the others, having significant changes in the numbers of 

samples given from one year to the next, and worth further review in detail. The four claim 

records were for a lab technician, a maintenance craftsman, a development physicist, and a 

neutron tube technician. All of these were jobs that NIOSH would expect to be on a weekly 

to monthly urine sample schedule. NIOSH reviewed these claims and determined that the 

worker monitoring appeared consistent with the job responsibilities and exposure potential

for these workers.

The Tiger Team audit document does not include references, specific data, or 

documentation to support the finding related to bioassay procedure compliance; therefore,

NIOSH must assess it at face value. During interviews with former workers and DOE 

oversight staff, NIOSH asked participants to identify the cause of bioassay non-compliance. 

Of the 15 former Pinellas workers and DOE oversight staff who were interviewed specifically 

on the topic of participation in the bioassay program, all stated that they did not know of 

workers not submitting samples as requested [ORAUT 2020a,b,c,d,e,f,g,h,I,j; ORAUT 

2021a,b,c,d,e]. Although they did not know of workers who were not submitting samples, 

the responses on possible causes ranged widely. A former worker who had participated in 

the Tiger Team audit said the Plant set the 80% participation goal in response to the audit,

and that non-participation was sometimes a result of workers being on leave during their 

scheduled sample period [ORAUT 2020a, PDF p. 7]. This same former worker informed 

NIOSH that there were support personnel who entered a production area on a non-routine 

basis, who the site assigned to the bioassay sample program for routine sampling instead of 

only requiring the worker to provide a sample upon leaving the tritium area. Providing a 

sample when exiting a radiological area was the Plant’s protocol for non-routine entries 

involving exposure potential. Thus, according to the interviewee, there were a large number 

of people placed on the routine sampling program though it was unnecessary [ORAUT 

2020a, PDF p. 6]. A Radiation Control Compliance document from 1993 reports that the 

system used to document participation did not accurately track the reason samples were not 

submitted (i.e., vacation, sick leave, reassignment, or “just forgot") [Martin Marietta 1993b, 

PDF p. 6]. Therefore, NIOSH doesn’t have any evidence or indication of a single root cause of 

non-compliance with the requirement to submit a bioassay sample. It is unlikely that the 

non-compliance issue was a systemic problem and there is no indication it was widespread 

among the workers. Therefore, the bioassay compliance issue does not impact NIOSH’s 

ability to develop a dose reconstruction approach based on the available monitored worker 

data.

In addition to reviewing Pinellas Plant documentation and interviewing former employees 

regarding the bioassay compliance finding, NIOSH also reviewed past ABRWH Pinellas Plant 

Work Group discussions and reviews regarding dose reconstruction methods for 

unmonitored workers. On September 15, 2006, SC&A issued their report, Review of the 
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NIOSH Site Profile for the Pinellas Plant Site. The report had 11 findings including “Finding 7: 

Missing Internal Dose Estimation Methods for Unmonitored Workers, such as Maintenance 

and Support Personnel, Not Provided” [SC&A/Salient 2006, PDF p. 14]. In Finding 7, SC&A 

indicated the ORAUT-TKBS-0029-5, Rev 0 statement, “All HTO and Plutonium potentially 

exposed workers have likely been monitored” needed justification [SC&A/Salient 2006, PDF 

p. 14]. When the ABRWH Pinellas Plant Work Group met on June 11, 2008, this became Issue 

#7 in the Issues Resolution Matrix for the Pinellas Plant [SC&A 2016a, PDF pp. 8–9].

NIOSH assesses unmonitored workers, those who were not monitored because their job 

assignment did not involve significant potential for internal exposure, as only being exposed 

to on-site levels of environmental tritium effluent and follows the guidance in Pinellas Plant 

– Occupational Internal Dose, ORAUT-TKBS-0029-5 [ORAUT 2016a, PDF p. 23]. To address 

the unmonitored worker issue, NIOSH developed a whole body dose for the unmonitored 

worker based on monitored, whole body doses calculated by Pinellas that were available in 

documents in the SRDB. The Pinellas Plant reported total whole body dose, which included 

the measured, external whole body dose and the calculated whole body dose based on

tritium bioassay. NIOSH analyzed the results and determined that on average, 95% of the 

monitored workers at the Plant received annual doses equal to or less than 100 mrem 

between 1957 and 1995 [ORAUT 2017a, PDF PP. 56–62]. ORAUT-TKBS-0029-6 Attachment B, 

Basis for Unmonitored External Dose Assignment describes the derivation of the dose.

During the February 11, 2016 ABRWH Pinellas Plant Work Group meeting, the Pinellas Plant 

Work Group discussed the need for an unmonitored dose approach specific to internal dose. 

However, the Work Group found that the approach for determining the unmonitored dose 

assigned in Pinellas Plant – Occupational External Dose, ORAUT-TKBS-0029-6, included 

internal dose and therefore met their concern about unmonitored internal dose [NIOSH 

2016, PDF pp. 25–26]. In the PowerPoint presentation dated March 23, 2016, SC&A 

discussed each issue from the Issues Matrix. On the slide for Issue 7 was the statement 

“NIOSH ‘whole body dose’ coworker model includes a tritium component in addition to 

neutron and external gamma dose assigned at the 95th percentile” [SC&A 2016b, PDF p. 13].

During this SEC evaluation, NIOSH reviewed this approach to determine if a methodology for 

assigning internal dose for individuals with monitoring gaps (e.g., when a worker did not 

submit a required urine bioassay sample) is needed. Currently, NIOSH applies the 95th

percentile whole body dose to all Pinellas claimants who were potentially exposed to 

photons or neutrons and were unmonitored for external exposure. NIOSH determined that 

the use of an unmonitored approach, based on the ‘whole body’ dose, as a surrogate for the 

internal dose component is appropriate and claimant favorable when alternative approaches 

are not viable. NIOSH will update Pinellas Plant – Occupational Internal Dose, ORAUT-TKBS0029-5, following the SEC-00256 evaluation to include a discussion of how to determine 

exposure potential for unmonitored workers or workers with large gaps in dosimetry and a 

discussion of available approaches to bound internal dose.

As described in Section 6.1.1, NIOSH has access to a considerable number of dosimetry 

records and tritium in vitro bioassay results for personnel who worked with or handled 

tritium equipment or tritium-contaminated systems because these were the former workers 

monitored for potential intakes. Pinellas Plant procedures required that supervisors assign 

anyone with the potential to receive 100 mrem/year or more from tritium to the monitoring 
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program, as discussed in Section 6.1. NIOSH assumes these supervisors would be in the best 

position to be aware of workers’ assignments and the potential of those tasks for tritium 

exposure, necessitating tritium exposure monitoring. NIOSH reconstructs operational 

internal doses for soluble tritium (i.e., tritium gas, tritium oxide, and organically-bound 

tritium) from these bioassay monitoring results. The method outlined in Pinellas Plant – 

Occupational Internal Dose, ORAUT-TKBS-0029-5, Section 5.8.1.1 details the methodology 

NIOSH uses [ORAUT 2016a]. NIOSH assesses exposure to both 100% tritium gas and tritium 

oxide and 100% organically-bound tritium and then assigns only the most claimant-favorable 

value. Tritium urine data are assessed as organically-bound tritium even though, as indicated 

in Section 5.2.1, organically-bound tritium exposure was only associated with work on 

vacuum-pump systems and their associated contaminated oils. Such activities involved a 

small subset of the Pinellas work force and individuals performing these activities were 

subject to a job-specific bioassay requirement (i.e., daily or upon job performance). 

NIOSH assumes that workers exposed to insoluble tritium compounds (i.e., certain metal 

tritides) would have worked with soluble tritium and that the Pinellas Plant would have

monitored them for tritium [ORAUT 2016a, PDF pp. 22–23]. Therefore, NIOSH assigns

insoluble tritium exposures only for the period of a worker’s history when they provided a 

urine sample. Although the Pinellas Plant limited the amount of the insoluble forms 

compared to the soluble forms, NIOSH assesses all former workers monitored for soluble 

tritium as though they received exposures to insoluble tritium at the same time. Although 

urine bioassay sampling has the capability to detect a large intake of insoluble forms of 

tritium, because of the nature of these compounds (i.e., solubility), it can be very difficult to 

accurately separate a large insoluble intake from a small soluble intake when exposed to 

both simultaneously. Instead, NIOSH assigns dose from insoluble tritium compounds based 

on a bounding, hypothetical intake derived using available tritium surface contamination 

data. The method used to bound operational internal doses for insoluble tritium is outlined 

in Pinellas Plant – Occupational Internal Dose, ORAUT-TKBS-0029-5 Section 5.7.1.2 [ORAUT 

2016a]. This bounding methodology was discussed with the ABRWH Pinellas Plant Work 

Group, as documented in meeting transcripts [NIOSH 2016, PDF pp. 43–114] and applied in 

Pinellas Plant – Occupational Internal Dose [ORAUT 2016a, PDF pp. 21–23].

In summary, the Pinellas Plant improved worker compliance with urine-sample submission 

frequency following the 1990 Tiger Team report and NIOSH found that measured doses did 

not increase as a result of improved compliance. This indicates there was no significant dose

that went unmonitored when workers sometimes did not turn in the urine samples 

according to procedure. NIOSH’s claimant-records review indicates that tritium bioassay

data are available for the workers most likely to have been exposed during the period under 

evaluation. Bioassay data are available for the time period, for the personnel who worked in 

the areas, doing the jobs that NIOSH considers to have the potential for radiation exposure. 

NIOSH will update the site profile document, Pinellas Plant – Occupational Internal Dose, 

ORAUT-TKBS-0029-5 to further explain unmonitored, internal tritium dose approaches and 

how NIOSH will use them to bound internal dose based on claim information, job title, and 

monitoring history.
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7.1.1.2 Plutonium 

The plutonium used at the Pinellas Plant in RTG production from 1975 through 1990 was not 

a potential source of internal exposure. The RTG heat-source containment rendered the 

plutonium non-dispersible and there was no plutonium contamination within the facility [GE

1982a, PDF p. 6; Pinellas Plant 1988, PDF p. 3; Pharo 1993, PDF p. 2]. However, out of an 

abundance of caution, the Pinellas Plant performed plutonium bioassay. An internal 

dosimetry practices document from 1983 states that “No leakage [of the 238PuO2 heat 

sources] has occurred during the eight years that those sources have been used at the site...” 

[Internal dosimetry practices 1983, PDF p. 2]. Workers assigned to the RTG project, working 

with the RTG sources, submitted annual samples while assigned to the work [Internal 

dosimetry practices 1983, PDF p. 2], and NIOSH has access to the bioassay results as 

discussed in Section 5.2.2. NIOSH concludes plutonium was not available in the work area for 

inhalation or ingestion by workers. The ABRWH Pinellas Plant Work Group concluded that 

they do not consider the potential for personnel internal dose from activities involving 

plutonium as credible [NIOSH 2011b; NIOSH 2012b; NIOSH 2016]. Therefore, an internal

dose reconstruction methodology for plutonium is not necessary.

7.1.1.3 Uranium

NIOSH and the ABRWH examined the potential for exposure to the uranium that was part of 

the tritium storage beds and the borosilicate glass at the Pinellas Plant and did not consider

it a potential source of internal exposure [NIOSH 2009, PDF pp. 60–64]. The Pinellas Plant 

reported that the surveys conducted at the time showed no uranium contamination [ORAUT 

2013a, PDF p. 5]. There were no reported incidents for the Pinellas Plant relating to a 

uranium release or a uranium fire incident. Neither form of uranium the Pinellas Plant used 

was available as a routine occupational internal exposure source and posed little to no 

internal dose hazard. NIOSH concludes that uranium was not available in the work area for

inhalation or ingestion by workers; therefore, an internal dose reconstruction methodology 

for uranium is not necessary.

7.1.1.4 Carbon-14

The Pinellas Plant used carbon-14 from 1979 through 1983. Pinellas Plant’s Radioactive 

Waste Implementation Plan stated that “Small quantities of carbon-14 labeled solvents are 

used in a laboratory operation which evaporates the solvent to the plant's east exhaust 

stack” [GE 1984a, PDF p. 9]. There were no other indications of carbon-14 in use at the

Pinellas Plant, nor any other occupational exposure pathways identified for plant workers.

The ABRWH Pinellas Plant Work Group discussed carbon-14 as part of the TBD review under 

“Finding #7: Missing Internal Dose Estimation Methods for Unmonitored Workers, such as 

Maintenance and Support Personnel, Not Provided”. The work group agreed in 2009 that the 

amount of carbon-14 in use at the Plant contributed less than a mrem/year dose and 

declared that part of the issue resolved [NIOSH 2009, PDF p. 57–58]. NIOSH concludes that 

carbon-14 was not available in the work area for inhalation or ingestion by workers; 

therefore, an internal dose reconstruction methodology for carbon-14 is not necessary.
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7.1.2 Evaluation of Bounding Ambient Environmental Internal Radiation Doses

The following subsections summarize the extent and limitations of information available for 

bounding ambient environmental internal radiation doses of the members of the class under 

evaluation.

NIOSH assessed potential onsite intakes attributable to the Pinellas Plant’s onsite measured 

air concentrations [ORAUT 2011f]. NIOSH also assessed bounding potential onsite 

environmental internal doses for a hypothetical worker employed at the Pinellas Plant from 

1957–1997, using the intake information and exposure scenarios described in Pinellas Plant 

– Occupational Environmental Dose [ORAUT 2011d, PDF pp. 19–21]. For each exposure 

scenario, the assessment indicates the total internal dose to all internal organs was <1 mrem 

[ORAUT 2011g,h]. 

7.1.2.1 Tritium

Onsite ambient environmental exposure to tritium was possible because airborne effluent, 

released primarily at the exhaust stacks, would have included tritium gas and tritiated water. 

Greater than 95% of the radioactivity released from the Pinellas Plant stacks was from 

tritium [ORAUT 2011d, PDF p. 19; ORAUT 2011i]. NIOSH adjusted tritiated water intakes by a 

factor of 1.5 in accordance with NIOSH procedures. NIOSH summarized the resulting annual 

intakes in Pinellas Plant – Occupational Environmental Dose [ORAUT 2011d, PDF p. 20]. As 

discussed in Section 6.3.1, NIOSH has access to sufficient amounts of environmental 

monitoring documentation to assess the onsite environmental internal exposures and 

subsequent doses to workers at the Pinellas Plant. The Pinellas Plant performed onsite 

tritium air monitoring from the beginning of operations, and the annual results are 

summarized for the years 1975 through 1992 [ORAUT 2011d, PDF p. 18; ORAUT 2021g, PDF 

p. 23]. NIOSH calculates potential intakes and applies them to unmonitored workers using 

over-estimating approaches with stack emissions data, liquid effluent data, and onsite air 

monitoring data.

7.1.2.2 Plutonium 

The Pinellas Plant conducted onsite environmental air monitoring for plutonium beginning in 

1975, when RTG production began, and DOE first brought plutonium onsite. Pinellas 

sampled airborne effluents from the Building 400 stack for plutonium using a continuous 

stack-sampling system. The Pinellas Plant collected particulate air samples on filters they

exchanged monthly and later analyzed for plutonium radioisotopes [IT/Radiological Sciences 

Laboratory 1986, PDF pp. 18–19]. Pinellas Plant – Occupational Environmental Dose

describes the analysis method [ORAUT 2011d, PDF p. 12]. The minimum detection levels 

reported for this type of plutonium sampling ranged from 5.9 × 10-19 to 3.7 × 10-18 μCi/mL for 

Pu-238 and Pu-239/240 [IT/Radiological Sciences Laboratory 1986, PDF p. 20]. NIOSH 

reviewed environmental monitoring reports for the Pinellas Plant and no plutonium was 

ever reported to have been released to the environment; therefore, an ambient 

environmental internal dose reconstruction methodology for plutonium is not necessary

[Martin Marietta 1994c, PDF p. 58; Martin Marietta 1995, PDF pp. 29–30]. 
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7.1.2.3 Carbon-14

The only indication of carbon-14 use at Pinellas Plant is in the annual environmental 

monitoring reports, which report carbon-14 releases to air from 1979 through 1983. 

According to Pinellas Plant environmental assessments, Pinellas used the carbon-14 as a 

solvent label in laboratory operations [GE 1980, PDF p. 13; GE 1984b, PDF p. 15]. Pinellas 

determined airborne effluent discharges of carbon-14 from the volumes of carbon-14 

containing solvent used each year [GE 1981, PDF p. 16]. The Pinellas Plant only discharged 

carbon-14 from the Building 100 laboratory stack [GE 1982b, PDF p. 16]. NIOSH found no 

other documentation indicating any other uses of carbon-14 at Pinellas Plant and found no 

information regarding the chemical forms of carbon-14. NIOSH documented stack releases in

Table 4-5 in ORAUT-TKBS-0029-4, Pinellas Plant – Occupational Environmental Dose [ORAUT 

2011d, PDF p. 20] with the activity amounts at a very small fraction (10-5 or less) of the 

tritium releases. The environmental reports indicate the maximum ground-level 

concentration of carbon-14 (i.e., 4.0 x 10-23 μCi/ml) [GE 1982b, PDF p. 17] was significantly 

less than 1/10 of 1 percent of the standard for continuous non-occupational exposure which 

was 1.0 x 10-7 μCi/ml [GE 1982b, PDF p. 17].

The quantity of carbon-14 measured in the effluent involved was small (less than 2 x 10-4

Ci/year for 5 years as shown in Table 4-2 of Pinellas Plant – Occupational Environmental 

Dose) [ORAUT 2011d, PDF p. 13]. NIOSH documented the maximum annual onsite average 

air concentrations of carbon-14 and the resulting annual intakes in the Pinellas Plant – 

Occupational Environmental Dose site profile document [ORAUT 2011d, PDF p. 13]. The 

highest calculated carbon-14 annual intake by inhalation is 3.5 x 10-14 Ci (1.30 x 10-3 Bq), 

which results in effective organ doses much less than 1 mrem. Therefore, it is unlikely that 

carbon-14 was a significant environmental internal dose concern at the Pinellas Plant and an 

ambient dose reconstruction methodology for carbon-14 is not necessary.

7.1.3 Internal Dose Reconstruction Feasibility Conclusion

NIOSH evaluated whether the reported non-compliance with Pinellas Plant bioassay 

sampling procedures for tritium had a significant impact on dose reconstruction feasibility

and found it does not because:

• After the Tiger Team assessment, the Pinellas Plant initiated efforts to improve 

participation in the Bioassay Sampling Program. The Pinellas Plant ALARA reports 

document success in increasing the participation rates. As discussed in Section 7.1.1.1, 

the increase in bioassay sample compliance achieved by the Pinellas Plant in response to 

the DOE Tiger Team findings did not lead to an increase in either the Pinellas Plant’s total 

measured internal dose or the average individual internal dose, as would be expected 

had the bioassay program missed identifying significant exposures.

• The Plant monitored those with the highest internal-exposure potential the most often, 

i.e., on a daily or weekly frequency. This group of workers was more compliant with the 

sampling program, according to the 1990 Tiger Team report. Therefore, the dataset 

available to NIOSH for determining an unmonitored dose approach would likely be 

biased high.
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• Doses for monitored workers are low. Attachment B of the Pinellas Plant – Occupational 

External Dose document demonstrates that eighty percent (80%) of monitored workers 

received an annual whole body dose less than or equal to 20 mrem on average, and 95% 

received an annual whole body dose less than or equal to 100 mrem for any given year 

[ORAUT 2017a, PDF p. 58]. These whole body doses include external dose and tritium 

internal dose. Therefore, NIOSH finds it can bound tritium internal dose.

