SEC Petition Evaluation Report
 

Petition SEC-00068 

Report Rev #:_ 0_ Report Submittal Date: August 5, 2008_ 

Subject Expert(s): Jack Fix, Melton Chew 

Site Expert(s): Don Bihl, Eva Hickey, Jerome Martin 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Qualification Date 

DOE/AWE Facility Name 

SEC-00068 83.13 November 20, 2007 Pantex Plant 

Petitioner Class Definition 

All employees who worked in all facilities at the Pantex Plant in Amarillo, Texas, from January 1, 1951 

through December 31, 1991. 

Class Evaluated by NIOSH 

All employees who worked in any facility/location at the Pantex Plant in Amarillo, Texas, from January 1, 

1951 through December 31, 1991. 

NIOSH-Proposed Class(es) to be Added to the SEC 

None 

Related Petition Summary Information 

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

None NA NA NA 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

None NA 

ORAU Lead Technical Evaluator: Tim Adler ORAU Review Completed By: Daniel H. Stempfley 

Peer Review Completed By: [Signature on file] 

Mark R. Rolfes 

08/07/2008 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

08/08/2008 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

08/08/2008 

Date 

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Evaluation Report Summary: SEC-00068, Pantex Plant 

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

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

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

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

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

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition 

Petition SEC-00068, qualified on November 20, 2007, requested that NIOSH consider the following 

class: All employees who worked in all facilities at the Pantex Plant in Amarillo, Texas, from January 

1, 1951 through December 31, 1991. 

Class Evaluated by NIOSH 

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

the following class: All employees who worked in any facility/location at the Pantex Plant in 

Amarillo, Texas, from January 1, 1951 through December 31, 1991. 

NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained numerous documents 

containing monitoring results, as well as Pantex process and source information. Pantex has provided 

monitoring data summaries from its employee exposure records databases, and current and retired site 

personnel have been interviewed. Employee-specific information provided through the EEOICPA 

claims process and Technical Basis Documents written by NIOSH have also been available for this 

evaluation. Based on its analysis of these available resources, NIOSH found no part of the class under 

evaluation for which it cannot estimate radiation doses with sufficient accuracy. 

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: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred in plausible circumstances by any member of 

the class; or (2) estimate radiation doses of members of the class more precisely than an estimate of 

maximum dose. Information available from the site profile and additional resources is sufficient to 

document or estimate the maximum internal and external potential exposure to members of the 

proposed class under plausible circumstances during the specified period. 

Health Endangerment Determination 

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

because NIOSH has determined that it has sufficient information to estimate dose for the members of 

the proposed class. 

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Table of Contents 

Evaluation Report Summary: SEC-00068, Pantex Plant ........................................................................ 3
 

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

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

3.0 SEC-00068, Pantex Plant Class Definitions................................................................................. 10 

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 10 

3.2 Class Evaluated by NIOSH ................................................................................................. 11
 

3.3 NIOSH-Proposed Class to be Added to the SEC ................................................................ 11
 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 11 

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

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

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

4.4 Previous Dose Reconstructions ........................................................................................... 14 

4.5 NIOSH Site Research Database .......................................................................................... 15 

4.6 Other Technical Sources...................................................................................................... 15 

4.7 Documentation and/or Affidavits Provided by Petitioners ................................................. 15
 

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 16 

5.1 Pantex Plant Process Descriptions and Facilities ................................................................ 16 

5.1.1 Pantex Plant Process Descriptions........................................................................... 16 

5.1.2 Pantex Plant Facilities ............................................................................................. 19 

5.2 Radiological Exposure Sources from Pantex Plant Operations .......................................... 22 

5.2.1 Internal Radiological Exposure Sources from Pantex Plant Operations ................. 22 

5.2.1.1 Uranium.................................................................................................... 22 

5.2.1.2 Tritium...................................................................................................... 23 

5.2.1.3 Plutonium ................................................................................................. 23 

5.2.1.4 Thorium .................................................................................................... 23 

5.2.1.5 Radon........................................................................................................ 24 

5.2.2 External Radiological Exposure Sources from Pantex Plant Operations ................ 24 

5.2.2.1 Photon....................................................................................................... 25 

5.2.2.2 Beta........................................................................................................... 25 

5.2.2.3 Neutron ..................................................................................................... 26 

5.2.3 Incidents .................................................................................................................. 26
 

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 27 

6.1 Available Pantex Plant Internal Monitoring Data ............................................................... 28 

6.2 Available Pantex Plant External Monitoring Data .............................................................. 31
 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 32 

7.1 Pedigree of Pantex Plant Data ............................................................................................. 33 

7.1.1 Internal Monitoring Data Pedigree Review............................................................. 35 

7.1.2 External Monitoring Data Pedigree Review............................................................ 36 

7.2 Evaluation of Bounding Internal Radiation Doses at the Pantex Plant ............................... 36 

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7.2.1 Evaluation of Bounding Operational Internal Monitoring Data.............................. 38 

7.2.1.1 Urinalysis Information and Available Data.............................................. 38 

7.2.1.2 Airborne Levels ........................................................................................ 40 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses........................... 41 

7.2.3 Methods for Bounding Internal Dose at the Pantex Plant ....................................... 41 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 45 