NIOSH reviewed each claim file in NOCTS to determine whether internal personal monitoring 

records were available for the employee and found internal monitoring results for the years 

1957 through 1990, the period under evaluation. These records include individual urine 

sample results for tritium in primary data form. The claimant files included job titles ranging 

from “accountant” to “worker in the X-ray department.” NIOSH reviewed the claim files 

specifically for maintenance positions, looking for any evidence that those workers were 

missing internal monitoring results and found the Plant monitored maintenance workers and 

their records are available.

NIOSH reviewed NOCTS claimant files in early 2020 and found over 20,000 tritium bioassay 

results for 230 individuals. NIOSH found that the dosimetry records in the claimant files 

often, but not consistently include indications of job changes and/or the intentional removal 

of an individual from the bioassay program in the form of notations regarding the start and 

stop dates for internal dose monitoring. NIOSH performed an in-depth review of claims with 

unusual result patterns (i.e., the number of results were higher than would be associated 

with simple routine monitoring) and found indications of samples being taken following nonroutine tasks that had potential for exposure (i.e., SWP covered work).

Former workers, Environmental Safety and Health staff, and DOE oversight personnel 

confirmed during interviews that Pinellas workers were generally very compliant with 

requirements. This supports the statement of one former worker who said the noncompliance may have been an artifact of the written bioassay lists not being well maintained 

(i.e., not promptly removing workers who no longer needed to submit a sample). NIOSH has 

the tritium bioassay results for hundreds of former Pinellas workers who have become 

claimants. In addition, NIOSH added scans of the entire radiological history files for most, if 

not all, formerly monitored workers to the SRDB in October 2020.

For routinely monitored workers, NIOSH uses the dosimetry results for the individual worker 

to assess internal dose reconstruction. For workers monitored in response to performing 

specific tasks with tritium exposure potential or those routinely monitored workers with 

significant gaps in dosimetry, NIOSH uses the individual’s available dosimetry in conjunction 

with claim information, default methods, and values prescribed in the site profile documents 

and applies the most conservative and reasonable assumptions.

The uranium used as part of the tritium-storage system only had dispersal potential during a 

non-routine incident. Pinellas Plant site records have no such incident documented. NIOSH 

does not consider uranium entrained in the borosilicate glass, as discussed in Section 5.2.3, a 

potential source of internal exposure at Pinellas Plant. Pinellas used carbon-14 in exempt

quantities in the laboratory to label solvents [Pinellas Plant 1980, PDF p. 3] and NIOSH 

considers it an unlikely source of internal exposure. NIOSH does not consider plutonium to 
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be an internal exposure concern at the Pinellas Plant both because monitoring for it 

indicates it was contained by the triple encapsulations and because bioassay monitoring (i.e., 

plutonium urinalysis) confirmed plutonium was not a source of internal radiation dose.

NIOSH has access to information to support bounding operational internal radiation doses 

including information on operations, programmatic reports, area contamination survey 

reports, air monitoring results, area characterization reports, internal dosimetry results, 

radiation dosimetry program information, radionuclide and source inventory, historical 

Radiation Protection Program information, employment records, information on hazardous 

waste operations, safe work permits, environmental management reports, unusual 

occurrence/incident reports, and related data for Pinellas Plant employees. With this 

information, which is representative of the workers with potential for exposure, and because 

NIOSH did not find an indication of a negative impact of the bioassay non-compliance issue 

on dose reconstruction, NIOSH is able to complete internal dose reconstruction.

NIOSH has enough information to assign internal doses to monitored and unmonitored 

Pinellas Plant workers.

7.2 External Radiation Doses at the Pinellas Plant

The principal source of external radiation doses for members of the class under evaluation 

was radioactive material and radiation-generating devices required during product 

manufacturing at the Pinellas Plant. The predominant radioactive materials used at the Plant 

included tritium, Kr-85, DU, and plutonium [ORAUT 2017a, PDF p. 10; Pinellas Plant 

radioactive, no date]. Various other radionuclides in the form of sealed and plated sources 

were also in use at Pinellas [Jech 1963, PDF p. 8]. The only open-area radiation fields that 

workers could routinely encounter were from the testing of neutron tubes and neutron 

generators, during the use of machine-generated X-rays, and during RTG heat source

operations in Building 400. Kr-85 gas leaks may have created non-routine, open-area 

radiation fields in the rooms housing the two leak-detection systems. The following 

subsections address the ability to bound external doses, methods for bounding doses, and 

the feasibility of external dose reconstruction.

7.2.1 Evaluation of Bounding Operational External Radiation Doses

The following subsections summarize the extent and limitations of information available for 

bounding the operational external doses of the members of the class under evaluation. 

7.2.1.1 Photon

Exposure to photons at the Pinellas Plant would result primarily from testing neutron tubes 

and generators in the Neutron Generator Production Areas, from exposure to Kr-85 gas, and 

from proximity to the heat sources in the RTG Production Areas. The photon energy 

distribution information is not available for most locations of the Pinellas Plant, so NIOSH 

generally assumes 100% of the photons are 30 to 250 keV photons unless specific 

information otherwise is known [ORAUT 2017a, PDF p. 14]. Specific photon-energy 

distribution information is available for Area 109, the Component Testing Area of Building 
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100 where workers used the Kr-85. NIOSH attributes the specific photon energy distribution 

only for exposures to Kr-85 gas, based on the X-rays and gamma-rays emitted from the 

krypton gas [ORAUT 2017a, PDF p. 14].

The Pinellas Plant started using external dosimetry in 1957 to monitor workers in the 

Neutron Generator Production Areas [ORAUT 2017a, PDF p. 25]. Records of radiation dose to

individual workers from personnel dosimeters are generally available for 1957 to 1994 for 

the workers’ time of employment. NIOSH’s review of the available dosimetry data indicates

that Pinellas routinely monitored employees with any significant potential for external dose 

exposure.

While only 27.5% of the Pinellas Plant workers wore dosimeters, this was more than was 

required by the regulations for the radiation exposure potentials, as described in Section 

6.2.1. NIOSH has employee dosimetry records (primary data) and area monitoring data to 

support dose reconstruction.

NIOSH looked at NOCTS claim records and compared them against their self-reported job 

title. NIOSH sorted these records by how many external dose results they had per year of 

employment. The job titles NIOSH expected to have the most potential for exposure 

opportunities included assembler or engineer. As expected, NIOSH found these job titles to 

have the most external monitoring data per year employed. In Attachment B of the Pinellas 

Plant – Occupational External Dose document, there is an analysis of all external dose results 

available from claimants in NOCTS at that time. Eighty percent (80%) of monitored workers 

received an annual whole body dose less than or equal to 20 mrem on average, and 95% 

received an annual whole body dose less than or equal to 100 mrem for any given year 

[ORAUT 2017a, PDF p. 58]. For years with detailed dose information, a significant number of 

the annual whole body doses are either entirely or mostly attributable to internal tritium 

dose [ORAUT 2017a, PDF p. 57]. The large percentage of monitored individuals that routinely 

had doses below the reporting levels demonstrates that the photon exposure potential at 

the Pinellas Plant was generally low, as discussed in Section 6.2.1.

For periods in which the Pinellas Plant did not monitor a worker for external dose, NIOSH 

assigns an annual unmonitored external dose of 100 mrem [ORAUT 2017a, PDF p. 56]. The 

100 mrem external dose for unmonitored workers was first presented to and discussed by 

the ABRWH Pinellas Plant Work Group in their meeting on June 11, 2008 [NIOSH 2008a, PDF 

pp. 63–81], and revisited in subsequent meetings. NIOSH derived the 100 mrem value from 

Pinellas whole body exposure totals and calculated it to represent the 95th percentile of all 

whole body exposure assigned by the Pinellas Plant. The ABRWH Pinellas Plant Work Group 

has discussed and agreed this 100 mrem value [NIOSH 2008a, PDF pp. 79–81; NIOSH 2009, 

PDF pp. 39, 55–57] is a reasonable overestimate of external exposure for those workers 

without external monitoring data. For unmonitored periods of less than a full year, NIOSH 

prorates the unmonitored dose assignment. The technical basis for the NIOSH established 

unmonitored external dose assignment can be summarized as:

 Pinellas Plant monitored workers based on exposure potential, so those workers that 

were not monitored are expected to have less exposure than the monitored workers.
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 The majority of the annual whole body doses reported for monitored Pinellas Plant 

workers were <20 mrem, or the limit of detection for some of the dosimeters used at the 

site.

 Therefore, external dose data from monitored workers provides a bounding approach for 

the unmonitored workers.

NIOSH provided a detailed discussion of the basis for unmonitored worker external dose 

assignment in Attachment B of the Pinellas Plant — Occupational External Dose [ORAUT 

2017a, PDF pp. 57–62], and it applies to the SEC-00256 evaluated class.

Missed photon doses apply to the neutron generator operations and RTG operations 

workers who had one or more reported dosimeter readings less than half the limit of 

detection. NIOSH will estimate missed dose for the NIOSH-evaluated class based on

dosimeter results and dosimeter limits of detection, as is explained in greater detail in the 

Pinellas Plant-Occupational External Dose [ORAUT 2017a, PDF pp. 31–32].

As described in Section 6.2.1, there are no adjustments or bias corrections to photon doses 

necessary except when assessing the Mound TLD results for X-ray exposures in Building 400 

from October 1979 through September 1987 [ORAUT 2017a, PDF p. 28]. NIOSH describes

signal fading dose reconstruction adjustments for the Mound TLD dosimeters in Pinellas 

Plant — Occupational External Dose [ORAUT 2017a, PDF p. 28].

The ABRWH Pinellas Plant Work Group reviewed the Pinellas Plant — Occupational External 

Dose site profile document and agreed that the protocols in the document are appropriate 

and sufficient to assign monitored and unmonitored photon dose [NIOSH 2011b, PDF pp. 

50–62; NIOSH 2016, PDF p. 22].

7.2.1.2 Beta

Though the predominant source of electron radiation at the Pinellas Plant was tritium, only 

beta exposures above 15 keV apply to external dose. Open-area radiation fields applicable to 

external dose may have been temporarily present during leaks of Kr-85 gas into Building 100, 

Area 109. Only the workers in the rooms housing the leak-detection systems during the 

event incurred these external exposures. Any leak-incident exposure is assessed as 100% >15 

keV electrons. Beta dose monitoring for Kr-85 at the Pinellas Plant may have underestimated 

the dose because of the correction factor used until 1986. NIOSH compensates for the 

energy spectrum differences by applying a correction factor of 3.5 for the applicable years 

[ORAUT 2017a, PDF p. 31].

NIOSH reviewed data for 172 claimants, those with external monitoring data in NOCTS, 

against each claimant’s job title. The data represented the span of Pinellas Plant operations 

from 1957 through 1997, with 21 workers only having data for a single year. NIOSH reviewed 

the available dosimetry data in light of job classification and found Pinellas routinely 

monitored employees with operational positions involving proximity to the Kr-85 leakdetection equipment and significant potential for external dose exposure. Either the worker 

or their survivor provided the claimant’s job title during the claim process and in a few cases 

included more than one job title. NIOSH observed broad patterns in the data when searching 
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for certain key words. For example, NIOSH found that workers with descriptors indicating 

operational work, potentially in proximity to the Kr-85 leak-detection systems, like

“assembler” or “engineer” in the job title had the most external monitoring data. Titles 

including “manager” and “guard” that NIOSH expected to routinely operate in proximity to 

the Kr-85 leak-detection system less frequently than “assemblers” and “engineers” had

some external monitoring data. Titles like “secretary” and “draftsman” that NIOSH expected

would not perform their work around the Kr-85 leak-detection system had very little 

external monitoring data.

Additionally, NIOSH found that workers with one or more of the construction trade titles, 

such as electrician, mason, pipe fitter, iron worker, etc., were represented in the data for all 

years that the Pinellas Plant was in operation. NIOSH reviewed the Tiger Team Assessment of 

the Pinellas Plant [DOE 1990a, PDF p. 216] and found the assessment reported no significant 

findings related to the External Dosimetry Program, other than the dosimetry system had 

not completed accreditation. The Tiger Team noted that the Pinellas Plant generally kept 

external exposures, both individual and integrated plant personnel, very low.

NIOSH has access to beta dosimetry results, as well as other supporting data as described in 

this report for the entire period under evaluation to reconstruct dose. The dose measured by 

dosimeters, recorded at the time of measurement, represents the highest quality record for 

dose reconstruction.

The ABRWH Pinellas Plant Work Group has reviewed the Pinellas Plant — Occupational 

External Dose site profile document and has agreed that the protocols in the document are 

appropriate and sufficient to assign monitored and unmonitored electron dose [NIOSH 

2011b, PDF pp. 50–62; NIOSH 2016, PDF p. 22].

7.2.1.3 Neutron

The Pinellas Plant generated neutrons by neutron-generator sources and by RTG sealed heat 

sources. These produced neutrons in two distinct energy ranges. In the Neutron Generator 

Production Areas, located in Building 100, the neutrons were in the 2 to 20 MeV range. The 

plutonium in the RTG heat sources emitted neutrons with an average energy of 2 MeV and 

an energy range of thermal to 12 MeV [Burkhart 1987]. The RTG heat sources were all 

located in Building 400.

As described in Section 6.2.1, the Pinellas Plant used neutron-sensitive photographic films 

from 1957 through 1978, and beginning in mid-1978, R.S. Landauer provided neutron 

dosimetry for the Plant. Pinellas used Mound Laboratory dosimeters for the RTG handling 

work at Building 400, beginning in October 1979. NIOSH applies a correction factor to adjust 

for the poor response of NTA film to low-energy neutrons. This limitation does not affect 

dosimetry for neutron generator workers because neutron generators produce higherenergy neutrons. A 1969 study documented film badge fading experienced over a 

monitoring period of one month for neutron exposures to determine a correction factor 

from the data [Dosimeter fade study, no date]. The study recommended that the Pinellas 

Plant incorporate a correction factor of 3 to account for fading in NTA track film, starting in 

January 1970 [Dosimeter fade study, no date, PDF p. 12]. NIOSH also applies the correction 

factor of 3 for NTA film results between 1957 and 1969 for neutron generator workers
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because there is no indication that the Pinellas Plant used this factor prior to 1970. The NTA 

film Pinellas used from 1957 through June 1978, does not detect neutrons with an energy 

below 0.5 MeV [ORAUT 2006, PDF pp. 10–11]. Because 6.4% of the neutrons from the RTG 

heat sources have an energy of less than 1 MeV [Neutron spectra RTG, no date, PDF p. 5],

NIOSH applies a 1.07 correction factor for NTA neutron results for RTG workers.

Starting in the third quarter of 1981, the Pinellas Plant processed Mound TLDs to avoid signal 

fading, a loss of information that caused an underestimate of up to 30% of the dose 

recorded [Meyer 1993, PDF pp. 309–310, 344]. To compensate for this potential 

underestimate, NIOSH applies a correction factor of 1.43 for Mound TLD results from

October 1979 through June 1981.

When Pinellas used the Mound dosimeters to monitor exposures from RTG operations (i.e., 

October 1979–September 1987), they applied a relative biological effectiveness (RBE) value 

of 7 to the Pinellas Plant doses reported by the Mound Laboratory [ORAUT 2004a, PDF p. 

25]. Because lower-energy neutrons have a relatively greater biological impact, the current 

ICRP Publication 60 uses a neutron-weighting factor of 20 for neutron energies at or below 2 

MeV, and a weighting factor of 10 for energies above 2 MeV and below 20 MeV [ICRP 1990].

NIOSH applies two RBE correction factors for neutron results from 1957 through 1997 for 

RTG workers. Half of the result is multiplied by 2.85 (20/7) for the range below 2 MeV and 

half of each result is multiplied by 1.42 (10/7) for the energy range above 2 MeV.

The Pinellas Plant used an RBE weighting factor of 10.0 when calculating the effective dose 

for 14-MeV neutrons [Holliday, no date]. Since this is equivalent to the ICRP Publication 60 

neutron-weighting factor for neutron energies from 2 MeV [ICRP 1990], NIOSH does not 

apply a correction factor to the RBE weighting factor for neutron generator workers.

Available documentation does not describe any separate dosimetry processing when the 

Pinellas Plant used Landauer dosimeters to monitor exposures from RTG operations. 

Therefore, NIOSH assumes that the Pinellas Plant applied an RBE of 10 to the neutron doses 

from RTG operations when workers used Landauer dosimeters for the RTG operations from

January 1, 1975 through September 1979, and from September 1987 through February 

1991. From October 1979 through September 1987, NIOSH applies a single RBE value of 7 to 

the Pinellas Plant doses reported by the Mound Laboratory [ORAUT 2004a, PDF p. 17]. 

Because the RBE used for the Mound dosimeters is more favorable to claimants than the 

RBE believed to have been used for Landauer dosimeters, and because it compensates for 

the signal fading, NIOSH assumes an RBE of 7 and multiplies the Mound TLD results reported 

during the period from October 1979 through June 1981 by a signal-fading correction factor 

of 1.43 (1/0.70). After June 1981, Mound dosimeters used TLD chips that responded well to 

the neutron energies encountered by RTG workers. There was no significant signal fading for 

those dosimeters and no corrections for signal fading are necessary. Therefore, NIOSH 

applies no adjustment for the neutron-energy response of the Mound dosimeters after June 

1981 [ORAUT 2004a]. For the Mound TLDs, NIOSH applies an uncertainty of ±30% based on 

the site-specific information for the Mound Site [ORAUT 2004a].
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The ABRWH Pinellas Plant Work Group reviewed the history of the RBE weighting factor 

[NIOSH 2011b, PDF pp. 51–55] and has reviewed the minimum detection levels of the 

neutron dosimetry and the expected neutron energy distribution [NIOSH 2016, PDF p. 17].

7.2.2 Evaluation of Bounding Ambient Environmental External Radiation Doses

Kr-85 is the only external ambient environmental exposure concern at the Pinellas Plant. 

Tritium emits beta particles of less than 15 keV and are not energetic enough to penetrate 

the skin. Based on the information available to NIOSH, workers could have received small 

external doses from the Kr-85 stack emissions. Emissions from the area sources (i.e., the 

ponds and aeration area) would not have contributed to the environmental external doses 

at the Pinellas Plant because tritium was the only emission from the area sources. NIOSH 

uses the annual airborne effluent data to calculate the maximum air concentrations from the 

annual Kr-85 releases, using the atmospheric dispersion factors documented in Table A-8 of 

Pinellas Plant – Occupational Environmental Dose [ORAUT 2011d, PDF p. 43]. NIOSH then 

calculates dose rates using the maximum dose coefficient for air submersion found in the 

Federal Guidance Report No. 12, External Exposure to Radionuclides in Air, Water, and Soil

[Eckerman and Ryman 1993, PDF p. 75]. NIOSH calculated onsite ambient Kr-85 doses 

assuming continuous release over a calendar year, even though most of the releases were 

instantaneous acute releases [ORAUT 2011j]. NIOSH multiplies the calculated dose rates by 

the number of seconds in a 2,600-hour working year to estimate the bounding annual onsite 

ambient doses. NIOSH included the onsite ambient external doses from stack releases of Kr85 in Pinellas Plant – Occupational Environmental Dose [ORAUT 2011d, PDF p. 23] for the 

years that the Pinellas Plant reported Kr-85 releases.

Unmonitored Pinellas Plant workers had the potential to receive external doses that were 

<20 mrem/year but were more than the highest onsite ambient doses for the site [ORAUT 

2011d, PDF p. 23]. Because the potential external doses at the Pinellas Plant were likely 

larger than the calculated onsite ambient doses, NIOSH assigns unmonitored external doses, 

based on the 95th percentile of monitored workers, for all workers in lieu of onsite ambient 

doses.

7.2.3 External Dose Reconstruction Feasibility Conclusion

Pinellas staff knew the areas of potential radiation exposure and routinely monitored them. 

Photon radiation exposure at Pinellas only occurred in the areas described in Section 5.3.1 of 

this report, including the Neutron Generator Production Areas, Building 400, accelerator 

areas, and the Component Testing Area. The Pinellas Plant routinely surveyed these areas 

and the results were below the operational standards. Based on NIOSH’s review of the 

available dosimetry data, the Pinellas Plant routinely monitored employees with a potential 

for external dose exposure. The large number of monitored individuals that routinely had 

doses below the reporting levels (approximately 95% of the monitored workers at the 

Pinellas Plant had a whole body dose of less than or equal to 100 mrem for any given year, 

and nearly 80% received annual doses less than or equal to 20 mrem per year) [ORAUT 

2017a, PDF p. 27] is evidence that exposures to large radiation fields were very unlikely. 

NIOSH has found that it is feasible to reconstruct external dose for Pinellas Plant workers for 

the period under evaluation, using the available personnel monitoring data, area monitoring 
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data, and ambient environmental data. NIOSH will continue to use the existing external dose 

assessment methods for the Pinellas Plant to assign external dose for the class under 

evaluation.

7.3 Occupational Medical X-ray Doses at the Pinellas Plant

As stated in Section 6.4, Pinellas Plant workers were administered chest X-rays throughout 

the Pinellas Plant history [ORAUT 2007a; ORAUT 2011c, PDF pp. 10–14]. NIOSH did not find 

site-specific information for radiographic equipment before 1972; organ doses for this 

period are from ORAUT-OTIB-0006 [ORAUT 2019]. NIOSH calculates organ doses for 1972 

and later based on actual Pinellas Plant X-ray machine measurements and included these 

doses in the Pinellas Plant – Occupational Medical Dose site profile document [ORAUT 

2011c, PDF pp. 20–32].

NIOSH has access to sufficient information to estimate the radiation dose resulting from 

occupational medical X-rays using OTIB-0006 [ORAUT 2019]. Therefore, NIOSH concludes 

that it is feasible to estimate the occupational medical dose for Pinellas Plant employees.

7.4 Evaluation of Petition Basis for SEC-00256

The following subsections evaluate the assertions made in petition SEC-00256 (August 17, 

2020 version) for the Pinellas Plant. From this point forward, all references to the petition 

include only the August 17, 2020 version unless otherwise specified. The petition requests a 

Special Exposure Cohort for the Pinellas Plant based on reported incomplete radiological 

characterizations that did not include strontium-90, cobalt-60, thallium-204, beryllium, and 

uranium [[redacted] 2020b, PDF pp. 24–31]. The petition claims dosimetry and exposure 

records are absent beyond 1981 for workers who the Pinellas Plant monitored, and that 

workers who the Pinellas Plant did not monitor would have been unaware of their exposures

[[redacted] 2020b, PDF pp. 24–25, 30]. It generally contends that there is uncertainty about 

the ability of NIOSH to adequately and accurately perform dose reconstructions for former 

workers of the Pinellas Plant given an incompleteness of data sources, questionable 

technical accuracy, and overall inadequacy of data related to the four previously mentioned 

radionuclides (beryllium is not a radionuclide and does not represent a source of radiological 

exposure). 

Note: Throughout Section 7.4 and its subsections, NIOSH has summarized all petitioneridentified issues unless they appear in italics, which indicates a direct quote.

7.4.1 Unmonitored Exposures to Sr-90, Co-60, Tl-204, and Uranium

Petition Issue: ORAU identifies seven radionuclides deemed pertinent to estimating the 

doses of the former workers of the Pinellas Plant and does not address other miscellaneous 

radionuclides for Pinellas Plant workers. The petitioners indicate that unmonitored 

exposures to strontium-90, cobalt-60, thallium-204, and uranium occurred [[redacted] 

2020b, PDF pp. 20–31].
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NIOSH Response: The petition included five “Exhibits,” including: Exhibit 1 titled “Radioactive 

Material Inventory at the Pinellas Plant,” Exhibit 2 titled “Pinellas Plant Radioactive Source 

Historical Inventory Status,” Exhibit 3 titled “Radioactive Measurements of Pinellas County,” 

Exhibit 4 titled “Space Isotopic Power Systems,” and Exhibit 5 titled “Properties of Isotopes 

Useful for Isotopic Power Generation.” Exhibits 1 through 3 are excerpts from documents 

that note the presence of radioactive materials in and around the Plant, including strontium 

check sources, and sampling results from five Pinellas County sampling locations for radium, 

tritium, strontium. The presence of radioactive materials at Pinellas is not an indication of an 

unmonitored exposure condition. Exhibits 4 and 5 are general references not specific to the 

Pinellas Plant that provide information about space isotopic-power systems and other 

isotopes useful for power generation. NIOSH found no indication of an unmonitored 

exposure condition at the Pinellas Plant related to strontium-90, cobalt-60, thallium-204, or 

uranium in these excerpts.

NIOSH reviewed the information available regarding post-employment urine sampling and 

analysis of former workers of the Pinellas Plant that the petitioners provided. NIOSH has 

concluded that there is no information supporting exposures to the radionuclides 

mentioned. The provided data (i.e., laboratory results) do not support the assertion that any 

individuals incurred exposures to these “other” radionuclides used at the facility. The metals 

urine analysis, purported to represent exposures to strontium-90, cobalt-60, and thallium204, was not specific to these radionuclides; rather, the results were for elemental 

strontium, cobalt, and thallium, all of which occur in nature in a non-radioactive form. The 

presence of these elements, as indicated by chemical analysis, is not indicative of 

occupational exposure to the radioactive isotopes. The results of the uranium analysis were 

reported as either ‘none detected’ or <1.0 ng/ml. A notation in the laboratory report 

associated with the < 1 ng/ml result is “Normal (unexposed population)” [[redacted] 2020b, 

PDF p. 47].

Uranium was used at the Pinellas Plant as described in Section 5.2.3 of this report, but there 

are no indications of internal exposures and uranium is considered to have posed little to no 

internal dose hazard. Although the Pinellas Plant used other radionuclides, as discussed in 

Section 5.3, they were mostly limited to sealed and plated check sources [Pinellas Plant 

radioactive, no date] and would not have presented a significant internal exposure hazard.

The site used strontium and cobalt sealed sources that were kept under control and some 

level of radiological surveillance to ensure that the materials were well fixed, as indicated by 

the identification of the leaking Co-60 source and indicated in routine health physics reports 

[Jech 1963, PDF p. 8]. NIOSH’s review of Pinellas Plant records suggests Pinellas addressed 

such incidents of contaminated sources immediately when found, including assessing

involved personnel. Consequently, contaminated sources are not evidence of unmonitored 

exposures.

7.4.2 Radiological Incidents

Petition Issue: Although the Department of Energy (DOE) and National Institute of 

Occupational Safety and Health (NIOSH) have documented a series of radiological incidents 

that occurred at the Pinellas Facility, nowhere in this documentation is there any discussion 
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of whether these exposures were actually used to determine the extent of exposure for ANY 

worker at the Pinellas Plant at the time of the incident [[redacted] 2020b, PDF p. 21].

NIOSH Response: Based on its review of radiological incidents that occurred during the 

petition time period, NIOSH found that worker dose assessment was an important part of 

each incident response. The Pinellas Plant included such dose assessments in the workers’ 

dosimetry file. A review of the scope of incidents shows them to primarily be contamination, 

loss of containment, or other isolated situations. The incidents are of a routine industrial 

variety that had the potential to result in localized radiation exposures, which according to 

NIOSH’s review, Pinellas likely assessed as part of the incident response. NIOSH initially 

reviews all incidents against the SEC Petition E.5 basis criteria.

Based on NIOSH’s review of available documentation, indications are that the Pinellas Plant 

was diligent about following-up on contamination-related incidents and personnel 

exposures, as documented in incident reports [GE 1972, PDF pp. 2–10; Holliday 1970–1979; 

Pinellas Plant 1976–1979; Pinellas Plant 1971–1975] and Health Physics Investigation 

Reports [Jech 1963; GE 1963; GE 1983b,c; Holliday 1982a,b]. Manufacturing Engineering and 

Health Physics conducted a three-week investigation of the contamination incident, as 

described in the subsequent correspondence [Phillips 1975]. Incidents meeting the reporting 

threshold as an unusual occurrence had the immediate response actions documented in 

Occurrence reports [Burkhart 1988, PDF pp. 4–7; DOE 1992a,b; DOE 1995b] along with any 

assessment of exposures. The Pinellas Plant would have included any incident-related 

exposures in the employee dose files.

The petition specifically cited three resources related to incidents: 

 Tiger Team Assessment of the Pinellas Plant by the U.S. Department of Energy, 

Environment, Safety and Health [DOE 1990a]

 Health Physics Report: Historical Report of Radiation Protection [Historical report of 

radiation, no date]

 Department of Labor’s Site Exposure Matrices: Incident Search by Related Item – Pinellas 

Plant by the U.S. Department of Labor [DOL, no date]

None of the three resources identified by the petitioners provided documentation of 

incidents that were unmonitored, unrecorded, or inadequately monitored or recorded.

The Tiger Team Assessment noted that there was no formal documentation of investigations 

into personnel exposure anomalies [DOE 1990a, PDF p. 222], but described investigations of 

personnel exposure anomalies that were completed by the health physicist who assigned

the final dose. The finding pertained to the lack of formality, and not informing personnel or 

their supervisors of the incident information used to develop the exposure assignment.

The Historical Report of Radiation Protection at GEND [Historical report of radiation, no 

date] discusses glass breakage as a frequent occurrence during early operations and 

breakage of a titanium-hydride bed causing high levels of floor contamination, both of which 

had the potential to cause personnel exposure. The report gives no indications that Pinellas 
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did not monitor or inadequately monitored personnel during these events, or that Pinellas 

did not document the monitoring.

The DOL Site Exposure Matrices website [DOL, no date] incident search for Pinellas Plant lists 

42 incidents, including radiological contamination, radiological releases, hazardous 

conditions, and potential exposures to toxic materials from 1963 to 1993. The Exposure 

Matrices website provides no information on personnel exposure or monitoring.

None of the three cited resources contain any specific information to support the assertion 

that Pinellas did not monitor employees for radiological exposure caused by radiological 

incidents. NIOSH has not found information indicating the Plant did not monitor individuals 

associated with the incidents discussed in the documents. NIOSH previously reached this 

same conclusion when it evaluated the incidents identified in the Historical Report of 

Radiation Protection at GEND as well as during a review of available SRDB documents during 

the qualification efforts for SEC-00130 [ORAUT 2009], SEC-00184 [ORAUT 2011k], and SEC00231 [ORAUT 2016b].

The petitioners cited an event listed in Appendix A of the report Historical Report of 

Radiation Protection at GEND [Historical report of radiation, no date, PDF pp. 9–12] related 

to a leaking Co-60 source in 1961 as an example of an incident involving potential 

unmonitored exposure. The full citation was: “100 mCi of Co-60 source found leaking was 

corrected” [Historical report of radiation, no date, PDF p. 10; Burkhart 1990]. A review of 

monthly health physics reports for 1961 identified the source of the summarized 

information as the July 1961 report, which contained the following entry: “A routine survey 

revealed leakage of Health Physics’ 100 mc [sic] cobalt source. Corrective action was taken 

immediately” [Forest 1961, PDF p. 4]. The source documents do not provide any indication 

or evidence to indicate that the identified condition, which Pinellas immediately corrected, 

precipitated an unmonitored exposure condition to site personnel.

7.4.3 Plutonium

Petition Issue: While the Department of Energy notes that plutonium present at the Pinellas 

Plant site was triply encapsulated in metal to contain potential releases, air monitoring and 

soil monitoring procedures were put in place to monitor for the release of plutonium 

238/239. Despite encapsulation, levels of plutonium 238 and 239 were detected in both air 

and soil samples. While the Department of Energy noted that the levels of plutonium were at 

environmental background levels, it is important to note that the Tiger Team found sampling 

deficiencies where plutonium was concerned. (Citation: A/CF-6 Plutonium Stack Sampling 

Deficiencies) The majority of workers WERE NEVER monitored for plutonium 238/239 

exposures [[redacted] 2020b, PDF p. 22].

NIOSH Response: Finding A/CF-6 Plutonium Stack Sampling Deficiencies specifically relates 

to the environmental monitoring equipment associated with the heat-source production 

area (i.e., the Building 400 area involving the use of plutonium sources). The stack-sampling 

equipment monitors concentrations of radionuclides in effluent leaving the facility and is 

unrelated to the concentrations within the facility work areas. Accordingly, the finding has 

no bearing on the radiation exposure monitoring program associated with site employees.
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In addition, the ABRWH contractor reviewed the issue of plutonium monitoring at the 

Pinellas Plant [SC&A/Salient 2006, PDF pp. 26, 33] and discussed it at subsequent Advisory 

Board Meetings [NIOSH 2009, PDF pp. 26–31; NIOSH 2011b, PDF pp. 70–89; NIOSH 2012b, 

PDF p. 28]. SC&A documented the final resolution in the March 15, 2016 update of the Issue 

Resolution Matrix [SC&A 2016a, PDF p. 5], which summarizes the plutonium issue as follows: 

This was a concern early in the issues resolution process, when some potential 

exposure to plutonium (Pu) was not ruled out. Based on discussions at the October 

2011 WG meeting, it was determined that the only source of potential intake was 

from handling of newly received triple encapsulated radio-thermal generators (RTGs). 

However, there was no surface contamination greater than 200 dpm (the rejection 

level), and NIOSH calculations show that to receive even 1 mrem annual dose would 

require handling thousands of RTGs in a year. Therefore there is no credible source of 

exposure. In Revision 2 of TBD 5, all Pu discussion was removed based on discussion 

at the October 2011 WG meeting. If evidence of a positive exposure is discovered, 

NIOSH will need to develop a dose reconstruction (DR) methodology.

Accordingly, NIOSH determined that there was no significant source of exposure to Pu-238 

at the facility and concluded that the issue does not impact its ability to perform individual 

dose reconstructions for members of the NIOSH-evaluated class.

7.4.4 Duplicate Samples

Petition Issue: Health Physicist Holliday also reported that accurate monitoring was impacted 

by the fact that “Employees were found falsely identifying urine samples” [[redacted] 2020b, 

PDF p. 22]. 

NIOSH Response: The source of the condition is a statement in the September 1963 monthly 

report by Health Physicist Holliday: “During the past month it was discovered that some 

personnel were falsely identifying urine samples submitted for radioactivity analysis. This 

condition was brought to the attention of responsible supervision and efforts are being made 

to develop a technique to positively identify duplicate samples” [Forest 1963a, PDF p. 4].

The October 1963 monthly report appears to follow-up on the issue when it states: “A 

discussion was held with a Manufacturing work group regarding the purpose and value of 

the Bio-assay Program” [Forest 1963b, PDF p. 4].

NIOSH has not located any further discussion definitively related to the issue. The response 

to the “condition” was to develop a technique to positively identify duplicate samples. This 

indicates the condition did not impact the actual individual sample results (i.e., the results 

derived from the samples were not falsified or otherwise impacted). The September Health 

Physics Report identifying the condition states “some personnel” were falsely identifying 

samples, which leads NIOSH to believe a simple misunderstanding by workers of the 

bioassay-sampling requirements is the most likely scenario. If the issue of “falsely identifying 

urine samples” was related to deliberately and incorrectly associating individual samples to a 

particular person and/or sample date, such a circumstance would not likely impact the 

overall population of sample results (which NIOSH has access to). NIOSH has found no 
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indication of widespread “falsely identifying urine samples” or that the condition impacted a 

majority of the results; NIOSH accepts the report statement that “some personnel” were 

involved.

NIOSH believes the most reasonable interpretation of the situation is one of misdating 

samples; for example, an employee who was required to provide more than one sample in a 

week could have split one sample by voiding in two sample containers or provided two 

samples on the same day. Two samples given at the same time or near to the same time 

would be considered duplicate samples for the purposes of determining tritium dose, unless 

they were specifically given before and after tritium work.

Based on the frequency of tritium bioassay sample collection, an issue with individual 

bioassay sample misidentifying would not impact the ability to reconstruct radiation dose for 

members of the evaluated class prior to 1963. NIOSH has access to Pinellas radiation 

protection program documentation confirming that Pinellas actively tracked individual 

radiation exposures via tritium urine bioassay samples. NIOSH understands that the Pinellas 

Plant expected that individuals continuing work in tritium areas, those included in the 

bioassay sampling program, would provide a sample during the next cycle. Those most likely 

to be exposed were on the shortest cycle (daily vs. weekly vs. monthly) and would have been

expected to provide a sample in the very near term. This means if there are individuals that 

may not have turned in samples due to this issue, NIOSH can calculate their dose from the 

next sample that was turned in. For any workers with duplicate samples, NIOSH will assign 

the higher of the two results for the monitoring period. The Pinellas Plant bioassay program 

records show that results seldom reached or exceeded the site action levels for the 

radionuclides under assessment. Therefore, it is unlikely that the Pinellas Plant failed to

monitor any significant worker exposures. Because individual duplicate results won’t affect 

the population of results, NIOSH can use tritium bioassay data from this time period to 

determine an unmonitored dose approach, if needed. NIOSH concludes that the issue does 

not impact its ability to perform individual dose reconstructions for all members of the 

NIOSH-evaluated class.

7.4.5 Radioactive Materials in Building 100

Petition Issue: Documentation mentions a Radioactive Materials Management Area (RMMA) 

in Building 100, and rooms within Building 100 are not self-contained, so airborne 

radioactive materials could circulate throughout the Plant [[redacted] 2020b, PDF p. 23]. 

NIOSH Response: The reference to the RMMA designation in Building 100 comes from the 

1995 report, Moratorium Documentation Manual for the Pinellas Plant. The purpose of this 

document is to identify areas where dispersible radioactive material is present in order to 

control the generation of mixed hazardous and radioactive waste [Ohlweiler 1995, PDF p. 

16]. Designation as an RMMA in and of itself does not relate to the potential for 

unmonitored radiological exposure to site personnel. NIOSH is aware of the designation of 

areas within Building 100 as RMMAs and has documented this in Table 2-3 of Pinellas Plant – 

Site Description [ORAUT 2011b, PDF p. 31]. The document does not provide any information 

specific to a lack of containment of radiological materials or a lack of radiological monitoring 

within the area identified as an RMMA within Building 100. 
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Documentation describes Building 100 as a warehouse-style facility with partitions. An 

MMSC safety assessment describes Building 100 as the main production area, divided into 

distinct rooms. Some areas of Building 100 were access controlled to prevent the spread of 

contamination. Access to these areas required passage through two sets of locked doors 

[Martin Marietta 1994d, PDF pp. 39–44]. Pinellas designed and constructed buildings with 

ventilation systems, fume hoods, and gloveboxes to minimize inhalation uptakes by workers 

[SC&A/Salient 2006, PDF p. 28]. The Pinellas Plant conducted routine surface and air 

monitoring in work areas containing radioactive material [ORAUT 2016a, PDF pp. 14–16], as 

discussed in Sections 6.1.2 and 6.2.2. Design features (e.g., ventilation systems and fume 

hoods), in conjunction with the radiological monitoring program in place, would preclude 

unidentified and unmonitored exposure of general employees in areas that were “not selfcontained.”