7.3 Evaluation of Bounding External Radiation Doses at the Pantex Plant .............................. 46 

7.3.1 Evaluation of Bounding Operational External Monitoring Data ............................ 46 

7.3.1.1 Personnel Dosimetry Data ........................................................................ 46 

7.3.1.2 Area Monitoring Data............................................................................... 48 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses.......................... 48 

7.3.3 Pantex Plant Occupational X-Ray Examinations .................................................... 48 

7.3.4 Methods for Bounding External Dose at the Pantex Plant ...................................... 49 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 50 

7.4 Evaluation of Petition Basis for SEC-00068 ....................................................................... 51 

7.4.1 Unmonitored Workers ............................................................................................. 51 

7.4.2 Effectiveness of the Health Protection and Industrial Health Programs ................. 51 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 52 

7.6 Summary of Feasibility Findings for Petition SEC-00068.................................................. 52
 

8.0 Evaluation of Health Endangerment for Petition SEC-00068...................................................... 53
 

9.0 NIOSH-Proposed Class for Petition SEC-00068 ......................................................................... 53
 

10.0 References .................................................................................................................................... 55
 

Attachment One—SRDB Data for Bounding Internal Doses ............................................................... 65 

Tables 

Table 4-1: No. of Pantex Plant Claims Submitted Under the Dose Reconstruction Rule..................... 14
 

Table 5-1: Pantex Plant Photon-Emitting Radionuclides ..................................................................... 25 

Table 5-2: Pantex Plant Beta-Emitting Radionuclides .......................................................................... 26
 

Table 6-1: Pantex Employee Monitoring Doses Recorded in the HERS and DoRMS Databases........ 29 

Table 6-2: Annual No. of Monitored Pantex Employees ...................................................................... 31
 

Table 7-1: Pantex Job Titles and Job Descriptions with the Possibility for Occupational Intake......... 37 

Table 7-2: Pantex Plant Worker X-ray Examinations ........................................................................... 48 

Table 7-3: Summary of Feasibility Findings for SEC-00068 ............................................................... 52 

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Figures 

Figure 5-1: Nuclear Weapon Assembly Process ................................................................................... 18 

Figure 5-2: Weapons Dismantlement and Pit Storage .......................................................................... 18 

Figure 5-3: Generic Representation of a Nuclear Explosive Bay ......................................................... 19 

Figure 5-4: Generic Representation of a Nuclear Explosive Cell ......................................................... 20 

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SEC Petition Evaluation Report for SEC-00068
 

1.0 Purpose and Scope 

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

facility/location at the Pantex Plant in Amarillo, Texas, from January 1, 1951 through December 31, 

1991. It provides information and analyses germane to considering a petition for adding a class of 

employees to the congressionally-created SEC. 

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

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

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

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

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

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

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

2.0 Introduction 

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

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

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

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

reconstructions.1 

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

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

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

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

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

estimate of the maximum radiation dose. 

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

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

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

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

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

not been established, then NIOSH is required to specify that health was endangered for those workers 

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

1

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

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

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

(excluding aggregate work day requirements). 

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

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

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

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

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

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

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

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

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

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

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

3.0 SEC-00068, Pantex Plant Class Definitions 

When a petition is submitted by a claimant, the requested class definition is evaluated as submitted. If 

the available site information and data justify a change in the petitioner’s class definition, NIOSH will 

specify a modified class to be fully evaluated. After a complete analysis, NIOSH will determine 

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

following subsections address the development of the class definition for SEC-00068, Pantex Plant. 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00068, which qualified on November 20, 2007, requested that NIOSH consider the 

following class for addition to the SEC: All employees who worked in all facilities at the Pantex Plant 

in Amarillo, Texas, from January 1, 1951 through December 31, 1991. 

The petitioners provided information and affidavit statements in support of their belief that accurate 

dose reconstruction over time is impossible for the Pantex Plant workers in question. During the 

qualification process for SEC-00068, the petitioners made several claims using multiple petition 

bases. At the conclusion of the process, the petitioners proposed a Pantex SEC designation on the 

basis that radiation exposures and radiation doses were not monitored, either through personal or area 

monitoring (F1 basis). NIOSH believes that the following statement provided by the petitioners best 

summarizes their final claims: 

The argument we have made is that there are inadequate individual radiation exposure 

monitoring data from which to perform accurate, valid, and timely dose reconstructions for 

members of the group. There are no data from Pantex for the majority of the workforce 

before 1979 and real questions [remain] regarding the efficacy of the Health Physics (HP) 

Program and Industrial Hygiene (IH) Program at this site, as reflected by workers’ 

histories and the Tiger Team report. 

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

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

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Because radiation exposure and area monitoring data applicable to members of the proposed class are 

available, NIOSH determined that the petitioner provided inadequate support to qualify the petition 

for additional evaluation. Furthermore, NIOSH determined that the documentation provided by the 

petitioners did not provide adequate support for their F1 basis, and in some cases the documentation 

was not provided in the required affidavit format. 

Following NIOSH’s determination, the petitioners requested an administrative review of NIOSH’s 

proposed finding to deny qualification of the petition. The Administrative Review panel decided that 

the petitioners had provided sufficient information to raise some doubts regarding the adequacy of the 

monitoring data at Pantex; therefore, the review panel recommended that the petition qualify for a full 

evaluation. 

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH accepted the petitioner-proposed class with a slight 

modification of the petitioner-requested definition (i.e., “worked in all facilities” was changed to 

“worked in any facility/location”). Therefore, NIOSH defined the following class for further 

evaluation: All employees who worked in any facility/location at the Pantex Plant in Amarillo, Texas, 

from January 1, 1951 through December 31, 1991. 