7.4.6 Employer-required Chest X-rays

Petition Issue: The petitioners reviewed employee files and found that the majority of 

employees were not afforded chest X-rays [[redacted] 2020b, PDF p. 23]. 

NIOSH Response: DOE provides records of medical X-rays performed for individual claimants. 

NIOSH detailed the interpretation of, and assumptions related to medical X-rays in ORAUTTKBS-0029-3, Pinellas Plant – Occupational Medical Dose. Current NIOSH dose 

reconstruction guidance assigns medical doses based on individual X-ray examinations 

recorded in the submitted medical records. When no X-ray examination records are 

available for an individual, the dose reconstructor assumes that an annual PA chest X-ray 

was administered, in accordance with the Pinellas Plant – Occupational Internal Dose site 

profile document [ORAUT 2011c, PDF p. 10]. NIOSH notes that if employees were not given 

chest X-rays, the approach described above would overestimate radiation doses to those 

employees.

7.4.7 Lack of Radiological Surveys

Petition Issue: A technical review of the Pinellas Plant in 1994 identified a lack of 

comprehensive radiological surveys [[redacted] 2020b, PDF p. 23]. 

NIOSH Response: The full citation, related to comprehensive surveys also includes the 

statement: “Process knowledge, experience, and surveys in hand describe the identification 

of the location, quantity, extent, and type of contamination within each buildings [sic]” [DOE 

1994b, PDF p. 55]. The purpose of the cited Independent Technical Review of the Pinellas 

Plant document is to document the transition of the Pinellas Plant from operations to either 

community-developed reuse or safe deactivation leading to decontamination and 

decommissioning [DOE 1994b, PDF p. 6]. The cited Technical Review is unrelated to the 

potential for unmonitored worker exposure during Pinellas Plant activities.

7.4.8 Environmental Monitoring Record Keeping

Petition Issue: According to the Pinellas Plant Feasibility Study Final Report (1990): “Typical 

of many DOE facilities, meticulous environmental monitoring and records keeping did not 
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take place until the early to mid 1970's. Prior to that, monitoring and records keeping was 

not very thorough” [[redacted] 2020b, PDF p. 23].

NIOSH Response: The complete citation includes the following statement: “However, after 

reviewing plant publications, interviewing key personnel, and checking the existence, 

accessibility, and quality of documents important to dose reconstruction at the plant, we 

have concluded that a dose reconstruction is feasible” [HRS 1994, PDF p. 124]. The scope of 

the document relates to the reconstruction of exposure to members of the public, not site 

employees, and is unrelated to the potential for unmonitored worker exposure during site 

activities.

7.4.9 Missing Dosimetry Records 

Petition Issue: A small number of workers were monitored for radiologic exposures, although 

inconsistently, and some were never monitored for such exposures. For those that were 

monitored, their dosimetry records only included information until 1981. Dosimetry records 

beyond 1981 were missing from all of their DOL and DOE files that were examined

[[redacted] 2020b, PDF p. 24].

NIOSH Response: As discussed in Section 6 of this report, NIOSH has access to both internal 

dosimetry data for 1957–1996 and external dosimetry data for 1957–1995. NIOSH also has 

area monitoring results spanning the operations at the Pinellas Plant. As mentioned in 

Section 6.1.1, NIOSH reviewed ALARA reports, which are available from 1986 through 1995, 

and that review showed the site monitored 1,772 workers over those 10 years. NIOSH has

estimated an average workforce size of 1,500 for all of those ten years, primarily from 

reviewing the annual site environmental reports and counting the number of employees 

listed on rosters. Dividing the number of employees monitored by the number of workers for 

10 years indicates that the site monitored approximately 12% of employees for tritium 

intakes from 1986 through 1995. Therefore, in response to the claim the Pinellas Plant 

monitored a small number of workers for radiological exposures, NIOSH agrees that this 

could be considered a small number of workers but finds that the monitoring practices at 

the Pinellas Plant were based on exposure potential rather than plant population and that 

adequate dosimetry records are available for dose reconstruction.

NIOSH’s review of the dosimetry files shows that the Pinellas Plant was consistent in 

assigning employees to the monitoring program. Although some Pinellas Plant files show 

that some workers have breaks in tritium bioassay monitoring, these are ordinary and 

explainable gaps in the dosimetry data that are consistent with the exposure potential of 

comparable tasks assigned to similar job descriptions across the DOE industrial complex.

While lending to the impression of inconsistent monitoring, these breaks do not impede 

dose reconstruction. NIOSH expects there to be periods when monitoring was halted for 

legitimate reasons and has established methods to account for such gaps in internal 

monitoring, as described in Section 7.1.1.

Regarding dosimetry data availability post-1981, as stated above, NIOSH has dosimetry data 

available past 1981. The petitioners mentioned “DOE and DOL files that were examined” in 

the issue identified above. NIOSH assumes the review is of dosimetry records files provided 
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for Pinellas Plant claimants by DOE or DOL. NIOSH reviewed the files it received from DOE 

and found that DOE is, in a majority of cases, providing the same dosimetry data that are 

available to NIOSH from NIOSH’s own independent data-capture efforts, including post-1981 

data.

In 2006, NIOSH became aware it was not receiving all of the dosimetry records from DOE for 

some Pinellas Plant claimant files. Following this discovery, NIOSH worked with DOE to 

locate additional dosimetry records at archival locations across the DOE complex; NIOSH

uploaded that additional data to the SRDB. NIOSH has completed linking this captured 

dosimetry data in the SRDB to individual NOCTS claimant files via the SPEDELite process.

NIOSH’s Post Approval Dosimetry (PAD) Evaluation Tracker System routinely identifies claims 

with new information. NIOSH reviews the information to determine if the SPEDELite-linked 

information has any impact on the previously-completed dose reconstruction. Completed 

dose reconstructions are re-evaluated regularly to include consideration of the updated 

dosimetry record for the individuals. If the new information has the potential to increase the 

previously reconstructed doses, NIOSH reworks the non-compensable dose reconstruction. If 

a previously non-compensable claim becomes compensable through the re-work process, 

NIOSH notifies the claimant. NIOSH has no mechanism to notify claimants that they are 

reviewing their claim in this PAD process unless the claim becomes compensable. Therefore, 

if the petitioners based their dosimetry data review on claims impacted by this issue, the 

original claimant files may not have included dosimetry data that NIOSH received and 

reviewed at a later time.

In 2020, NIOSH performed a data review to ensure that DOE was providing data for 

monitored Pinellas worker claims. NIOSH identified monitored workers by the presence of 

SPEDELite links to monitoring data in the SRDB. Using this information, NIOSH has been able 

to identify 332 claimants for whom NIOSH has significant dosimetry data within the SRDB 

(out of 496 Pinellas claimants). An additional 59 claimants were not included in this analysis 

because, for them, NIOSH only identified termination samples and no other routine 

monitoring data. Of these 332 claimants with significant dosimetry data, DOE provided all of 

the same dosimetry data for 293 (88%).

NIOSH then chose the 10 claims with the highest number of SPEDELite links to check that the 

data provided by DOE in response to claim-record requests were consistent with what 

NIOSH had independently captured and loaded in the SRDB. NIOSH’s comparison showed 

that seven of the 10 files had no discrepancies between what DOE provided on request and 

what NIOSH has available for those workers. Of the three DOE responses that had some 

discrepancy, two were missing a termination tritium-sample result, and the final response 

was missing both a termination tritium-sample result and one other sample (which showed 

no detectable tritium internal exposure). Note that whether NIOSH receives the information

in the DOE responses or via data capture and SPEDELite-linked to the claim, NIOSH considers 

all information in the dose reconstruction.

NIOSH also compared the contents of the termination folders in the SRDB [Pinellas Plant 

1942–1985; Pinellas Plant 1948–1985] to the DOE record-request responses. NIOSH 

reviewed the termination folder records and identified records for 21 NOCTS claims. For the 

21 claims, the DOE response had 100% agreement with the termination folder data.
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7.5 Summary of Feasibility Findings for Petition SEC-00256

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

the Pinellas Plant from January 1, 1957 through December 31, 1990. NIOSH found that the 

available monitoring records, process descriptions, and source term data are sufficient to 

complete dose reconstructions for the evaluated class of employees.

NIOSH has determined that the Pinellas Plant had policies in place to monitor internal and 

external radiation doses incurred by members of the NIOSH-evaluated class. The Internal 

Dose Monitoring Program in effect during the NIOSH-evaluated period is described in 

Pinellas Plant – Occupational Internal Dose [ORAUT 2016a, PDF pp. 14–18]. Pinellas Plant – 

External Dosimetry describes the external dose monitoring program [ORAUT 2017a, PDF pp. 

16–27]. These documents indicate that Pinellas did not monitor some workers but did 

monitor the workers with the potential for radiation exposure using bioassay and external 

dosimetry. Both external and internal dosimetry results are available, and the available data 

extend beyond 1981. In addition, NIOSH has found that claimant records provided by DOE 

generally include both internal and external dosimetry results for potentially exposed 

workers. NIOSH finds that the Pinellas Plant did monitor potentially exposed personnel and 

did not find indications of lack of monitoring for the class under evaluation. NIOSH concludes 

that it has sufficient data to perform dose reconstructions.

Table 7-1 summarizes the results of the feasibility findings at the Pinellas Plant for each 

exposure source during the period from January 1, 1957 through December 31, 1990. 

Table 7-1: Summary of Feasibility Findings for SEC-00256

January 1, 1957 through December 31, 1990

Source of Exposure Reconstruction Feasible 

(Yes or No)

Internal (tritium) Yes

Internal (plutonium, uranium, carbon-14) N/A

External (Gamma, Beta, Neutron) Yes

External (Occupational Medical X-ray) Yes

As of May 3, 2021, NIOSH has received a total of 496 claims for individuals who worked at 

the Pinellas Plant during the period under evaluation in this report. NIOSH has completed 

dose reconstructions for 456 individuals (~92%). 
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8 Evaluation of Health Endangerment for Petition SEC-00256

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 the radiation dose that 

the class members received, then NIOSH must also determine that there is a reasonable 

likelihood that such radiation dose may have endangered the health of members of the 

class. There are two ways to establish health endangerment. First, if NIOSH finds 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, then 

NIOSH will assume that any duration of unprotected exposure could cause a specified 

cancer, and hence may have endangered the health of members of a class. Second, if the 

occurrence of an exceptionally high-level exposure has not been established, then NIOSH 

will specify that health was endangered for those employees 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 [42 C.F.R. 83, 2018, PDF p. 11]. 

Based on the sum of information from available resources, NIOSH’s evaluation determined

that it is feasible to estimate the radiation dose received by members of the NIOSHevaluated class. Therefore, a health endangerment determination is not required.
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9 Class Conclusion for Petition SEC-00256

Based on its full research of the class under evaluation, NIOSH found that it can estimate 

radiation doses received by members of the class under evaluation and the entire period of 

employment under consideration. This class includes all employees of the Department of 

Energy, its predecessor agencies, and their contractors and subcontractors who worked at 

the Pinellas Plant in Clearwater, Florida for the period from January 1, 1957 through 

December 31, 1990.

NIOSH has carefully reviewed all material sent in by the petitioners, 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 SRDB, for 

information relevant to SEC-00256. In addition, NIOSH reviewed its NOCTS dose 

reconstruction database to identify EEOICPA-related dose reconstructions that might 

provide information relevant to the petition evaluation.

NIOSH bases these actions 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 wellgrounded 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 contends that it has complied with these standards of 

performance in determining the feasibility or infeasibility of reconstructing radiation dose 

for the class under evaluation. 
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10 References

42 C.F.R. 81 [2019]. Guidelines for determining probability of causation under the Energy 

Employees Occupational Illness Compensation Program Act of 2000. [SRDB Ref ID: 

180246]

42 C.F.R. 82 [2019]. Methods for conducting dose reconstruction under the Energy 

Employees Occupational Illness Compensation Program Act of 2000. [SRDB Ref ID: 

180247]

42 C.F.R. 83 [2018]. Procedures for designating classes of employees as members of the 

Special Exposure Cohort under the Energy Employees Occupational Illness Compensation 

Program Act of 2000. [SRDB Ref ID: 179160]

ANSI [1981]. American national standard for dosimetry – internal dosimetry programs for 

tritium exposure – minimum requirements. New York, NY: American National Standards 

Institute. ANSI N13.14-1983. July 8. [SRDB Ref ID: 31910]

Barclay HT [1995]. Health physics consensus statement 6 Pinellas Plant personnel external 

dosimetry program revised October 31, 1995. November 7. [SRDB Ref ID: 187618]

Biedermann C [1994]. Historical tritium inventory. Correspondence to Simonton R, 

Department of Energy, Industrial Hygiene/Health Physics. Largo, FL: Martin Marietta 

Specialty Components. March 9. [SRDB Ref ID: 12020]

Burkhart RA [1987]. Recommendation to use R. S. Landauer as our sole dosimetry vendor. 

Correspondence to Richardson CD, Environmental Health and Safety Programs. Pinellas 

Plant, Largo, FL: GE Neutron Devices. July 16. [SRDB Ref ID: 12184]

Burkhart RA [1988]. Unusual occurrence report NDD-88-03 failure of an X-ray shield on Ebeam welding unit Area 331. Correspondence with report. Pinellas Plant, Largo, FL: GE 

Neutron Devices. April 20. [SRDB Ref ID: 105284]

Burkhart RA [1989]. Release criteria used at GEND. Correspondence to Gregory HF. 

Pinellas Plant, Largo, FL: GE Neutron Devices. October 2. [SRDB Ref ID: 188521]

Burkhart RA [1990]. Historical report on radiation protection at GE Neutron Devices.

Pinellas Plant, Largo, FL: GE Neutron Devices. GEPP-EV-1126, July 11. [SRDB Ref ID: 12026]

Burkhart RA [1995]. Internal dosimetry technical basis document. Pinellas Plant, Largo, FL: 

Lockheed Martin Specialty Components. MMSC-ESH-95062, July. [SRDB Ref ID: 12945]

Carpenter RT [1963]. Space isotopic power systems. May. [SRDB Ref ID: 187545]

[redacted] [2020]. SEC-00256 interview participants. Compilation of Emails sent to NIOSH. 

November 17–18. [SRDB Ref ID: 185815]

Detlefs EH [1993]. TRACER-Flo operational readiness approval. Pinellas Plant, Largo, FL: 

Martin Marietta Specialty Components. July 1. [SRDB Ref ID: 187543]
SEC-00256 10-13-2021 Pinellas Plant

86 of 130

DOE [no date-a]. Office of Environment, Health, Safety and Security (EHSS) facilities 

database listing for Pinellas Plant. Washington, DC: U.S. Department of Energy. Date 

accessed: July 12, 2021. [SRDB Ref ID: 187540]

DOE [no date-b]. Environmental management site cleanup summaries. Appendix E, Paths 

to Closure. Washington, DC: U.S. Department of Energy. [SRDB Ref ID: 73786]

DOE [1983]. Environmental assessment Pinellas Plant Site. Washington, DC: U.S. 

Department of Energy. DOE/EA-0209, July. [SRDB Ref ID: 9971] 

DOE [1987]. Environmental survey preliminary report for Pinellas Plant, Largo, Florida. 

Washington, DC: U.S. Department of Energy, Environment, Safety and Health. 

DOE/EH/OE-13P, November. [SRDB Ref ID: 88797]

DOE [1990a]. Tiger Team assessment of the Pinellas Plant. Washington, DC: U.S. 

Department of Energy, Environment, Safety and Health. DOE/EH-0126, May. [SRDB Ref 

ID: 46090]

DOE [1990b]. Pinellas Plant final action plan. Washington, DC: U.S. Department of Energy, 

Environment, Safety and Health. DOE/EH-0126, December 3. [SRDB Ref ID: 88853]

DOE [1991]. Health physics operating procedures manual. Washington, DC: U.S. 

Department of Energy, Environment, Safety and Health. August 20. [SRDB Ref ID: 12976]

DOE [1992a]. Occurrence report DP-ALO-PI-GEND-PINELLAS-1991-1082 tritium recovery 

system converter failure. Pinellas Plant, Washington, DC: U.S. Department of Energy. 

March 11. [SRDB Ref ID: 182220]

DOE [1992b]. Occurrence report DP-ALO-PI-GEND-PINELLAS-1991-1081 contaminated 

waste area exceeds site contamination standards. Pinellas Plant, Washington, DC: U.S. 

Department of Energy. April 22. [SRDB Ref ID: 182218]

DOE [1994a]. U.S. DOE implementation guide G-10 C.F.R. 835/C2 - rev. 1 external 

dosimetry program. Washington, DC: U.S. Department of Energy, Office of the Assistant 

Secretary for Environment, Safety and Health. G-10 CFR 835/C2 Rev. 1, November. [SRDB 

Ref ID: 165219]

DOE [1994b]. Independent technical review of the Pinellas Plant. Washington, DC: U.S. 

Department of Energy, Environment, Safety and Health. LA-UR-94-3662, July. [SRDB Ref 

ID: 181753]

DOE [1995a]. Environmental assessment for decontamination and dismantlement. 

Washington, DC: U.S. Department of Energy. DOE/EA-1092, June. [SRDB Ref ID: 9965]

DOE [1995b]. Occurrence report EM-ALO-PI-MMSC-PINELLAS-1995-0008 tritium 

contamination. Pinellas Plant, Washington, DC: U.S. Department of Energy. July 20. [SRDB 

Ref ID: 182216]
SEC-00256 10-13-2021 Pinellas Plant

87 of 130

DOE [2007]. DOE handbook – tritium handling and safe storage. Washington, DC: U.S. 

Department of Energy. DOE-HDBK-1129-2007, March. [SRDB Ref ID: 166548]

DOL [no date]. Department of Labor’s site exposure matrices: incident search by related 

item – Pinellas Plant. Washington, DC: U.S. Department of Labor. Date accessed: August 

25, 2020. [SRDB Ref ID: 182695] 

DOL [2020]. Pinellas Plant site clarification. Correspondence to DOE and NIOSH. Pinellas 

Plant. Washington, DC: U.S. Department of Labor. December 31. [SRDB Ref ID: 189074]

Doran WT [1967]. Examples of types of accidents or occupationally-related disease that 

have resulted or could result in a workmen's compensation claim or civil suit. 

Correspondence. Washington, DC: U.S. Atomic Energy Commission Headquarters. July 12. 

[SRDB Ref ID: 187539]

Dosimeter fade study [no date]. [SRDB Ref ID: 12778]

Eckerman KF, Ryman JC [1993]. External exposure to radionuclides in air, water, and soil. 

Oak Ridge, TN: Oak Ridge National Laboratory. EOA-402-R-93-081, September. [SRDB Ref 

ID: 11997]

Eichman CC [1979]. New uranium bed processing system. Pinellas Plant, St. Petersburg, 

FL: General Electric Company Neutron Devices Department. PT Report No. 79-008, April 

11. [SRDB Ref ID: 13169]

Ellis ED, Boice JD, Golden AP, Girardi DJ, Cohen SS, Mumma MT, Shore RE, Leggett RW, 

Kerr GD [2018]. Dosimetry is key to good epidemiology: workers at Mallinckrodt Chemical 

Works had seven different source exposures. Health Phys 114(4):386–397. [SRDB Ref ID: 

178826]

First plutonium delivered on-site [no date]. [SRDB Ref ID: 12022]

Forest EP [1959–1962]. ES&H reports 1959–1962. Largo, FL: Pinellas Plant. [SRDB Ref ID: 

15179]

Forest EP [1961]. Health physics report July 1961. Largo, FL: Pinellas Plant. August 16. 