3.3 NIOSH-Proposed Class to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained numerous documents 

containing monitoring results, as well as Pantex process and source information. Pantex has provided 

monitoring data summaries from its employee exposure records databases, and current and retired site 

personnel have been interviewed. Employee-specific information provided through the EEOICPA 

claims process and Technical Basis Documents written by NIOSH have also been available for this 

evaluation. Based on its analysis of these available resources, NIOSH found no part of the class under 

evaluation for which it cannot estimate radiation doses with sufficient accuracy. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

NIOSH identified and reviewed numerous data sources to locate 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 Technical Basis Documents (TBDs) 

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

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

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

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

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

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

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radiological operations at the site. As part of NIOSH’s evaluation detailed herein, it examined the 

following TBDs for insights into Pantex Plant operations or related topics/operations at other sites: 

•	 TBD for the Pantex Plant – Introduction, ORAUT-TKBS-0013-1; Rev. 02; May 11, 2007; SRDB 

Ref ID: 20152 

•	 TBD for the Pantex Plant – Site Description, ORAUT-TKBS-0013-2; Rev. 02; May 8, 2007; 

SRDB Ref ID: 20153 

•	 TBD for the Pantex Plant – Occupational Medical Dose, ORAUT-TKBS-0013-3; Rev. 02; 

February 1, 2007; SRDB Ref ID: 20154 

•	 TBD for the Pantex Plant – Occupational Environmental Dose, ORAUT-TKBS-0013-4; Rev. 01; 

June 22, 2007; SRDB Ref ID: 20155 

•	 TBD for the Pantex Plant – Occupational Internal Dose, ORAUT-TKBS-0013-5; Rev. 01; June 

22, 2007; SRDB Ref ID: 26727 

•	 TBD for the Pantex Plant – Occupational External Dose, ORAUT-TKBS-0013-6; Rev. 01; June 

22, 2007 SRDB Ref ID: 11068 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

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

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

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

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

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

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

•	 OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, ORAUTOTIB-0006, Rev. 03 PC-1; December 21, 2005; SRDB Ref ID: 20220 

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

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

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

•	 OTIB: Analysis of Coworker Bioassay Data for Internal Dose Assignment, ORAUT-OTIB-0019, 

Rev. 00; December 29, 2004; SRDB Ref ID: 19439 

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

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

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

ID: 29984 

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

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

•	 PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, Rev. 02; 

January 2, 2008; SRDB Ref ID: 39338 

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed former Pantex employees and reviewed the 

documentation associated with interviews performed as part of the ORAU Site Profile development. 

Interviewee selection was based on individual availability and the potential knowledge of Pantex 

working conditions during the period of the proposed class. For the current SEC interviews, NIOSH 

developed and refined interview questions based on interviewees’ job titles and work experiences. 

Information obtained during these interviews contributed to NIOSH’s general knowledge of Pantex 

Plant conditions and monitoring practices. 

•	 Personal Communication, April 7, 2008, Personal Communication with [Name Seven Redacted], 

communication with a former Pantex Weapons Engineer; April 7, 2008; SRDB Ref ID: 45919 

•	 Personal Communication, October 1, 2003, Personal Communication with [Name Eight Redacted], 

communication with a member of the Pantex Radiation Safety Department; October 1, 2003; 

SRDB Ref ID: 11077 

•	 Personal Communication, September 24, 2003a, Personal Communication with [Name Nine 

Redacted], communication with Pantex Training Manager; September 24, 2003; SRDB Ref ID: 

11078 

•	 Personal Communication, June 29, 2003, Personal Communication with [Name Four Redacted], 

communication with Pantex Safety Engineer; June 29, 2003; SRDB Ref ID: 11079 

•	 Personal Communication, October 8, 2003, Personal Communication with [Name Five Redacted], 

communication with former Pantex Radiation Safety Manager; October 8, 2003; SRDB Ref ID: 

11081 

•	 Personal Communication, September 24, 2003b, Personal Communication with [Name Six 

Redacted], communication with retired Pantex Training Manager; September 24, 2003; SRDB Ref 

ID: 11083 

•	 Personal Communication, September 23, 2003, Personal Communication with [Name Ten 

Redacted], communication with former Pantex employee; September 23, 2003; SRDB Ref ID: 

11084 

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•	 Personal Communication, June 20, 2003 & May 27, 2004, Personal Communication with [Name 

Four Redacted]; communication with Pantex Safety Engineer; June 20, 2003 and May 27, 2004; 

SRDB Ref ID: 14542 

•	 Personal Communication, June 16, 2004, Personal Communication with [Name Four Redacted]; 

communication with Pantex Safety Engineer; June 16, 2004; SRDB Ref ID: 13467 

•	 Personal Communication, October 11, 2006, Personal Communication with [Name Eleven 

Redacted]; communication with Pantex Safety Engineer; October 11, 2006; SRDB Ref ID: 27015 

•	 Personal Communication, April 8, 2008, Personal Communication with [Name Five Redacted]; 

communication with site expert; April 8, 2008; SRDB Ref ID: 46110 

In addition to the personal communications listed above, two additional interviews were conducted. 

However, notes from these interviews have not been returned from the Pantex site. Additionally, 

Computer-Assisted Telephone Interviews (CATI) conducted with Pantex claimants provided more 

detailed information as noted in Section 4.4 below. 

4.4 Previous Dose Reconstructions 

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

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

summarizes the results of this review. (NOCTS data available as of August 1, 2008) 

Table 4-1: No. of Pantex Plant Claims Submitted Under the Dose Reconstruction Rule 

Description Totals 

Total number of claims submitted for dose reconstruction 380 

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

under evaluation (January 1, 1951 through December 31, 1991) 357 

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

the class under evaluation1 244 

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

evaluated class definition 157 

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

evaluated class definition 240 

Notes: 

1

 Number reflects the number of claims completed by NIOSH and submitted to the Department of Labor (DOL) for final
 

approval.
 

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

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

obtain monitoring data for many of the claims that meet the proposed class definition. Of the total 

number of claims submitted for energy employees that meet the worker class definition being 

evaluated in this report, 157 (44%) contain internal monitoring data and 240 (67%) contain external 

monitoring data. 

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The CATI conducted with Pantex claimants provided additional detailed information regarding work 

locations, hours worked, incidents, and hazards encountered. The CATI also identified conditions for 

which there would have been potential for either internal or external exposures. 

4.5 NIOSH Site Research Database 

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

evaluation of the proposed class. Five hundred ninety-six documents in this database were identified 

as pertaining to Pantex. These documents were evaluated for their relevance to this petition. The 

documents include historical background on external and internal dosimetry programs and 

evaluations, monitoring summary reports, annual environmental reports, reviews and assessments of 

the Pantex Plant, evaluations of specific buildings, site surveys, and facility and process descriptions. 

4.6 Other Technical Sources 

In addition to its own SRDB, NIOSH also examined data contained within the following repositories: 

•	 Historical Exposure Records System (HERS), located at the Pantex Plant (now incorporated into 

the Dosimetry Records Management System) 

•	 Dosimetry Records Management System (DoRMS), located at the Pantex Plant 

•	 Optix® Imaging System (a document imaging storage system), located at the Pantex Plant 

4.7 Documentation and/or Affidavits Provided by Petitioners 

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

petitioners: 

•	 Petition Form B; [Name One, Name Two, and Name Three Redacted]; September 6, 2006; OSA 

Ref ID: 100557 

•	 Letter of Transmission for SEC Petition; [Name One Redacted]; September 6, 2006; OSA Ref ID: 

101753 

•	 Table 6.1-1 History of External Radiation Exposures at the Pantex Plant, extracted from an 

October 1998 Safety Information Document; OSA Ref ID: 100559, pp. 1-4 

•	 Table 6.1-2 History of Internal Radiation Exposures at the Pantex Plant, extracted from an 

October 1998 Safety Information Document; OSA Ref ID: 100559, pp. 4-5 

•	 Table 6.1-3 Percent of Total Doses Attributed to Neutron Radiation, extracted from an October 

1998 Safety Information Document; OSA Ref ID: 100559, p. 6 

•	 Three Pantex Incident Descriptions, extracted from an October 1998 Pantex Safety Information 

Document; OSA Ref ID: 100559, pp. 8-10 

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•	 Abstract from Mortality Update for the Pantex Weapons Facility: Final Report Health-Related 

Energy Research Branch, a 1990 NIOSH epidemiologic study; OSA Ref ID: 100559, pp. 11-12 

•	 Various excerpts from the 1990 Tiger Team Assessment of the Pantex Plant Amarillo, Texas, 

DE000634; OSA Ref ID: 100559, pp. 12-19 

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize both radiological operations at the Pantex Plant from January 

1951 through December 1991 and the radiological exposure source information available to NIOSH 

that characterizes 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. The information included within this evaluation report is intended only to be a summary of 

the available information. 

5.1 Pantex Plant Process Descriptions and Facilities 

Located approximately 17 miles northeast of Amarillo, Texas (in the Texas panhandle), the Pantex 

Plant played an important role in the U.S. Nuclear Weapons program. Operations included fabricating 

high explosives and assembling and disassembling nuclear weapons. 

5.1.1 Pantex Plant Process Descriptions 

ATTRIBUTION: Section 5.1.1 was completed by Jerome Martin, Dade Moeller and Associates. These 

conclusions were peer-reviewed by the individuals listed on the cover page. The rationales for all 

conclusions in this document are explained in the associated text. 

The Pantex Plant, one of the last plants built by the United States to support the war effort during the 

World War II era, was built to load, assemble, and pack ordnance. The original WWII-era work at 

Pantex was all non-nuclear. By the end of the war, Pantex had three loading lines running full-time. 

World War II operations at Pantex stopped the week after the war ended (Mitchell, 2003). Because 

the original scope of the work is not related to nuclear weapons operations/activities, this timeframe is 

not covered under the EEOICPA radiological dose reconstruction program (i.e., not included in the 

NIOSH-evaluated worker class for this petition or included in the evaluation performed within this 

report). 

In 1951, the U.S. Atomic Energy Commission (AEC) was looking for a new High Explosives (HE) 

Fabrication plant, and decided on the unused 6-year-old HE loading line at Pantex. AEC contracted 

with Silas Mason Company to construct 10 new buildings and modify three other buildings; 

construction began on April 13, 1951 (Mitchell, 2003). 