[SRDB Ref ID: 182941] 

Forest EP [1963a]. Health physics report September 1963. Largo, FL: Pinellas Plant. 

October 21. [SRDB Ref ID: 182940]

Forest EP [1963b]. Health physics report October 1963. Largo, FL: Pinellas Plant. 

November 22. [SRDB Ref ID: 182939]

Fry S [1990]. Epidemiologic study of Pinellas Plant employees: implementation. 

Correspondence to McLaren L. Pinellas Plant, Oak Ridge, TN: Oak Ridge Associated 

Universities. September 12. [SRDB Ref ID: 187536]
SEC-00256 10-13-2021 Pinellas Plant

88 of 130

GE [1963]. Radiation incident investigation report 3. Pinellas Plant, St. Petersburg, FL: 

General Electric Company X-ray Department. April 17. [SRDB Ref ID: 187682]

GE [1969–1983]. Radiological safety manual. Pinellas Plant, St. Petersburg, FL: General 

Electric Company Neutron Devices Department. [SRDB Ref ID: 123366]

GE [1971–1984]. Ion acceleration information including shielding – safety assessment 

document building 800. Compilation of various versions of the same document. Pinellas 

Plant, St. Petersburg, FL: General Electric Company Neutron Devices Department. [SRDB 

Ref ID: 12802]

GE [1972]. Radiation exposure [redacted] May 15, 1972. Compilation of correspondence

relating to exposure incident. [SRDB Ref ID: 13196]

GE [1977]. Preliminary proposal Ion Accelerator Facility. December 8. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. [SRDB Ref ID: 

186333]

GE [1980]. Pinellas Plant environmental monitoring report 1979. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. GEPP-EM-484, 

April. [SRDB Ref ID: 185626]

GE [1981]. Pinellas Plant environmental monitoring report 1980. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. GEPP-EM-570, 

March. [SRDB Ref ID: 185627]

GE [1982a]. Safety analysis report expansion of Building 400 RTG Facility. Pinellas Plant, 

St. Petersburg, FL: General Electric Company Neutron Devices Department. May. [SRDB 

Ref ID: 13264]

GE [1982b]. Pinellas Plant environmental monitoring report 1981. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. GEPP-EM-654,

March. [SRDB Ref ID: 185628]

GE [1983a]. Pinellas Plant environmental monitoring report 1982. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. GEPP-EM-729, 

April. [SRDB Ref ID: 185629]

GE [1983b]. Report of investigation of tritium release incident, January 5, 1983. Pinellas 

Plant, St. Petersburg, FL: General Electric Company Neutron Devices Department. 

February 21. [SRDB Ref ID: 187685]

GE [1983c]. Tritium release Area 108. Pinellas Plant, St. Petersburg, FL: General Electric 

Company Neutron Devices Department. February 28. [SRDB Ref ID: 187686]

GE [1984a]. Pinellas Plant’s radioactive waste implementation plan. Pinellas Plant, Largo, 

FL: General Electric Company Neutron Devices Department. GEPP-SP-848, September. 

[SRDB Ref ID: 186416]
SEC-00256 10-13-2021 Pinellas Plant

89 of 130

GE [1984b]. Pinellas Plant environmental monitoring report 1983. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. GEPP-EM-806, 

April. [SRDB Ref ID: 12260] 

GE [1984c]. Assignment of personnel to work in radioactive material, contamination or 

radiation areas. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron 

Devices Department. G.1.12, June 29. [SRDB Ref ID: 185867]

GE [1986]. Pinellas Plant facts. St. Petersburg, FL: General Electric Company Neutron 

Devices Department. GEPP-CB-986, September. [SRDB Ref ID: 88851]

GE [1987]. Pinellas Plant environmental monitoring report 1986. Pinellas Plant, Largo, FL: 

General Electric Company Neutron Devices Department. GEPP-EM-1017, April. [SRDB Ref 

ID: 88850]

GE [1989a]. Pinellas Plant: child care/partnership school safety assessment. Largo, FL: 

General Electric Neutron Devices Department. NDPP-97004108, November. [SRDB Ref ID: 

186016]

GE [1989b]. Requirements for radioactive contamination monitoring and control. Largo, 

FL: General Electric Neutron Devices Department. STANDARD 5.2 Rev. 2.0, January 20. 

[SRDB Ref ID: 12992]

GE [1990]. Environmental assessment operation of the Pinellas Plant Child Development 

Center/Partnership School. Pinellas Plant, Largo, FL: General Electric Neutron Devices 

Department. DOE-EA-0642, July 20. [SRDB Ref ID: 88791]

Goldsmith R [1990]. DOE notification of ORAU epidemiologic study of Pinellas Plant 

employees. Correspondence to Patenaud E. Washington, DC: U.S. Department of Energy. 

September 5. [SRDB Ref ID: 187537]

Gueretta J [2015]. Pinellas Plant history and information used to process EEOICPA claim 

requests. PowerPoint presentation. Washington, DC: U.S. Department of Energy. July 9. 

[SRDB Ref ID: 184115]

Gurley J [1968]. MC unit – timer – TTA matrix electronic units. August 1. [SRDB Ref ID: 

187360]

Hall CK [1989]. GEND’s remedial action plan for the Department of Energy Laboratory 

Accreditation Program (DOELAP), DOE Order 5480.15. Correspondence with application 

and personnel dosimetry reports. Pinellas Plant, St. Petersburg, FL: GE Aerospace. 

December. [SRDB Ref ID: 12166]

Harder UM [1991]. 1990 annual ALARA program report for ionizing radiation. May 14. 

[SRDB Ref ID: 182932] 

Historical report of radiation protection at GEND [no date]. Document included as part of 

petition SEC-00256 application. [SRDB Ref ID: 19647]
SEC-00256 10-13-2021 Pinellas Plant

90 of 130

Holliday JN [no date]. RBE factors used at Pinellas Plant for tritium and neutron 

exposures. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron Devices 

Department. [SRDB Ref ID: 186384]

Holliday JN [1970–1979]. 1970s incident reports involving tritium. Compilation of incident 

reports. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron Devices 

Department. [SRDB Ref ID: 12804]

Holliday JN [1982a]. Status report – recommendations tritium release – Area 108, 

September 1, 1982. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron 

Devices Department. November 29. [SRDB Ref ID: 187684]

Holliday JN [1982b]. Tritium release Area 108, September 1, 1982. Pinellas Plant, St. 

Petersburg, FL: General Electric Company Neutron Devices Department. September 14. 

[SRDB Ref ID: 187683]

Holliday JN [1983]. Unusual personnel radiation exposure dosimeter period: June 1, 1983 

through July 11, 1983. Pinellas Plant, St. Petersburg, FL: General Electric Company 

Neutron Devices Department. August 11. [SRDB Ref ID: 187542]

HRS [1994]. Pinellas Plant feasibility study—final report. Tallahassee, FL: State of Florida 

Department of Health and Rehabilitative Services (HRS). September. [SRDB Ref ID: 6501]

HRS [1995]. Department of Energy oversight program Pinellas Plant environmental 

radiological measurements January 1994–December 1994 annual report. Tallahassee, FL: 

State of Florida Department of Health and Rehabilitative Services (HRS) Office of Radiation 

Control. [SRDB Ref ID: 187491]

ICRP [1990]. ICRP 60 – 1990 recommendations of the International Commission on 

Radiological Protection. ICRP Publication 60. Ann ICRP 21(1–3). [SRDB Ref ID: 11517]

ICRP [1994a]. ICRP 68 – dose coefficients for intakes of radionuclides by workers. ICRP 

Publication 68. Ann ICRP 24(4). [SRDB Ref ID: 22731]

ICRP [1994b]. ICRP 66 – human respiratory tract model for radiological protection. ICRP 

Publication 66. Ann ICRP 24(1–3). [SRDB Ref ID: 22732]

ICRP [2008]. ICRP 107 – nuclear decay data for dosimetric calculations. ICRP Publication 

107. Ann ICRP 38(3). [SRDB Ref ID: 136400]

Institute of Medicine [2013]. Review of the Department of Labor's site exposure matrix 

database. Washington, DC: The National Academies Press. [SRDB Ref ID: 178827]

Internal dosimetry practices [1983]. September 23. [SRDB Ref ID: 12177]

Inventory of radionuclides historically used at the plant [no date]. [SRDB Ref ID: 187616]

IT/Radiological Sciences Laboratory [1986]. A technical evaluation of the air monitoring 

systems in use for exhaust stack emissions and environmental measurements at the 
SEC-00256 10-13-2021 Pinellas Plant

91 of 130

Pinellas Plant, Largo, Florida. Pinellas Plant, Oak Ridge, TN: IT/Radiological Sciences 

Laboratory. September 30. [SRDB Ref ID: 13255]

Jech JJ [1963]. Health physics report 1962. Correspondence to Wilson RF. March 25. 

[SRDB Ref ID: 187681]

Jelinek TM [1990]. Epidemiologic study of Pinellas Plant employees. Correspondence to 

Veigel JM, Oak Ridge Associated Universities. Washington, DC: U.S. Department of 

Energy. October 5. [SRDB Ref ID: 187490]

Kocher DC [1981]. Radioactive decay data tables, a handbook of decay data for 

application to radiation dosimetry and radiological assessments. Washington, DC: U.S. 

Department of Energy, Office of Scientific and Technical Information. DOE/TIC-11026. 

[SRDB Ref ID: 32563] 

[redacted] [2019]. Special exposure cohort petition SEC-00256 Pinellas Plant. Received by 

NIOSH December 16, 2019. [SRDB Ref ID: 182952] 

[redacted] [2020a]. Special exposure cohort petition Pinellas Plant revised edition. 

Received by NIOSH May 21, 2020. May 20. [SRDB Ref ID: 182963]

[redacted] [2020b]. Special exposure cohort petition Pinellas Plant revised edition. 

Replaces documents submitted on January 21 and May 20, 2020. Received by NIOSH 

August 17. August 17. [SRDB Ref ID: 182967] 

Malbrough DJ [1983]. The Pinellas Plant Ion Accelerator Facility: an apparatus for lowenergy ion scattering and nuclear reactor analysis. Pinellas Plant, St. Petersburg, FL: 

General Electric Company Neutron Devices Department. GEPP-OP-741, April 19. [SRDB 

Ref ID: 88901]

Martin Marietta [1992]. Pinellas Plant site environmental report for CY1991. Pinellas 

Plant, Largo, FL: Martin Marietta Specialty Components. MMSC-EM-92047, October. 

[SRDB Ref ID: 12025]

Martin Marietta [1993a]. Pinellas Plant annual site environmental report for calendar 

year 1992. Pinellas Plant, Largo, FL: Martin Marietta Specialty Components. MMSC-ESH93035, June. [SRDB Ref ID: 12013]

Martin Marietta [1993b]. Final action plan. Pinellas Plant, Largo, FL: Martin Marietta 

Specialty Components. MMSC-OSP-93052. [SRDB Ref ID: 12956] 

Martin Marietta [1994a]. The last of the best...from tubes and generators to heather and 

capacitors...employees come through. Headliner. September 23. [SRDB Ref ID: 187361]

Martin Marietta [1994b]. Radionuclide air emissions annual report for CY1993. Pinellas 

Plant, Largo, FL: Lockheed Martin Specialty Components. MMSC-EM-94150, May 12. 

[SRDB Ref ID: 88876]
SEC-00256 10-13-2021 Pinellas Plant

92 of 130

Martin Marietta [1994c]. Pinellas Plant environmental monitoring plan. Pinellas Plant, 

Largo, FL: Martin Marietta Specialty Components. MMSC-EM-94099. April. [SRDB Ref ID: 

88847]

Martin Marietta [1994d]. Safety assessment of Area 108, tube exhaust. Pinellas Plant, 

Largo, FL: Martin Marietta Specialty Components. MMSC-SA-93076, January 28. [SRDB 

Ref ID: 12031]

Martin Marietta [1994–1995]. X-ray diffraction survey. Various completed X-ray 

equipment survey forms. Pinellas Plant, Largo, FL: Martin Marietta Specialty Components. 

[SRDB Ref ID: 13201]

Martin Marietta [1995]. Pinellas Plant environmental baseline report. Pinellas Plant, 

Largo, FL: Martin Marietta Specialty Components. February 8. [SRDB Ref ID: 13197]

Martin Marietta [1996]. Radionuclide air emissions annual report for CY1995. Pinellas 

Plant, Largo, FL: Lockheed Martin Specialty Components. MMSC-EM-96031, May. [SRDB 

Ref ID: 185573]

Martin Marietta [1997a]. Radionuclide air emissions annual report for CY1996. Pinellas 

Plant, Largo, FL: Lockheed Martin Specialty Components. MMSC-EM-97006, April. [SRDB 

Ref ID: 12244]

Martin Marietta [1997b]. Pinellas Plant environmental baseline report June 1997. Pinellas 

Plant, Largo, FL: Lockheed Martin Specialty Components. MMSC-EM-97013, June. [SRDB 

Ref ID: 48197]

McCall GR [1973]. Report of radiation protection survey at General Electric Co. St. 

Petersburg, FL: Pinellas County Health Department. January 4. [SRDB Ref ID: 188564]

Meyer HE [1993]. History of personnel external dosimetry program at the Dayton Project 

and Mound Laboratory, 1946–1993, volume V. [SRDB Ref ID: 3297]

Moeller MP, Townsend RD, Dooley DA [2008]. The NIOSH radiation dose reconstruction 

project: managing technical challenges. Health Phys 95(1):14–19. [SRDB Ref ID: 178830]

NCRP [1983]. NCRP 72 – radiation protection and measurements for low-voltage neutron 

generators. Bethesda, MD: National Council on Radiation Protection and Measurements 

(NCRP). November 1. [SRDB Ref ID: 167665]

NDD generator [1986]. NDD generator production. September 2. [SRDB Ref ID: 187359]

NDD product [1980]. NDD product descriptions. April. [SRDB Ref ID: 187249]

NDD product [1990]. NDD product descriptions. October 31. [SRDB Ref ID: 187358]

Neutron spectra RTG [no date]. [SRDB Ref ID: 13165]
SEC-00256 10-13-2021 Pinellas Plant

93 of 130

Newton [no date]. DOL notice of final decision on employee dates. Washington, DC: U.S. 

Department of Labor. [SRDB Ref ID: 187688]

NIOSH [2007]. External dose reconstruction implementation guideline. Cincinnati, OH: 

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

Prevention, National Institute for Occupational Safety and Health. OCAS-IG-001 Rev 3, 

November 21. [SRDB Ref ID: 38864]

NIOSH [2008a]. The U.S. Department of Health and Human Services Centers for Disease 

Control and Prevention National Institute for Occupational Safety and Health convenes 

the Workgroup meeting Advisory Board on Radiation and Worker Health Pinellas June 11, 

2008. Transcript. Washington, DC: U.S. Department of Health and Human Services, 

Centers for Disease Control and Prevention, National Institute for Occupational Safety 

and Health, Advisory Board on Radiation and Worker Health. [SRDB Ref ID: 186980] 

NIOSH [2009]. United States of America Department of Health and Human Services 

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

Health Advisory Board on Radiation and Worker Health Work Group on the Pinellas Plant 

SEC Thursday, June 11, 2009. Transcript. Washington, DC: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, Advisory Board on Radiation and Worker Health. [SRDB 

Ref ID: 183079]

NIOSH [2011a]. Internal procedures for the evaluation of special exposure cohort 

petitions. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for 

Disease Control and Prevention, National Institute for Occupational Safety and Health. 

DCAS-PR-004 Rev. 1, April 15. [SRDB Ref ID: 94768]

NIOSH [2011b]. U.S. Department of Health and Human Services Centers for Disease 

Control National Institute for Occupational Safety and Health Advisory Board on Radiation 

and Worker Health Work Group on Pinellas Thursday, October 13, 2011. Transcript. 

Washington, DC: U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and Health, Advisory 

Board on Radiation and Worker Health. [SRDB Ref ID: 183137]

NIOSH [2012a]. Pinellas Plant site expert interview list. Cincinnati, OH: U.S. Department of 

Health and Human Services, Centers for Disease Control and Prevention, National 

Institute for Occupational Safety and Health. January 24 and 25. [SRDB Ref ID: 185817]

NIOSH [2012b]. U.S. Department of Health and Human Services Centers for Disease 

Control National Institute for Occupational Safety and Health Advisory Board on Radiation 

and Worker Health Work Group on Pinellas Monday, November 19, 2012. Transcript. 

Washington, DC: U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and Health, Advisory 

Board on Radiation and Worker Health. [SRDB Ref ID: 183138]

NIOSH [2016]. U.S. Department of Health and Human Services Centers for Disease Control 

National Institute for Occupational Safety and Health Advisory Board on Radiation and 
SEC-00256 10-13-2021 Pinellas Plant

94 of 130

Worker Health Pinellas Plant Work Group Thursday, February 11, 2016. Transcript. 

Washington, DC: U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and Health, Advisory 

Board on Radiation and Worker Health. [SRDB Ref ID: 187124]

NIOSH [2020a]. Summary of telephone conversation and agreements SEC-00256 – 

Pinellas Plant – [redacted] January 21, 2020. Correspondence to [redacted]. Cincinnati, 

OH: U.S. Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health. January 29. [SRDB Ref 

ID: 182960]

NIOSH [2020b]. Summary of telephone conversation and agreements SEC-00256 – 

Pinellas Plant – [redacted] June 17, 2020. Correspondence to [redacted]. Cincinnati, OH: 

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

Prevention, National Institute for Occupational Safety and Health. June 23. [SRDB Ref ID: 

182964]

NIOSH [2020c]. Summary of telephone conversation and agreements SEC-00256 – 

Pinellas Plant – [redacted] June 17, 2020. Correspondence to [redacted]. Cincinnati, OH: 

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

Prevention, National Institute for Occupational Safety and Health. June 23. [SRDB Ref ID: 

182965]

NIOSH [2020d]. Summary of telephone conversation and agreements SEC-00256 – 

Pinellas Plant – [redacted] June 17, 2020. Correspondence to [redacted]. Cincinnati, OH: 

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

Prevention, National Institute for Occupational Safety and Health. June 23. [SRDB Ref ID: 

182966] 

Ohlweiler F [1995]. Moratorium documentation manual for the Pinellas Plant. Pinellas 

Plant, Largo, FL: Martin Marietta Specialty Components. MMSC-ESH-0016 Rev. G, January 

12. [SRDB Ref ID: 13505]

ORAUT [2004a]. Technical basis document for the Mound Site – occupational external 

dosimetry. Oak Ridge Associated Universities Team. ORAUT-TKBS-0016-6 Rev 00, August 

11. [SRDB Ref ID: 19791]

ORAUT [2004b]. Tritium calculated and missed dose estimates. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-OTIB-0011 Rev. 00, June 29. [SRDB Ref ID: 19430] 

ORAUT [2006]. Effect of threshold energy and angular response of NTA film on missed 

neutron dose at the Oak Ridge Y-12 facility. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-OTIB-0051 Rev. 00, May 15. [SRDB Ref ID: 29977]

ORAUT [2007a]. Documented communication with [redacted] on technical basis 

document Pinellas Plant – occupational medical dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. November 13. [SRDB Ref ID: 37343]
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ORAUT [2007b]. Documented communication with [redacted] on Technical Basis 

Document Pinellas Plant - Occupational External Dose: inquiring about potential radiation 

exposures from the Kr-85 gas that is used in the Radiflo leak detection systems. Oak 

Ridge, TN: Oak Ridge Associated Universities Team. November 20. [SRDB Ref ID: 37342]

ORAUT [2009]. Special Exposure Cohort (SEC) petition SEC-00130 Pinellas Plant petition 

document review. Oak Ridge, TN: Oak Ridge Associated Universities Team. January 13. 