Pantex completed its first HE operations in December 1951. By mid-1952, Pantex was at full 

production and was responsible for HE fabrication, assembly of nonnuclear components, retrofits, 

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modifications, and disassembly for retirements. Between 1952 and 1954, Pantex’s primary mission 

was to precision-machine HE castings before sending them to Sandia National Laboratory for 

assembly. The retrofits and modifications, performed during the 1952 through 1957 timeframe, 

involved in-flight insertable nuclear weapons (i.e., the insertable pits required to make a complete 

nuclear weapon were not handled at Pantex). Since these weapons did not yet contain pits, the only 

nuclear component involved prior to 1957 was depleted uranium (DU). Beginning in 1957, tritium 

reservoirs were received from the Savannah River Plant, and in 1958, the Rocky Flats Plant started 

shipping sealed plutonium pits to Pantex (Personal Communication, June 29, 2003 & May 27, 2004; 

Personal Communication, June 29, 2003). With the advent of the sealed-pit design in 1958, all 

assembly and disassembly work was performed on complete, sealed-pit weapons (Mitchell, 2003). 

The nuclear weapons assembly process was highly standardized and consistent. Rigorous procedures 

were followed to ensure product quality and uniformity. Classified records documented every step of 

the assembly and disassembly of every weapon, including the badge number or inspection stamp of 

the person completing the step (Personal Communication, September 24, 2003a; Personal 

Communication, April 2008). 

Most nuclear weapon assembly parts were manufactured within the Nuclear Weapons complex of 

government-owned/contractor-operated facilities. Pantex received nuclear parts as completed major 

components (Mitchell, 2003). These components supported one of three major processes: 

HE subassembly, mechanical assembly, or “physics package” (1958 and later). Unlike the physics 

package, the HE subassembly and mechanical assembly did not involve any radioactive components. 

The physics package operation (1958 and later) involved combining the HE subassembly with the 

nuclear components. Once assembled into a single unit, the physics package was sent to the 

Non-Destructive Examination section for radiography. Next, it was sent to Mechanical Assembly 

where the weapon was built around the physics package. The completed weapon was checked for 

leaks by filling the weapon with a tracer gas such as helium or argon, placing the weapon in a vacuum 

chamber, and applying a vacuum in the chamber to detect any tracer gas leaking from the weapon. 

After the vacuum leak check was successfully completed, the interior of the weapon was purged and 

backfilled with an inert gas, usually nitrogen (BWXT, 2001). 

Warheads were sent to the Mass Properties area for spin balancing, to test moments and products of 

inertia, and to test the center of gravity. Once the mass properties procedures were complete, 

warheads were sent back to the Non-Destructive Examination section for radiography. Bombs from 

the paint bay and warheads from radiography were both processed for ultimate user packaging, which 

included final checks on stenciling, serial numbers, and other program-specific documentation. 

Completed and packaged weapons were staged for shipment to the U.S. Department of Defense 

(DOD) (BWXT, 2001). 

Figure 5-1 is a schematic illustration of the weapon assembly process at Pantex Plant. The shaded 

steps are those with the highest potential for radiation exposure. Figure 5-2 shows how the 

dismantlement of nuclear weapons at Pantex Plant was basically the reverse of the assembly process 

(Mitchell, 2003). 

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Figure 5-1: Nuclear Weapon Assembly Process 

Completed HE 

Subassembly from 

Machining Process 

Warehouse Received 

Parts & Components 

from Vendors 

Palletized for: 

• HE Subassembly 

• Physics Package 

Assembly, or 

• Mechanical 

Assembly 

HE Subassembly, Pit, 

Secondary, & Palletized 

Parts Mated to Form 

Physics Package 

Radiography 

Physics Package to 

Mechanical 

Assembly Bay 

Completed Weapon to 

Vacuum Leak Check 

• Weapon Filled with 

Tracer Gas 

• Weapon Placed in 

Vacuum Chamber 

• Vacuum Pulled in 

Chamber 

Weapon to Purge 

& Backfill 

Warheads go to Mass 

Properties 

• Spin Balance 

• Moments & Products 

of Inertia 

• Center of Gravity 

Staging in 

Zone 4 

Back for New 

Material or 

Disassembly 

& Inspection 

Shipped to DOD by Transportation 

Safeguards Division 

Vacuum Leak 

Check or Weight 

Check 

Pits & Components 

Received from 

Nuclear Weapons 

Complex 

Bombs go To 

Paint Bay 

Ultimate User 

Packaging 

Warheads to 

Radiography 

Source: Mitchell, 2003
 

Figure 5-2: Weapons Dismantlement and Pit Storage 

Source: Mitchell, 2003
 

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5.1.2 Pantex Plant Facilities 

ATTRIBUTION: Section 5.1.2 was completed by Jerome Martin, Dade Moeller and Associates. These 

conclusions were peer-reviewed by the individuals listed on the cover page. The rationales for all 

conclusions in this document are explained in the associated text. 

Major operations included staging special nuclear materials in Zone 4 and assembling and 

disassembling nuclear weapons in Zone 12 South (BWXT, 2001). The Moderate-hazard facilities at 

Pantex were primarily used for assembly and disassembly. The Special-Purpose and Nuclear Staging 

facilities handled the completed nuclear weapons (nuclear explosives) and components (BWXT, 

2001). The bays, cells, Special-Purpose facilities, and Nuclear Staging facilities at Pantex are 

described below. 

Bays 

Figure 5-3 shows a generic bay situated off a ramp or hall for transport of a weapon or weapon 

component into the bay. Bays were accessed through a pair of interlocked blast-proof doors, which 

prevented the outer door from opening unless the inner door was closed (and vice-versa). A pair of 

double doors (also with an interlocking system) was used to bring equipment into the bay. A special 

work stand for weapons work occupied the middle of the floor space (ORAUT-TKBS-0013-2). 

The principal functions of the bays were the assembly and disassembly of nuclear explosives, 

particularly the mechanical portion, which included the electrical components and tritium reservoirs 

(BWXT, 2001). The major operations in these bays included the partial assembly or disassembly of 

nuclear weapons containing HE and the complete assembly and disassembly of nuclear weapons 

containing insensitive high explosives (IHE). 

Figure 5-3: Generic Representation of a Nuclear Explosive Bay 

Source: Mitchell, 2003 

Alpha and tritium continuous air monitors, connected to the Pantex Radiation Alarm Monitoring 

System (RAMS), were used to detect airborne radiological contamination in the bays and cells 

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(BWXT, 2001). The Radiation Safety system in the radiography bays provided interlocking safety 

devices to protect workers from accidental exposures (BWXT, 2001). Additional safety measures 

included interlocks between the operating controls; gamma radiation detectors; panic switches; 

warning lights, chimes, and horns; passageway door switches; and fire alarms. 

Nuclear explosive assemblies and subassemblies were inspected and certified in the radiography bays, 

which currently house an 8-million-electron-volt (MeV) linear accelerator (Linac) and a 9-MeV Linac 

(BWXT, 2001). The current radiography bays were built in 1970. Prior to that time, the original 

radiography machines and sources were used primarily in Building 12-21 (BWXT 2001). Per a 

NIOSH interview with an early radiation safety officer (Personal Communication, April 7, 2008), the 

original radiography equipment at Pantex included a 1 MeV X-ray, Ir-192, Cs-137, and Co-60 

sources. 

Additional details regarding bay operations are provided in ORAUT-TKBS-0013-2. 

Cells 

The principal functions of the cells included the assembly and disassembly of nuclear explosives, 

particularly operations on the physics package of nuclear explosives that contained HE; work on 

nuclear explosives that contained IHE could be performed in the bays (BWXT, 2001). 

The cell facilities consisted of a round room, staging rooms, a corridor area, and a unit 

equipment/mechanical room. All of these areas were inside the blast-resistant cell structure and 

provided protection from external events, including external explosions, winds, and tornados. 

The mounded earth and gravel cover over a cell was supported by a cable catenary system. The 

cables were suspended from the top of a cell's round room wall. The cell roof consisted of the support 

cables, layers of wire mesh, gravel and earth coverings, and a gunite or concrete cap. Figure 5-4 

shows a generic cell design (Mitchell, 2003). 

Figure 5-4: Generic Representation of a Nuclear Explosive Cell 

Source: Mitchell, 2003 

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Cell design was based on “Gravel Gertie” experiments showing that the cell structure largely 

dissipated blast pressures (BWXT, 2001). The mounded gravel roof over the round room was 

designed to lift and vent gas pressure produced in an explosion. Plutonium was filtered from the 

vented gases by the gravel structure so that releases into the environment would be minimized. The 

equipment passageway doors were designed to remain intact in the event of an accidental detonation, 

and the doors were interlocked so that only one door at a time could be opened. The two blast doors 

were also interlocked. 

Additional details regarding cell operations are provided in ORAUT-TKBS-0013-2. 

Special-Purpose Facilities 

The Special-Purpose facilities at Pantex included the Paint facility, the Separation Testing facility, the 

Mass Properties facility, the Weapons Aging facility, and the Weapons Transfer Station (BWXT, 

2001). Details regarding these facilities are provided in ORAUT-TKBS-0013-6. 

Nuclear Staging Facilities 

Nuclear Staging facilities were located in Zone 4 and Zone 12-South. Zone 4 facilities were used as a 

staging or interim storage area for weapons, weapon components, and other process-related materials 

(BWXT, 2001). Nuclear explosive components without HE were staged in Zone 12 facilities, 

including pit vaults, warehouses, and Special Nuclear Material (SNM) component staging facilities 

(BWXT, 2001). Details regarding these facilities are provided in ORAUT-TKBS-0013-6. 

Burning Grounds and Firing Site 

The burning grounds were used to burn waste HE, some of which was contaminated with uranium238 (Drummond, 1971). Burning HE was a part-time task for Transportation Department workers 

involving a few hours approximately once a week. Only a few workers would have been involved 

during any single burn. The ignition operators were about 100 yards from the burn pad during each 

burning. Access for all other workers was restricted to about 300 yards or more. Ash from the burn 

was collected and placed in 10- to 20-gallon cans for burial. Operators wore half-face respirators with 

high-efficiency particulate air filters during the ash collection task (Personal Communication, June 16, 

2004). 