[SRDB Ref ID: 182944]

ORAUT [2011a]. Pinellas Plant – introduction. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-TKBS-0029-1 Rev. 01, April 18. [SRDB Ref ID: 99872] 

ORAUT [2011b]. Pinellas Plant – site description. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-TKBS-0029-2 Rev. 02, April 01. [SRDB Ref ID: 99874] 

ORAUT [2011c]. Pinellas Plant – occupational medical dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0029-3 Rev. 01, October 13. [SRDB Ref ID: 

102290] 

ORAUT [2011d]. Pinellas Plant – occupational environmental dose. Oak Ridge, TN: Oak 

Ridge Associated Universities Team. ORAUT-TKBS-0029-4 Rev. 01, July 15. [SRDB Ref ID: 

99867]

ORAUT [2011e]. Pinellas Plant annual environmental intakes based on stack releases 

spreadsheet. Spreadsheet. Oak Ridge, TN: Oak Ridge Associated Universities Team. 

February 11. [SRDB Ref ID: 92634]

ORAUT [2011f]. Annual environmental intakes attributable to Pinellas Plant’s onside 

measured air concentrations spreadsheet. Spreadsheet. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. February 16. [SRDB Ref ID: 92800]

ORAUT [2011g]. Pinellas Plant simplified environmental intakes for dose estimate 

spreadsheet. Spreadsheet. Oak Ridge, TN: Oak Ridge Associated Universities Team. 

February 11. [SRDB Ref ID: 92638]

ORAUT [2011h]. Pinellas bounding environmental internal dose assessment spreadsheet. 

Spreadsheet. Oak Ridge, TN: Oak Ridge Associated Universities Team. February 10. [SRDB 

Ref ID: 92633]

ORAUT [2011i]. Pinellas Plant stack data spreadsheet. Spreadsheet. Oak Ridge, TN: Oak 

Ridge Associated Universities Team. February 11. [SRDB Ref ID: 92639]

ORAUT [2011j]. Pinellas Plant annual onsite ambient doses spreadsheet. Spreadsheet. 

Oak Ridge, TN: Oak Ridge Associated Universities Team. February 11. [SRDB Ref ID: 

92637]

ORAUT [2011k]. Petition document review – professional judgement Special Exposure 

Cohort petition SEC-00184, Pinellas Plant. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. June 1. [SRDB Ref ID: 183175]
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ORAUT [2013a]. Documented communication with [redacted] on past radiological control 

practices at the Pinellas Plant with an emphasis on the controls for metal tritides. Oak 

Ridge, TN: Oak Ridge Associated Universities Team. June 18. [SRDB Ref ID: 127111]

ORAUT [2013b]. Documented communication with [redacted] and [redacted] on 

analyzing tritium contamination smears at Pinellas Plant. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. November 12. [SRDB Ref ID: 129125]

ORAUT [2016a]. Pinellas Plant – occupational internal dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0029-5 Rev. 03, July 18. [SRDB Ref ID: 

158070] 

ORAUT [2016b]. SEC-00231 Pinellas Plant petition document review. Oak Ridge, TN: Oak 

Ridge Associated Universities Team. September 12. [SRDB Ref ID: 183176]

ORAUT [2017a]. Pinellas Plant – occupational external dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0029-6 Rev. 02, December 11. [SRDB Ref ID: 

168436] 

ORAUT [2017b]. Guidance on assigning occupational X-ray dose under EEOICPA for X-rays 

administered off site. Oak Ridge, TN: Oak Ridge Associated Universities Team. ORAUTOTIB-0079 Rev. 02, June 15. [SRDB Ref ID: 166967]

ORAUT [2017c]. Special exposure cohort. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-PROC-0044 Rev. 01, October 19. [SRDB Ref ID: 181580]

ORAUT [2017d]. Pinellas Plant – table 6-1 for ORAUT-TKBS-0029-6. Spreadsheet. Oak 

Ridge, TN: Oak Ridge Associated Universities Team. October 10. [SRDB Ref ID: 167865]

ORAUT [2019]. Dose reconstruction from occupational medical X-ray procedures. Oak 

Ridge, TN: Oak Ridge Associated Universities Team. ORAUT-OTIB-0006 Rev. 06, 

September 27. [SRDB Ref ID: 178310]

ORAUT [2020a]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990. Oak 

Ridge, TN: Oak Ridge Associated Universities Team. October 23. [SRDB Ref ID: 185745]

ORAUT [2020b]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. November 30. [SRDB Ref ID: 185748]

ORAUT [2020c]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 2. [SRDB Ref ID: 185752]

ORAUT [2020d]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 
SEC-00256 10-13-2021 Pinellas Plant

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particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 7. [SRDB Ref ID: 185809]

ORAUT [2020e]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 7. [SRDB Ref ID: 185753]

ORAUT [2020f]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 9. [SRDB Ref ID: 185749]

ORAUT [2020g]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 9. [SRDB Ref ID: 185754]

ORAUT [2020h]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 16. [SRDB Ref ID: 185929]

ORAUT [2020i]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 22. [SRDB Ref ID: 185747]

ORAUT [2020j]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. December 22. [SRDB Ref ID: 185813]

ORAUT [2021a]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 14. [SRDB Ref ID: 185751]

ORAUT [2021b]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 27. [SRDB Ref ID: 185810]

ORAUT [2021c]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. January 28. [SRDB Ref ID: 185812] 
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ORAUT [2021d]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. February 1. [SRDB Ref ID: 185811]

ORAUT [2021e]. Documented communication SEC-00256 with [redacted] on ability to 

perform radiation dose reconstructions for Pinellas workers between 1957 and 1990, 

particularly those not returning bioassay samples. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. February 2. [SRDB Ref ID: 185814]

ORAUT [2021f]. Number of Pinellas claimants by year and those with tritium data by year 

spreadsheets. Spreadsheet. Oak Ridge, TN: Oak Ridge Associated Universities Team. 

August 12. [SRDB Ref ID: 188333]

ORAUT [2021g]. Site profile and technical basis document development. Oak Ridge, TN: 

Oak Ridge Associated Universities Team. ORAUT-PROC-0031 Rev. 05, June 3. [SRDB Ref 

ID: 186309]

Patenaude E [1997]. Transfer of Pinellas facility. Correspondence to Williams K. Pinellas 

Plant, Washington, DC: U.S. Department of Energy. July 15. [SRDB Ref ID: 133405]

Pharo T [1993]. Building 400 safety analysis report – request to cancel. Pinellas Plant,

Largo, FL: Martin Marietta Specialty Components. July 21. [SRDB Ref ID: 186417]

Phillips D [1975]. Suggestion 10582 uranium bed incidents. Correspondence to Meadors 

RE. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron Devices 

Department. May 19. [SRDB Ref ID: 13125]

Pinellas Plant [1942–1985]. Termination folders “S”. Compilation of microfilm images for 

employees with last names beginning with the letter S. Pinellas Plant, St. Petersburg, FL: 

General Electric Company Neutron Devices Department. [SRDB Ref ID: 15185]

Pinellas Plant [1948–1985]. Employee termination folders “E–G”. Compilation of 

microfilm images for employees with last names beginning with the letters E through G. 

Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron Devices Department. 

[SRDB Ref ID: 15183]

Pinellas Plant [1957–1973]. HP summary reports for 1957–1973. Compilation of health 

physics reports for most months. [SRDB Ref ID: 27095]

Pinellas Plant [1960–1978]. 1960–1978 dosimetry data. Pinellas Plant, St. Petersburg, FL: 

General Electric Company Neutron Devices Department. [SRDB Ref ID: 11739]

Pinellas Plant [1971–1975]. 1970s incident reports. Compilation of incident reports with 

different dates. [SRDB Ref ID: 12805]

Pinellas Plant [1975–1986]. Plutonium bioassay data. Compilation of plutonium results 

from multiple employees, reporting forms, and sample dates. [SRDB Ref ID: 12102]
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Pinellas Plant [1976–1979]. Contamination and exposure incidents at GEND. Compilation 

of investigations into exposure incidents. [SRDB Ref ID: 12806]

Pinellas Plant [1976–1986]. Bioassay results for 1976–1986. Compilation of bioassay 

results from multiple employees, reporting forms, and sample dates. [SRDB Ref ID: 12770]

Pinellas Plant [1976–1987]. XRD and industrial X-ray surveys. Compilation of X-ray 

information, including procedures and surveys. [SRDB Ref ID: 13212]

Pinellas Plant [1978]. Termination reports. Compilation of termination occupational 

exposure reports. Pinellas Plant, St. Petersburg, FL: General Electric Company Neutron 

Devices Department. [SRDB Ref ID: 15851]

Pinellas Plant [1980]. U.S. DOE Pinellas Plant. Pinellas Plant, St. Petersburg, FL: General 

Electric Company Neutron Devices Department. [SRDB Ref ID: 187541]

Pinellas Plant [1988]. 1988 plutonium bioassay results. Compilation of plutonium bioassay 

results for 1988. [SRDB Ref ID: 12099]

Pinellas Plant [1992–1994]. Natural uranium glass concerns and related material. [SRDB 

Ref ID: 13204]

Pinellas Plant [1993]. Tritium results for oils/solvents. Compilation of tritium results for 

1993. [SRDB Ref ID: 133411]

Pinellas Plant [1995]. Health physics survey schedule. [SRDB Ref ID: 13230]

Pinellas Plant [1996]. Quarterly report on employees’ dose CY1995. February 9. [SRDB Ref 

ID: 187620]

Pinellas Plant radioactive source historical inventory/status [no date]. [SRDB Ref ID: 

186018]

Pope LE [2007]. Neutron generator production mission in a national laboratory. 

Albuquerque, NM: Sandia National Laboratories. SAND2007-3261, August. [SRDB Ref ID:

88823] 

Proposed increase in radiation dose rate from RTG heat sources [1988]. Compilation of 

related documents. [SRDB Ref ID: 12185]

Ragheb M [2011]. Radioisotopes power production. February 15. [SRDB Ref ID: 187544]

SC&A/Salient [2006]. SC&A review of the NIOSH site profile for the Pinellas Plant site. Rev. 

0 draft. Vienna, VA: S. Cohen & Associates. Jefferson, MA: Salient. SCA-TR-TASK1-0015 

Rev. 0 draft, September 15. [SRDB Ref ID: 105289]

SC&A [2016a]. Issues resolution matrix for Pinellas Plant – draft. Vienna, VA: SC&A, Inc. 

March 15. [SRDB Ref ID: 183078]
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SC&A [2016b]. Pinellas site profile review status report and action items following the 

work group meeting held on March 1, 2016. PowerPoint presentation. Vienna, VA: SC&A, 

Inc. March 23. [SRDB Ref ID: 188334]

Toohey RE [2008]. Scientific issues in radiation dose reconstruction. Health Phys 95(1):26–

35. [SRDB Ref ID: 79530]

Tritium smear surveys preparation and processing [no date]. [SRDB Ref ID: 12958]

University of North Carolina [1997]. Case control study of multiple myeloma among 

workers exposed to ionizing radiation and other physical and chemical agents – final. 

Chapel Hill, NC: University of North Carolina at Chapel Hill, Department of Epidemiology, 

School of Public Health. March 26. [SRDB Ref ID: 187538]

Ward WE [1971a]. Sensitivity levels of radiation measurements. Correspondence to 

Forest EP, Environmental Health & Safety Programs. Pinellas Plant, St. Petersburg, FL: 

General Electric Neutron Devices Department. February 5. [SRDB Ref ID: 187619]

Ward WE [1971b]. Changes in bioassay program. Correspondence to Forest EP, 

Environmental Health & Safety Programs. Pinellas Plant, St. Petersburg, FL: General 

Electric Neutron Devices Department. March 1. [SRDB Ref ID: 182935]

Ward WE [1973]. Tritium control technology at the AEC’s Pinellas Plant. Pinellas Plant, St. 

Petersburg, FL: General Electric Neutron Devices Department. GEPP-104, July 16. [SRDB 

Ref ID: 13128]

Ward WE [1974]. Film badge Types J, K, M. Correspondence with attachment. Pinellas 

Plant, St. Petersburg, FL: General Electric Neutron Devices Department. June 11. [SRDB 

Ref ID: 187617]

Weaver AS [no date]. Health physics guidelines for Kr-85 operations. [SRDB Ref ID: 

188446]

Weaver AS [1989]. External dosimetry procedure. Pinellas Plant, St. Petersburg, FL: 

General Electric Neutron Devices Department. HPO3 Rev 4.0, May 30. SRDB Ref ID: 12989

Weaver AS [1990a]. Health physics HP06 air sampling and monitoring. Pinellas Plant, St. 

Petersburg, FL: General Electric Neutron Devices Department. HP06 Rev. 4.0, April 12. 

[SRDB Ref ID: 187622]

Weaver AS [1990b]. Health physics HP03 external dosimetry. Pinellas Plant, St. 

Petersburg, FL: General Electric Neutron Devices Department. HP03 Rev. 5.0, January 15. 

[SRDB Ref ID: 187623]

Weaver AS [1990c]. Health physics HP03 external dosimetry. Pinellas Plant, St. 

Petersburg, FL: General Electric Neutron Devices Department. HP03 Rev. 6.0, April 11. 

[SRDB Ref ID: 187621]
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Weaver AS [1991]. 1990 annual ALARA program report for ionizing radiation. Pinellas 

Plant, St. Petersburg, FL: General Electric Neutron Devices Department. May 10. [SRDB 

Ref ID: 13008]

Weaver AS [1992]. ALARA program report for CY1991. Pinellas Plant, Largo, FL: General 

Electric Neutron Devices. April 13. [SRDB Ref ID: 182933] 

Weaver AS [1993a]. 1992 ALARA. Pinellas Plant, Largo, FL: Martin Marietta Specialty 

Components. April 26. [SRDB Ref ID: 12852]

Weaver AS [1993b]. ALARA program report for CY1992. Pinellas Plant, Largo, FL: Martin 

Marietta Specialty Components. March 25. [SRDB Ref ID: 182930]

Weaver AS [1995]. Health physics Pinellas Plant personnel external dosimetry program. 

Pinellas Plant, Largo, FL: Martin Marietta Specialty Components. February 23. [SRDB Ref 

ID: 186415]

Weaver AS [1996a]. Neutron generator health physics info sheet. Pinellas Plant, Largo, FL: 

Lockheed Martin Specialty Components. February 2. [SRDB Ref ID: 189295]

Weaver AS [1996b]. 1995 annual ALARA program report for ionizing radiation. Pinellas 

Plant, Largo, FL: Lockheed Martin Specialty Components. February. [SRDB Ref ID: 179210]
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ATTACHMENT ONE: DATA CAPTURE SYNOPSIS 

Table A1-1: Summary of Holdings in the SRDB for Pinellas Plant 

Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Primary Site / Company Name: 

Pinellas Plant

DOE 1957-1997; Remediation 

1999, 2008-2009 

Alternate Site Names: GE X-ray 

Division-Florida; GE Neutron 

Devices Department (GENDD); GE 

Neutron Devices (GEND) GE 

Pinellas Plan (GEPP)

Physical Size of the Site: 99.9 

acres; 755,584 ft2 interior 

building space; 

Site Population: 285 employees 

at the Neutron Generator 

temporary plant in 1957; 1252-

1304 total plan employees from 

1960-1973; 1974-1975 not 

available; 1976-1985 298-405 

employees monitored for 

radiation exposure.

Annual report on waste generation and waste minimization 

progress, conduct of operations implementation plan, 

development of the Pinellas plant site profile presentation, 

medical X-ray survey, gas leak reported at nuclear facility, general 

electric (GE), "GEND medical X-ray surveys" health physics 

department, historical report of radiation protection at GEND, 

medical facility shielding document, NIOSH Dose Reconstruction 

Project meeting on Pinellas site profile, Pinellas community 

health concerns detail report, report of radiation protection 

survey at General Electric Co., X-ray projections, techniques and 

shielding data.

02/21/2013 8 

State Contacted: [redacted], 

M.P.H., Chief, Florida 

Department of Health, Bureau of 

Radiation Control [redacted]

No relevant documents identified. 02/25/2013 0 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

DCAS SEC Viewer Employment records, petition and request for a full evaluation 

for a Special Exposure Class (SEC) under the EEOICP Act and 

Government Fraud of Transparency, petition document reviews, 

Professional Judgment SEC Petition, radiation exposure and 

employment records, SEC petition-Form B, and summary of 

telephone conversations and agreements.

09/23/2020 32

Department of Labor / Paragon Application for a hazardous waste facility permit, area 117P room 

diagram, asbestos-containing materials survey and bulk sampling 

report, banned hazardous substances, catholyte mixture, 

chemical and hazardous material inventories, conduct of 

operations area operating envelope for different areas tube 

assembly, de-encapsulation process specification, DOE tritium 

focus group meeting notes 1993, radiation dosimetry of metal 

tritides, effects of vacuum processing erbium 

dideuteride/ditritide films, final safety analysis reports, Industrial 

Hygiene audits, irradiation of units at low temperature test, job 

titles and responsibilities, neutron device department nonexempt job descriptions and position analysis forms, notes of 

areas and operations, occupational medical appraisal, Pinellas 

Plant inventory list, process waste assessment plan, review of 

neutron generator disposal, radio isotopically-powered 

thermoelectric generators (RTG) fixture cleaning process, safe 

work permits, air monitoring results, systematic risk assessment 

for General Electric neutron devices department, waste, trip 

report, tritium control technology at the Pinellas Plant, uranium 

bed oxidation vacuum process system, and X-ray emission 

spectroscopic determination.

01/23/2012 337
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

DOE Germantown DOE Legacy Management process used to respond to Energy 

Employee Occupational Illness Compensation Act (EEOICPA) 

claims, search procedures for records request to records holding 

area 1916T-2 Oak Ridge, Tennessee, and toxic hazards of 

beryllium as related to the reactor development program.

08/08/2012 4 

DOE Legacy Management - Grand 

Junction Office

Baseline environmental management report 1996. 11/18/2010 1 

DOE Legacy Management - 

Morgantown Office

Area radiation and contamination surveys, daily gel 

columns/monthly totals, air surveys, area closeout surveys, area 

characterization and final closeout reports, area film monitors, 

badge distribution lists by department, bioassay results, area 

tritium results, comprehensive Quality Assurance Plan, counter 

efficiency worksheets, daily tritium oxide discharge sheets, 

gamma and neutron film personnel data, health physics reports, 

items to be released surveys, National Emission Standards For 

Hazardous Air Pollutants Proposed Standards (NESHAPS) for 

radionuclides, Nuclear Chicago film badge exposure reports, 

personnel bioassay results, radon screening results, 

radioisotopically-powered thermoelectric generator (RTG) air 

sample station report, tritium bioassay results, waste summary, 

and exhaust stack summary.