Pantex has used firing sites for HE quality control and research since 1952. Some of the test firings at 

Firing Sites 4, 5, and 10 involved DU through 1985 (DOE, 1997, Chapter 7). According to a former 

employee who worked at the firing sites from 1959 to 2000 and was supervisor of the firing site since 

1960, the first hydroshot that involved DU occurred in late 1959 or 1960 (Personal Communication, 

October 11, 2006). According to this supervisor, operators were in a bunker a few tens of feet from 

the detonation site. The bunker was fully enclosed with a ventilation system that was shut down 

during the detonation. After the detonation, the operators walked to ground zero to retrieve their 

instruments. A driver, who was outside the fenced area (approximately 2,000 feet from ground zero), 

drove to the detonation site to retrieve the operators. The total exposure time for the operators was 

less than 30 minutes. The cloud from the detonations was clearly visible and the operators and driver 

avoided direct exposure to the cloud (Personal Communication, June 16, 2004). 

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5.2 Radiological Exposure Sources from Pantex Plant Operations 

The following subsections provide an overview of the internal and external exposure sources for the 

Pantex Plant class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from Pantex Plant Operations 

ATTRIBUTION: Section 5.2.1 and its related subsections were completed by Melton Chew, M. H. 

Chew and Associates, Inc. These conclusions were peer-reviewed by the individuals listed on the 

cover page. The rationales for all conclusions in this document are explained in the associated text. 

The major workplace radiation environments that contributed to internal exposure involved nuclear 

weapons components assembly and disassembly, high explosives research and development, weapons 

evaluation, and component storage. This historically included tritium, uranium (U-234, U-235, U238, and uranium metal), thorium (Th-232), and plutonium (Pu-238 and Pu-239). Modification 

operations, assembly, and disassembly activities started at the Pantex Plant in the summer of 1952. 

The weapons dismantlement function has existed since the latter part of 1952 (DOE, 1995). 

As noted in Section 5.1, the retrofits and modifications, performed during the 1952 through 1957 

timeframe, involved in-flight insertable nuclear weapons. Since these weapons did not yet contain 

pits, the only nuclear component involved prior to 1957 was DU. Because DU components were new 

at the time of assembly, there was minimal potential for depleted uranium oxide contamination on the 

components (Personal Communication, October 8, 2003; Davis, 1967). Likewise, the potential for 

significant removable plutonium or tritium contamination (1957 and later) was minimal because the 

sealed plutonium pits and tritium reservoirs had to meet rigorous shipping requirements. Records 

indicated that very little, if any, contamination was detected on weapon components (Davis, 1967). 

The only other sources of radiation exposure at Pantex during this early period were industrial 

radiography and medical X-rays (Personal Communication, September 24, 2003b). 

Workers may have been exposed to indoor radon and its short-lived radioactive daughter products at 

select facilities within the Pantex complex (the source of this exposure being the natural source of 

radiation and radioactive decay associated with the materials that were used in the construction of 

some facilities at Pantex). 

5.2.1.1 Uranium 

Uranium at Pantex was enriched, natural, and depleted. All of the unsealed uranium used at the 

Pantex facility was either depleted uranium or natural uranium. Natural uranium was in a form 

referred to as tuballoy. Kilogram quantities of enriched uranium were processed through the Pantex 

Plant. Weapons processed at Pantex contained enriched uranium as a part of the primary and/or 

secondary component (with composition was up to 93.5% in some units). Some weapons had 

composite pits that contained both uranium and plutonium. Enriched uranium was always associated 

with a sealed component with little likelihood of release and therefore not considered a significant 

potential exposure source for the proposed worker class evaluated in this report. Many of the 

weapons containing enriched uranium have been modified or dismantled since the closure of the 

Medina, Clarksville, and Iowa weapons plants (ORAUT-TKBS-0013-5). 

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Beginning in 1952, some DU was released at the burning grounds through burning DU contaminated 

high explosives. Some DU was also released at the hydro test firing sites when hydro tests involved 

DU components (Firing Sites 4, 5, and 10 only). Machining was performed on DU for a period in the 

early 1960s for one particular weapon design (Personal Communication, June 29, 2003 & May 27, 

2004). 

5.2.1.2 Tritium 

Tritium was introduced into weapons systems in the late 1950s. Reservoirs began arriving at Pantex 

in late 1956 or early 1957 (ORAUT-TKBS-0013-5). The primary form of tritium used in the Pantex 

weapons programs was gas contained in pressured gas cylinders (reservoirs) (BWXT, 2004). During 

disassembly of tritium-containing parts there were routine and expected small releases of tritium into 

the work space. Portable tritium monitors were used to detect tritium off-gassing, and local 

ventilation was available. 

A Cockcroft Walton neutron generator in use before 1956 also produced some tritium in the off-gas, 

and titanium tritide particulate contamination probably existed in the target and the area where the 

drift tube connected to the target, but the amount would have produced negligible intakes (ORAUTTKBS-0013-5). Tritium sealed under high pressure in the reservoir units has the potential to leak 

during disassembly. The Internal Dosimetry Technical Basis and Quality Assurance Document states 

that tritium could leak through reservoir materials, which presumably refers to concern for migration 

of molecular tritium through welds. The tritium in the reservoirs is 99% gaseous molecular hydrogen 

(DT, HT, or T2) and 1% tritiated water vapor (HTO or T2O) (Pantex Plant, August 2001). 

Tritium gas interacts over time with moisture in the air, hydrogenated materials (e.g., hydrocarbons, 

organic compounds, and concrete), and some forms of metals to form tritiated compounds and metal 

tritides (Peterson, 2002). 

The potential for tritium compound exposure existed at Pantex. Tritides were formed as a result of the 

tritium gas reacting with metal components of weapons and producing tritiated compounds. In 

addition, tritium compounds were used in some weapons programs. 