06/18/2014 239
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

DOE Legacy Management - 

MoundView Office (Fernald 

Holdings, includes Fernald Legal 

Database)

DOE's annual radionuclide air emission report 1985, incineration 

of radioactive solid wastes a report, individual dosimetry data 

1979-1987, manufacturing statement for weapons production 

schedule of transfers 1962, and Mound reports of 

neutron/photon dosimeter results from Pinellas neutron devices 

department 1985.

02/01/2012 15

DOE Legacy Management - 

Westminster Office

NIOSH worker study protocol comments and Federal Bureau of 

Investigation (FBI) files of site raid in 1989.

07/03/2014 2 

DOE National Nuclear Security 

Administration (NNSA) - 

Albuquerque Office

Active employee listing 1995, area characterization and final 

closeout report, bioassay results 1993-1996, dose data summary 

1994-95, final radiological status reports, Landauer external 

exposure reports 1993-96, personnel dosimetry –thermal 

luminescent dosimetry (TLD) system questionnaire, Pinellas Plant 

personnel external dosimetry program, and life dose sorted by 

badge number 1996.

09/04/2008 69

DOE Office of Scientific and 

Technical Information (OSTI)

History of the production complex, DOE environmental 

restoration, and waste management site maps and facilities 

listings. 

05/17/2007 2 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Federal Records Center (FRC) - 

Atlanta

Active employees by badge unit and shift, air flow studies, air 

sample results, analysis of stack heights, annual ALARA report, 

annual radionuclide air emission report, annual stack emissions 

reports (tritium), annual summary of whole body exposures, area 

badge results, area film badge results, area surveys, bed 

oxidation capability, bioassay trends, building decommissioning 

and descriptions, calibration facility (Cs-137), calibration sources, 

clean air act assessment package-1988 (CAP 88-pc), 

characterization report Area 195, radiological incidents, 

contamination assessment reports for groundwater investigation, 

criticality safety for Pu-238 systems, decontamination and 

decommissioning summary site plan, environmental monitoring, 

EPA compliance certification, estimated doses to personnel 

handling unmarked neutron generation units, evaluation of 

energy conservation and tritium containment options, exhaust 

stack H3 and Kr-85 emission summary, final radiological status 

report, first plutonium delivered onsite, gamma and neutron film 

data worksheet, health physics data summary, health physics 

operating procedures, historical tritium inventory, industrial Xray surveys, internal dosimetry technical basis document 

Lockheed Martin, Kr-85 release survey, lab procedures for tritium 

analysis, medical and health physics services report, neutron 

shielding charts, environmental monitoring report, plutonium 

bioassay results, quality program plan health physics program, 

quality program plan for mixed waste management, radiological 

control manual, radon results, RTG safety information, safety 

analysis reports, semi-annual leak test master list, special work

permits, state of Florida tritium smear data, technical evaluation 

of the air monitoring systems, termination urines, unusual 

occurrence reports, visitor dose information, and X-ray producing 

equipment at General Electric Neutron Device facility (GEND).

09/302020 586
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Federal Records Center (FRC) - 

Denver 

Data inventories by facility, beryllium incidents, and onsite 

discharge data compilations 1973.

06/15/2010 3 

Federal Records Center (FRC) - 

Kansas City

Tiger Team findings, onsite radioactive waste inventories 1989, 

cleaning of equipment contaminated with beryllium or 

radioactive material, and nuclear safety appraisal of the 

Albuquerque Operations Office 1985.

10/09/2013 4 

Federal Records Center (FRC) - 

Lee's Summit

Analysis of findings DOE Tiger Team assessments, draft materials 

in inventory depleted uranium project, noteworthy practices as 

identified by the Tiger Team assessment 1990, proposed site 

treatment plan national summary report, radiological related 

occurrence reports, replacement of General Electric neutron 

devices, review of draft programmatic environmental impact 

statement for environmental restoration and waste 

management, and an annual report on waste generation and 

waste minimization progress.

06/06/2016 13 

Federal Records Center (FRC) - 

San Bruno

Corrective action plan to the report of the task group on 

operation of DOE tritium facilities.

11/30/2005 1 

Hanford Defense programs monthly occurrence report summary 1995, 

DOE comments on the Hazardous Waste Management system, 

and air quality area designations and classifications for DOE 

facilities. 

04/15/2011 4 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Idaho National Laboratory Tritium storage development progress report 1978, DOELAP 

accreditation decision for Pinellas Plant, DOE Laboratory 

Accreditation Program (DOELAP) applications for Albuquerque 

Operations Office 1988, and Idaho National Laboratory visitor 

cards 1971-1972.

08/25/2018 6 

Interlibrary Loan Environmental levels of radioactivity at Brookhaven National 

Laboratory and Pinellas Plant 1965-1972.

04/01/2010 13

Internet - Centers for Disease 

Control and Prevention (CDC)

Issue resolution matrix for Pinellas Plant (draft), NIOSH Advisory 

Board on Radiation and Worker Health work group on Pinellas 

2009, 2011-2012.

09/17/2020 4 

Internet - Defense Technical 

Information Center (DTIC)

Los Alamos National Laboratory institutional plan 1998-2003 and 

estimating the cold war mortgage volume 1 the 1995 baseline 

environmental management report.

07/20/2012 2 

Internet - DOE Facility l for General Electric X-ray Division. 02/16/2007 1 

Internet - DOE Hanford 

Declassified Document Retrieval 

System (DDRS)

Comments and request to postpone proposed rule changes to 

Washington Administrative Code, radiation protection - air 

emission program.

09/01/2010 1 

Internet - DOE Health Safety and 

Security (HSS)

Twenty-fourth annual report radiation exposures for DOE and 

DOE contractor employees 1991.

03/07/2011 1 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - DOE Legacy 

Management

Area plume control report, site assessment reports, 

environmental restoration project closure monitoring plan, 

environmental restoration project quarterly progress report, 

Pinellas environmental restoration project sitewide 

environmental monitoring quarterly progress reports, sampling 

and analysis plan for U.S. DOE Office of Legacy Management 

sites, and a DOE interim mixed waste inventory report.

03/30/2020 50

Internet - DOE Legacy 

Management Considered Sites

No relevant documents identified. 06/08/2020 0 

Internet - DOE Noncompliance 

Tracking System (NTS)

Radiological worker training closed report and a radiological 

incident of contaminated material not properly transferred.

06/09/2020 2 

Internet - DOE Occurrence 

Reporting Processing System 

(ORPS)

Occurrence reports of radiological incidents that include: 

contaminated material, improper shipment of explosive neutron 

generators, air monitor alarms, tritium control limits exceeded, 

improper shipment labeling, radiation readings exceeding site 

standards, stack alarm failure, inoperative Kanne chamber alarm, 

radiological exposure to an operator, and violation of a 

radiological safety procedure.

10/21/2020 57

Internet - DOE OpenNet AEC financial report, division progress report, index to the 

twenty-third semiannual report to Congress, manufacturing 

statement for weapons production schedule of transfers 1962-

64, shipping request to General Electric Company, and a United 

States nuclear weapons program summary.

08/01/2012 12
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - DOE Office of Scientific 

and Technical Information (OSTI)

Pulsed neutron generator for logging, analyses and hydrogenisotope-transport calculations of current and future designs of 

the rotating-target neutron source, applications of nuclear 

reaction analysis to metal hydride film characterizations, assay of 

heavy water in drums, conceptual site treatment plan for Pinellas 

Plant, contamination control training, evaluation of a laboratory 

neutron generator, electron focusing by an ion beam, 

environmental assessment for decontamination and 

dismantlement, install active/passive neutron examination and 

assay, ion sources for sealed neutron tubes, main radiological 

exhaust stack monitoring system evaluation project plan, 

milliwatt generator heat source progress reports, mobile site 

safety review for the transuranic (TRU) waste characterization 

program, neutron tube disassembly glovebox operational 

readiness check, operating characteristics of a developmental 

model portable neutron generator, portable tritium recovery 

system (TRS) - operational readiness check, quality program plan 

for environmental monitoring, radiological dose assessment of 

DOE Pinellas waste, radiological emergency actions manual, 

safety assessment/building 800 low-level waste repacking, semiannual report of the DOE Office of Environmental Restoration, 

thick target D-T neutron yield measurements using metal 

occludes, and a DOE Legacy Management site fact sheet.

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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - DOE OSTI Energy 

Citations

Annual report of waste generation and pollution prevention 

progress, application to ship defense low-level radioactive waste 

to the Nevada Test Site, chemical processing of Pu-238, internaldosimetry practices at DOE facilities, environmental restoration 

activities at the Pinellas Plant, impact statement and the baseline 

environmental management report, environmental monitoring 

plan, radiological stack flow report, radiological control manual, 

radionuclide air emissions annual report 1993, safety assessment 

for waste management environmental, safety and health, site 

dose assessment plan, and waste characterization summary 

form.

03/28/2013 47

Internet - DOE OSTI Information 

Bridge

Annual waste reduction activities report, environmental 

management progress, integrated database for spent fuel and 

radioactive waste inventories, neutron generator production 

mission in a national laboratory, report of the task group on 

operation of DOE tritium facilities, Savannah River Laboratory 

monthly reports, Pinellas Plant ion accelerator facility, DOE 

Legacy Management program update 2009, and workforce 

estimates for environmental restoration.

12/30/2012 50

Internet - DOE OSTI SciTech 

Connect

Report to Congress on long-term stewardship, annual report on 

waste generation and waste minimization progress 1991-1992, 

1995, planning process for mixed low-level waste disposal, 

summary of treatment, storage, and disposal facility usage data 

collected from DOE sites.

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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - Energy Employees 

Claimant Assistance Project 

(EECAP)

Environmental restoration program wastewater neutralization 

area corrective measures, Pinellas environmental restoration 

project interim remedial action plan, and a site environmental 

report for 2004.

03/30/2020 20

Internet - Environmental 

Protection Agency (NEPIS EPA)

USEPA's center for exposure assessment modelingmeteorological data -Florida, remediation case studies Volume 

13.

11/11/2013 2 

Internet - Google Report to Congress detailing DOE's existing and anticipated longterm stewardship obligations, review of the health and mortality

experience of DOE workers, effectiveness of personnel protective 

equipment against tritium, ALARA analysis of alternatives for 

disposal of hazardous wastes, acronym master list, annual report 

of waste generation and pollution prevention progress 1994, 

report on contractor work force restructuring, Building 100 area 

remediation technology screening report, controlling 

particulates, temperature, and tritium in an inert glovebox, DOE 

environmental management Pinellas Plant, human radiation 

experiments, Sternglass papers, nuclear weapons data book, 

operational accidents and radiation exposures 1975-1977, 

radiological impact caused by emissions of radionuclides into air, 

sitewide environmental monitoring quarterly progress reports 

2004- 2009, summary site environmental report radiological 

doses and releases 1990-1994, and a Legacy Management 

program update 2006.

11/03/2020 184

Internet - Health Physics Journal No relevant documents identified. 06/08/2020 0 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - Journal of Occupational 

and Environmental Hygiene

No relevant documents identified. 06/08/2020 0 

Internet - National Academies 

Press (NAP)

Nuclear weapons complex management for health, safety, and 

the environment best practices, improving management of 

persistent contaminants, and research opportunities for 

deactivating and decommissioning DOE facilities.

09/01/2010 4 

Internet - National Institute for 

Occupational Safety and Health 

(NIOSH)

Building 200 information, report on residual radioactive and 

beryllium contamination at atomic weapons employer facilities, 

Special Exposure Cohort (SEC) petition evaluation report, and 

notes on a Pinellas technical call with Landauer dosimetry expert.

11/06/2018 13

Internet - NRC Agencywide 

Document Access and 

Management (ADAMS) 

Environmental restoration wastes, evaluation of the potential for 

recycling of scrap metals from nuclear facilities, integrated 

database for 1991-92 spent fuel and radioactive waste 

inventories, and long-term surveillance and maintenance 

program reports 1998-2000.

09/28/2017 15

Internet - ORAU Medical testing for beryllium sensitivity or exposures available to 

former Pinellas Plant workers.

09/01/2010 1 

Internet - Sandia National 

Laboratory - New Mexico

Transfer of the neutron generator production mission to Sandia 

lessons learned.

04/01/2013 1 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Internet - US Army Corps of 

Engineers (USACE)

No relevant documents identified. 06/08/2020 0 

Internet - US Transuranium and 

Uranium Registries

No relevant documents identified. 06/08/2020 0 

Kansas City Plant Annual environmental summary reports 1973-1981, DOE followup review of 10CFR835 Radiation Protection Program, DOE 

Laboratory Accreditation Program (DOELAP) onsite assessment 

report, facilities radioisotopes data 1990, occupational radiation 

exposure 1958-1969, packing and transportation safety appraisal 

of the Pinellas Plant site, radioactive source surveys 1976-1977, 

radioactive waste documentation, and personnel neutron 

monitoring badges for the neutron generator tester area.

01/14/2016 18

Landauer Client (site) List No relevant documents identified. 01/27/2021 0 

Lawrence Livermore National 

Laboratory

Building 331 tritium facility upgrade relative to vacuum effluent 

recovery system.

02/26/2015 1 

Los Alamos National Laboratory Nonnuclear consolidation environmental assessment volume II, 

spent fuel and radioactive waste inventories, and projections and 

characteristics.

12/13/2007 2 

Mel Chew & Associates Recycled uranium project Fernald historical data shipments of 

depleted and normal uranium 1952-1999 spreadsheets.

12/14/2014 2 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Missouri Department of Natural 

Resources

Plutonium working group report on environmental, safety and 

health vulnerabilities associated with the department's 

plutonium storage.

10/01/2008 3 

Mound Museum Manufacturing statement for weapons production schedule of 

transfers 1964, quarterly health physics report through 1959, and 

Mound Laboratory classification guides 1966, 1969.

07/14/2008 5 

National Archives and Records 

Administration (NARA) - Atlanta

Environmental monitoring, in-plant surveys (1958-1967), 

personnel dose report, bioassay reports, area film monitor 

worksheets, CAP - 88 run 1997, directory of consultants to AEC 

contractors, dosimeter badge distribution, environmental 

monitoring procedures, monitored employees list, health physics 

guidelines for Kr-85 operations, health physics report, incident 

investigations, historical radionuclides and sources inventory, 

information on tritides, internal dose information, Landauer 

radiation dosimetry report, Pinellas plant radioactive waste 

management implementation plan, Pu heat source standards, Pu238Be neutron source information, radiation work permits, 

radioisotope thermoelectric generator (RTG) assemblies at 

Pinellas, special work permits and contamination survey reports, 

termination occupational exposure reports, tritium particulate air 

and smear sampling, urine sample submittal procedure for 

tritium analysis, and a waste management site plan.

08/12/2004 71

National Archives and Records 

Administration (NARA) - Kansas 

City

Facilities used by Atomic Energy Commission (AEC) between 

1942-1957.

11/10/2004 1 
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

National Institute for 

Occupational Safety and Health 

(NIOSH)

Annual report to Congress of the Atomic Energy Commission 

1965, 1970-71, Advisory Board meeting on issues of concern with 

Pinellas Plant data, Pinellas 1980 directory, environmental 

baseline report 1997, tritide study at the Responsive Neutron 

Generator Product Deployment Center, unusual occurrence 

report on 03 failure of an X-ray shield on E-beam welding, and 

worker outreach meeting notes.

08/25/2020 44

NIOSH OCAS Claims Tracking 

System (NOCTS)

Operation and Maintenance instructions electron beam welder 

and Pinellas Plant newsletter articles 1981-1987.

10/05/2010 2 

Nevada Test Site Final environmental impact statement for the Nevada Test Site 

and offsite locations in the state of Nevada volume 1.

10/01/2003 1 

Nuclear Regulatory Commission 

Public Document Room

Registry of radioactive sealed sources. 09/01/2011 1 

NV5/DMA Richland Office Personnel dosimetry performance criteria for testing. 09/22/2017 1 

ORAU Team Annual environmental intakes attributable to Pinellas Plant's 

onsite air concentrations, application of photofluorography, 

documented communications, eighth annual report of radiation 

exposures 1975, Landauer dosimetry information from the 

1970s, plant stack data spreadsheet, and unmonitored insoluble 

H-3 intakes spreadsheet.

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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Pantex Equipment analysis automation of pit staging vaults. 06/23/2011 1 

Personal files - [redacted] Biokinetics and dosimetry of titanium tritide particles in the lung, 

dissolution rates, and radiation dosimetry of metal tritides.

01/02/2008 3 

Personal files - [redacted] Seventeenth – twenty-first annual report radiation exposures for 

DOE and DOE contractor employees 1984-1988.

10/11/2006 5 

Personal files - [redacted] Department of Labor (DOL) response to a proposal to extend the 

covered employment for the Pinellas Plant to include 1956.

01/07/2021 1 

S. Cohen & Associates (SC&A) Documented communication on history of operations at SNLLivermore from 1956 to present, total inventory of all 

microfilmed records 1992, Pinellas Plant's waste management 

site plan, radioisotopic thermoelectric generator (RTG) shipping 

container, environmental survey preliminary summary report of 

the defense production facilities, and packing of low-level 

radioactive wastes.

05/24/2017 16

Sandia National Laboratory - 

Albuquerque, New Mexico

Revised radiological control manual implementation plans with 

comments, final radiological status reports for areas and 

buildings, health protection survey reports, Ross Aviation 

shipment surveys and shipping documents 1982, and incident of 

unsuspected contamination.

09/09/2014 31
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Savannah River Site Californium packaging facility general information and a 

compliance assessment of the Savannah River Site 1990.

02/07/2012 3 

Science Applications 

International Corp (SAIC)

Radiation exposure information 1963-1973 and summaries of 

whole body radiation exposures to external penetrating radiation 

accumulated during the year 1962 and 1964.

09/02/2004 9 

Southern Illinois University Department of Health and Human Services Centers for Disease 

Control National Institute for Occupational Safety and Health 

Advisory Board on Radiation and Worker Health 48th Meeting 

2007.

11/01/2008 1 

University of Colorado Norlin 

Library 

Study of cost and benefits of a formal safety program. 04/10/2006 1 

University of Rochester Nuclear materials management station code list. 08/20/2008 1 

Unknown Annual site environmental report Sandia National Laboratories 

Albuquerque, New Mexico 1999, environmental legacy of nuclear 

weapons production, decommissioning information, description 

of the exposure monitoring at Pinellas, DOE occupational 

radiation exposure report 1992-1995, epidemiologic use of nondetectable values in radiation exposure measurements, 

framework for DOE mixed low-level waste disposal, history of 

personnel external dosimetry program at the Dayton Project and 

Mound Laboratory 1946-1993, site history, fact sheet, and 

environmental data and surveys.

11/12/2004 25
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Data Capture 

Information Data Capture Description Date Completed 

No. 

Uploaded 

into SRDB

Unknown / SC&A Environmental assessment Pinellas Plant site, personnel security 

report monthly alpha listing and terminated list 1992, radiation 

hazards questionnaire, radiological monitoring personnel, 

environmental and workplace 1957-1971, and a Pinellas Plant 

overview. 

06/16/2004 8 

TOTAL N/A N/A 2,218
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Table A1-2: Database Searches for Pinellas Plant 

Database/Source

Database search terms and Internet URL are available in the Microsoft Excel file called

“Pinellas Plant Rev 00, (SEC-00256) 02-03-2021.”

No. of Hits

No. 

Uploaded 

into SRDB

Defense Technical Information Center (DTIC)

COMPLETED 06/08/2020

797 0 

DOE Hanford Declassified Document Retrieval System (DDRS) and Public Reading Room

COMPLETED 06/08/2020

0 0 

DOE Legacy Management Considered Sites

COMPLETED 06/08/2020

1,785 0 

DOE National Nuclear Security Administration (NNSA) - Nevada Site Office

COMPLETED 06/08/2020

76,937 0 

DOE Noncompliance Tracking System 

COMPLETED 10/21/2020

2 2 

DOE Occurrence Reporting Processing System 

COMPLETED 10/21/2020

250 50 

DOE OpenNet

COMPLETED 06/08/2020

46 0 

DOE OSTI.Gov

COMPLETED 06/08/2020

51,932 39

Energy Employees Claimant Assistance Project (EECAP)

COMPLETED 03/30/2020

105 22 
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Database/Source

Database search terms and Internet URL are available in the Microsoft Excel file called

“Pinellas Plant Rev 00, (SEC-00256) 02-03-2021.”

No. of Hits

No. 

Uploaded 

into SRDB

Google

COMPLETED 11/17/2020

20,455,117 32 

Health Physics Journal

COMPLETED 06/08/2020

212 0 

Journal of Occupational and Environmental Hygiene

COMPLETED 06/08/2020

0 0 

National Academies Press

COMPLETED 06/08/2020

61,631 1 

National Service Center for Environmental Publication (NSCEP)

COMPLETED 06/08/2020

2,713 0 

NRC ADAMS Reading Room

COMPLETED 06/08/2020

67 0 

United States Army Corps of Engineers (USACE)

COMPLETED 06/08/2020

0 0 

U.S. Transuranium & Uranium Registries

COMPLETED 06/08/2020

0 0 
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ATTACHMENT TWO: REVIEW OF PETITIONER-PROVIDED 

DOCUMENTATION 

This attachment itemizes the various parts of the petition submission for SEC-00256 

Pinellas Plant. It provides a concise summary of the NIOSH review of the submission and 

the supporting documentation that followed.

Table A2-1 below itemizes the content of the qualified, Form B petition (August 17, 2020 

version). The 83.13 petition submission initially followed the same naming convention as 

the SEC Form B until Section F relating to the bases for proposing an addition to the 

Special Exposure Cohort (SEC). “Part F: Basis for Proposing that Records and Information 

are Inadequate for Individual Dose Reconstruction” makes up the major part of the 

petition, excluding Appendix 1 (pp. 43–59) which includes 24-hour urine heavy metals 

test information and results. Appendix 2 (pp. 60–76) includes a copy of the report 

Historical Report of Radiation Protection at GEND. 

Table A2-1: Petition SEC-00256 (August 17, 2020 version) 

Petitiona Content PDF Page 

Number

Parts A-D: Petition representative information and energy employee 

information for both petitioners, as applicable. 

pp. 3–5

PART E: PROPOSED DEFINITION OF ENERGY EMPLOYEE CLASS COVERED BY 

PETITION – includes petitioner’s requested definition of class.

pp. 5–6

PART E: Subsection E.1 includes 9 alternate names for the Pinellas Plant. One 

of the names cited is the General Electric Temporary Plant, which is not a 

covered facility.

p. 6

PART E: Subsection E.2 includes 191 named locations at the facility with the 

caveat “All locations and areas of the facility including but not limited to:” 

pp. 6–11

Part E: Subsection E.3 includes a listing of job titles and/or duties of energy 

employees, including but not limited to 184 primary job titles with associated 

alternate titles.

pp. 11–20

Part E: Subsections E.4 and E.5 include employment dates relevant to the 

petition and the declaration that the petition is not based on one or more 

unmonitored, unrecorded or inadequately monitored or recorded exposure 

incidents. 

Note: PDF p. 20 starts the deviation from the 83.13 Form B labeling. Instead, 

the petition uses the following title: “PART F: BASIS FOR PROPOSING THAT 

RECORDS AND INFORMATION ARE INADEQUATE FOR INDIVIDUAL DOSE 

RECONSTRUCTION” which includes sub-parts F.1 through F.3, F.8, and F.4 in 

that order.

p. 20
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Petitiona Content PDF Page 

Number

Part F: Subsection F.1 “Historic Approach to Monitoring of Radiological 

Exposures at the Pinellas Plant” introduces Exhibit 1: Radioactive Material 

Inventory at the Pinellas Plant [HRS 1994, PDF p. 34] and the Pinellas Plant 

Feasibility Study: Final Report [HRS 1994]. The subsection also lists 

radionuclides mentioned in ORAU Team documents relevant to worker doses. 

These include tritium, plutonium, depleted uranium, natural uranium, nickel63, carbon-14, and krypton-85. Text in this subsection states that the Plant 

never monitored the majority of workers for any possible exposure to the 

listed radionuclides.

pp. 20–21

Part F: Subsection F.2: “Incomplete Radiological Characterization at the 

Pinellas Plant and Need for Special Exposure Cohort” includes three subheadlines. 

Sub-headline “Exposures Not Monitored or Inadequately Monitored” lists 

sources of information believed to contain radiological incident information, a 

lack of monitoring for associated exposures, and sampling deficiencies. It 

includes 11 numbered points and discussion of the DOE Tiger Team 

Assessment of the Pinellas Plant [DOE 1990a], the report Health Physics 

Report: Historical Report of Radiation Protection [Historical report of radiation, 

no date], and the Department of Labor Site Exposure Matrices [DOL, no date]. 

Sub-headline “Characterization of Former Nuclear Weapons Workers at 

Pinellas Plant” summarizes a review of workers’ files and notes that workers 

often worked in multiple locations and performed multiple roles for which 

monitoring was often inconsistent and erratic. It includes 5 numbered points 

and discussion of the Pinellas Plant Environmental Baseline Report June 1997

[Martin Marietta 1997b], Independent Technical Review of the Pinellas Plant

[DOE 1994b], and the Pinellas Plant Feasibility Study: Final Report [HRS 1994]. 

Sub-headline “24 Hour Heavy Metals Urine Tests” summarizes heavy-metal 

urine tests performed and includes 3 numbered points and mentions the 

previously discussed reports.

pp. 21–26

Part F: Subsection F.3: “Presence of Radioactive Materials at the Pinellas Plant” 

includes the sub-headlines “Strontium-90” (with 7 numbered points), “Cobalt60” (with 4 numbered points), “Thallium” (with 2 numbered points), 

“Uranium” (with 3 numbered points), and “Beryllium” (with 3 numbered 

points). Each sub-headline focuses on presenting evidence of the specified 

source terms.

pp. 26–30

Part F. Subsection F.8: “Conclusion” summarizes the petitioners’ bases for 

their position that U.S. Department of Labor, DOE, and ORAU have incomplete 

Pinellas Plant radiological characterizations and that previous worker 

exposures to strontium-90, cobalt-60, thallium-204, beryllium, and uranium 

are probable.

pp. 30–31
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Petitiona Content PDF Page 

Number

Part F. Subsection F.4: “Bibliographic of Scientific or Technical Reports” 

includes a discussion of five reports and provides material (titled as exhibits) 

that reflects possible intent to support the standard EEOICPA F.3 basis goals 

and requirements, although the introductory text paraphrases the 83.13 Form 

B, F.4 basis goals and requirements. Summaries of the following five 

documents and their applicability to monitoring deficiencies are provided:

1. Dosimetry is Key to Good Epidemiology: Workers at Mallinckrodt Chemical 

Works had Seven Different Source Exposures [Ellis et al. 2018]

2. Review of the Department of Labor’s Site Exposure Matrix Database

[Institute of Medicine 2013] 

3. Tiger Team Assessment of the Pinellas Plant [DOE 1990a]

4. The NIOSH Radiation Dose Reconstruction Program: Managing Technical 

Challenges [Moeller et al. 2008]

5. Scientific Issues in Radiation Dose Reconstruction [Toohey 2008]

pp. 31–36

5 exhibits:

1. Exhibit 1 (PDF p. 37): a one-page excerpt of the Pinellas Plant Feasibility 

Study Final Report [HRS 1994, PDF pp. 34–36] from section 3, Radioactive 

Material Inventory at the Pinellas Plant, listing 28 radioactive materials 

used in the plant

2. Exhibit 2 (PDF p. 38): a table labeled “Pinellas Plant Radioactive Source 

Historical Inventory/Status” from the Pinellas Plant Feasibility Study Final 

Report [HRS 1994, PDF p. 122] presenting the activity and dates of four 

strontium-90 check sources 

3. Exhibit 3 (PDF pp. 39–40): tables labeled “Pinellas County Water Sources 

Radioactivity Measurements” from the Pinellas Plant Feasibility Study Final 

Report [HRS 1994, PDF pp. 173–174] presenting various sampling results 

from five Pinellas County sampling locations for total alpha, beta, radium, 

radon, tritium, and strontium collected between April 1976 and July 1993 

4. Exhibit 4 (PDF p. 41): a table labeled “Space Isotopic Power Systems” from 

an article of the same name [Carpenter 1963, PDF p. 4 ] summarizing the 

designation, use, power output, weight, size, isotopic fuel, design life, and 

operational dates, ranging from 1959–1966, of SNAP, thermionic, and 

thermoelectric power systems

5. Exhibit 5 (PDF p. 42): a single-page excerpted table labeled “Properties of 

Isotopes Useful for Isotopic Power Generation” listing emissions, half-lives, 

specific power, and melting points for 28 isotopes useful for power 

generation from a document called Radioisotopes Power Production

[Ragheb 2011, PDF pp. 7–8] 

pp. 37–42
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Petitiona Content PDF Page 

Number

Appendix 1: “24-Hour Urine Heavy Metals Tests” includes heavy-metals urine 

test results (beryllium, cobalt, thallium, and uranium) for eight EEOICPA 

claimants

pp. 43–59

Appendix 2 consists of a copy of the report “Historical Report of Radiation 

Protection at GEND” [Historical report of radiation, no date]

pp. 60–76

a. Source: [[redacted] 2020b]

Following the qualification of the petition, the petitioners provided NIOSH with the 

documents listed in Table A2-2 below as support of the petition. NIOSH reviewed and 

assessed all of the documents for information related to the evaluation of dose 

reconstruction feasibility for the class of workers included in the SEC-00256 petition.

In addition, the petitioners made NIOSH aware of additional documents by email 

correspondence, providing limited bibliographic information for each. NIOSH attempted 

to locate these documents as well and was able to access those listed in the table below. 

NIOSH reviewed each of the additional documents for information pertinent to dose 

reconstruction feasibility. None of the reviewed documents indicated difficulties that 

could hinder or impede dose reconstruction to the class of workers, and none of the 

documents pertained to radiological exposures, lack of dosimetry information, or any 

other condition that would negatively impact dose reconstruction for the class of workers 

under evaluation.

Table A2-2: Supporting Documents for SEC-00256 Provided Post-Qualification 

Document Description SRDB Ref ID

NDD Product Descriptions April 1980/NDD Products 198004xx.pdf. A onepage table of various neutron generators, assemblies, lightning arrester 

connectors, capacitors, thermal batteries, neutron detectors, and other 

products. A useful reference document. Dated April 1980.

187249

NDD Product Descriptions October 31, 1990/NDD Products 19901031.pdf. A 

single-page table including various neutron generators, assemblies, lightning 

arrester connectors, capacitors, power sources, neutron detectors, quartz 

devices, and other products. The table also lists units in later stages of preproduction development. A useful reference document.

187358

NDD Generator Production/NDD Units 19860902.pdf. A quality assurance 

flow chart for the neutron generator components involved in certain 

products. Dated 9/2/1986.

187359

MC Unit-Timer-TTA Matrix Electronic Units/NDD Units Electronic 

19680801.pdf 

187360
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Document Description SRDB Ref ID

Epidemiologic Study of Pinellas Plant Employees. A memo from Energy 

Programs Division of DOE to the president of ORAU announcing the request 

for an epidemiologic study among present and former Pinellas Plant 

workers, and asking for ORAU staff to participate in an introductory on-site 

meeting with representatives of the Plant to develop the action plan and 

initiate the study. The memo date is 10/5/1990.

187490

Epidemiologic Study of Pinellas Plant Employees: Implementation. A memo 

initiating interactions with the Pinellas Area Operations Office and Pinellas 

Plant personnel to begin outlining the scope of an epidemiologic study of 

Pinellas Plant employees, identify working contacts and develop an action 

plan. The memo date is 9/12/1990.

187536

DOE Notification of ORAU Epidemiologic Study of Pinellas Plant Employees. A 

letter from DOE headquarters in Washington DC to the DOE Pinellas Area 

Office announcing that ORAU will conduct an epidemiologic study of present 

and former Pinellas Plant workers. The letter specifies ORAU responsibilities 

and the cooperation required from Pinellas staff to accomplish the study. 

The letter date is 9/5/1990.

187537

DOL Notice of Final Decision on Employment Dates. This DOL document is 

the decision of the Final Adjudication Branch concerning a claim for benefits. 

187688

GE Headliner Newsletter The Last of the Best...From Tubes & Generators to 

Heather & Capacitors...Employees Come Through. The first page of the 

Martin Marietta Specialty Components newsletter Vol. 3, No. 38 dated 

September 23, 1994. The article reports on neutron generator production 

ending, and provides some history of the temporary plant. The final Heather 

cap assemblies welding operation was also mentioned.

187361

GE memo re: specifics of classified associations between the Heather 

program and Building 300 production. A one-page memo announcing a 

meeting on October 30, 1968, to discuss classification concerns. The memo 

date is October 24, 1968. 

187689

Case Control Study of Multiple Myeloma Among Workers Exposed to 

Ionizing Radiation and Other Physical and Chemical Agents – Final. The Final 

Technical report by the School of Public Health at UNC-Chapel Hill on a study 

of multiple myeloma among workers at DOE nuclear facilities to evaluate 

occupation exposures to ionizing radiation and other biological, physical, and 

chemical hazards as risk factors for multiple myeloma. The Pinellas Plant 

cohort of workers was not included in this study because there was no 

evidence of significant external radiation exposures at the plant. The 

populations included in the study had the potential for external radiation 

exposure.

187538
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Document Description SRDB Ref ID

Examples of Types of Accidents or Occupationally-Related Disease That Have 

Resulted or Could Result in a Workmen’s Compensation Claim or Civil Suit. A 

memo from DOE headquarters regarding examples of types of cases to be 

listed in information storehouse, that would be maintained and followed by 

this office, identifying employees involved in accidents or occupationallyrelated disease while in the employment of a contractor, of such degree or 

with results of such experience that has or could sometime in the future 

result in a workmen's compensation claim or civil suit and includes examples 

of cases for input.

187539

“Resume of Radi-flo Leak Detection” A report discussing the parameters and 

procedures for use of the Radiflo system to detecting leaks in completed 

product tubes and to guarantee that tubes do not exceed a prescribed 

maximum leak rate. Also describes a two-week course delivered by the 

vendor on the theory, application, operation, and maintenance of the 

equipment. The report lists the names of personnel who completed the 

course.

108394

Health Protection Survey Reports/Memo to H A Nowak, Subject: Revision of 

Trip Report - Industrial Health Survey of Pinellas Area Plant (ATT: Trip Report 

Re Same). A report on an industrial health survey of industrial medicine, 

industrial hygiene, radiological safety, waste disposal, and food-handling 

sanitation at the Pinellas Plant conducted in 1963. The discussion of 

radioactive waste disposal includes a listing of tritium gas and oxide releases 

through the 100’ stack from March 1962 through December 1962. The 

report discusses solid and liquid wastes, personnel exposures including the 

number of employees monitored during the month, and contamination 

control. The report mentions daily, composite urine-sample collection in 

addition to routine individual urine samples. It announces the installation of 

a new “Radiflo” unit, with a 500 Ci Kr-85 reservoir. The report provides a 

calculated estimate of 0.5 Ci for release to the stack per cycle.

86965 PDF pp. 

17–24

Unusual Occurrence Report NDD-88-03 Failure of an X-ray Shield on E-Beam 

Welding Unit Area 331 – Final Report. An unusual occurrence report 

concerning a failure of an X-ray shield on an E-beam welding unit in Area 

331. The Pinellas Plant did not support the lead glass shielding in the 

window-opening in the door of the welder in a fail-safe manner. Health 

Physics personnel performed surveys and calculations to define the scope of 

the X-ray field present during operation, and estimates of exposures 

received for personnel involved using interview responses to determine time 

and distance estimates.

105284

Memo to H A Nowak, Subject: Radiological Fallout Monitoring Station at the 

Pinellas Plant. A memo regarding adding a fallout station to the nationwide 

network of stations. The memo gives requirements for the proposed station 

and provides reporting conditions. “Information is desired on general 

atmospheric radiation fallout due to atomic weapons testing, etc., not on 

local plant operation.”

In process
SEC-00256 10-13-2021 Pinellas Plant

129 of 130

Document Description SRDB Ref ID

Press Release, Subject: Pinellas Area Office to be Opened 2/3/58 (Press 

Queries)-indicates H. Nowak as Manager. A press release documenting the 

opening of a new Area Office at the Pinellas Plant, known as the Pinellas 

Area Office. The press release reports the appointment of Henry A. Nowak as 

Manager. The office was responsible to the Albuquerque Operations Office 

for the GE contract administration.

In process

Press Release, Subject: Bulcock and Scoville Transfer to ALO and Eagle 

Transfers from Rocky Flats to Pinellas. A press release documenting two AEC 

employees transferring to the Albuquerque Operations Office and one 

employee transferred to Pinellas Area Office as a Program engineer.

In process

Pinellas Quality Assurance Inspection Agency (Quality Report)-reporting 

acceptance numbers on materials per specifications by material and lot 

identifier. A report including a general summary, quality rating for contractor 

performance, compilation of verification inspection, description of audit and 

survey activity, and items of general interest.

In process

Memo to File, Subject: AEC 177/6 - Payments in Lieu of Taxes to Pinellas 

County, Florida-notes of a meeting on 3/22/61 related to burdens and 

benefits to the county resulting from the Plant.

In process

Memo to James Scammahorn, Acting Director, Subject: AEC 127/21 -

Extension of Incentive Arrangement- GE-Pinellas. A memo relaying notes 

related to payments and contract negotiations.

In process

Memo to File, Subject: AEC 127/22 - Transfer of Work from GE X-ray 

Department at Milwaukee to Pinellas Plant. Notes of an AEC meeting 

approving the General Managers recommendation to transfer the neutron 

generator development support work from Milwaukee to Pinellas Plant.

In process

Memo to A N Kenly, Subject: Re Heather Program (AS100070). A memo 

announcing a meeting to discuss the classified association between 

programs.

In process

Heather Project Documentation (U) Supplement to the Heather Project 

Executive Summary (AS11133009) (Partial). Only the document cover pages 

were accessible.

In process

Helix Adjust History (AS68048). This file includes hand-written notes, charts,

and work order profile reports compiled to evaluate the defect and yield 

history of the Helix Adjust Line to determine process stability.

In process

IP Schedule Transmittal/Approval GEND Shipment to ABA/BKCD (AS163332). 

The transmittal paperwork related to a transformer, CV toroid to be 

returned to GEND on a proposed alternative schedule. ABA/BKCD is Allied 

Bendix Aerospace Bendix Kansas City Division.

In process
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130 of 130

Document Description SRDB Ref ID

Memo to G W Torrance, et al, Subject: Request for Pump Needed for Helix 

Proof Test (AS20995). A memo from GE to Q.C. Equipment & Facilities 

Planning with justification and the request to obtain reliable pump 

equipment for use with the Helix Proof Test Station.

In process