5.2.1.3 Plutonium 

Weapons components that contained plutonium were hermetically sealed units. Since the late 1950s, 

these units were inventoried and tracked. Particular radionuclides of plutonium were also used in 

other capacities in the weapons system. The components were surveyed upon arrival at the plant and 

through various stages of assembly and disassembly. Pantex serves as the interim storage for 

plutonium components and continues to monitor them (Pantex Plant, August 2001). 

Plutonium at Pantex was located in the encapsulated pits of nuclear weapons. Strict workplace 

monitoring practices, including contamination smear checks during assembly and disassembly, 

ensured the integrity of the encapsulation (Pantex Plant, August 2001). 

5.2.1.4 Thorium 

Thorium was handled during assembly, modification, and disassembly of particular weapons 

programs. Thorium at Pantex existed as thorium metal, thorium alloys, or materials impregnated with 

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a thorium compound. Workers handled these forms during assembly and disassembly of certain 

weapons. Because of the relative hazard of thorium, Pantex used strict workplace monitoring 

practices, including smear checks of components, to verify the integrity of the thorium encapsulation. 

Although information regarding source terms of weapons containing thorium is still classified, it is 

assumed that workers could have encountered oxidized thorium components during disassembly of 

weapons in the mid-1960s. Pantex has never conducted machining of components containing thorium 

(ORAUT-TKBS-0013-5, Section 5.2.3). 

5.2.1.5 Radon 

While the general characteristics of areas with the potential for elevated levels of indoor radon, as well 

as construction designs that tend to enhance radon levels, are known, it is rarely possible to predict 

indoor radon levels for a given structure. In general, structures that exhaust air to the environment 

without adequately engineered replacement air have higher indoor radon levels than do betterengineered structures. In addition, structures that have exposed soil (dirt floors, sumps) or exposed 

minerals (e.g., gravel) tend to have higher radon levels. Underground structures have a higher ratio of 

soil surface to building volume. All other factors being equal, an underground building would be 

likely to have a higher radon concentration than an aboveground building. 

At Pantex, the Gravel Gertie cells were in Buildings 12-44, 12-85, 12-96, and 12-98, which were 

considered to be underground even though they are not below-grade. Bays, which were also 

considered underground, were in Buildings 12-17, 12-19, 12-21, 12-56, 12-64, 12-84 East, 12-84 

West, 12-99, 12-104, and 12-117. Workers in these buildings were likely to have greater exposures to 

radon and its decay products than workers in other buildings (ORAUT-TKBS-0013-5). 

The radon progeny associated with thorium (Rn-220) is a radioactive noble gas, commonly called 

thoron. Thoron has a much shorter half-life (55.6 seconds) than its parent. In general, Rn-220 decays 

before it can build up to significant levels unless there are large quantities of Th-232 and its decay 

products present. Based on this information, and because work on thorium weapons was infrequent 

(ORAUT-TKBS-0013-5), there is no reason to expect that Pantex had significant Rn-220. 

5.2.2 External Radiological Exposure Sources from Pantex Plant Operations 

ATTRIBUTION: Section 5.2.2 and its related subsections were completed by Melton Chew, M. H. 

Chew and Associates, Inc. These conclusions were peer-reviewed by the individuals listed on the 

cover page. The rationales for all conclusions in this document are explained in the associated text. 

Details regarding Pantex workers handling sources of radiation, such as depleted uranium, plutonium, 

and other nuclear weapon materials, involve classified information. Work activities varied over time. 

Analysis of historical information showed that assembly activities at Pantex began in 1952, which 

corresponds with the first record of personnel monitoring (Carr, unknown date). The nature of the 

radiation fields a Pantex worker could have encountered depends on the type of facility in which the 

work occurred. Nuclear weapons components emit alpha, beta, X-rays, gamma rays, and neutrons; 

however, doses to workers depend strongly on the configuration (i.e., material and shielding) of the 

source of radiation and the work performed (BWXT, 2001). In addition, industrial radiography 

operations had the potential to expose some workers to X-ray, gamma, and neutron radiation. 

At first, Pantex issued dosimeters only to workers likely to receive a significant radiation dose per 

existing radiation protection guidelines. From 1952 through 1957, this included only radiographers; 

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other sources for significant external exposures were minimal (Personal Communication, April 7, 

2008). From 1958 through 1988, only radiation workers were monitored. From 1989 to 2005 (up to 

the time that ORAUT-TKBS-0013-6 was completed), all Pantex workers were monitored for external 

radiation exposure. 

5.2.2.1 Photon 

Photon radiations encountered at Pantex have widely-varying energies, ranging from about 30 keV to 

a few MeV (ORAUT-TKBS-0013-6). Of the various photon radiation sources at Pantex, the lowest 

energy (about 30 keV) was produced by X-ray diffraction machines. The highest energy (2.6 MeV) is 

produced by the thorium decay product thallium-208. Table 5-1 summarizes the photon-emitting 

radionuclides and corresponding emission energies found at Pantex. The cladding on plutonium pits 

attenuates the low-energy photons and X-rays associated with the respective plutonium decay chains. 

Table 5-1: Pantex Plant Photon-Emitting Radionuclides 

Radionuclide Energy (MeV) 

Thorium-232 decay series Up to 2.614 

Uranium-235 decay series Up to 0.898 

Uranium-238 decay series Up to 2.204 

Americium-241 0.014 (43%), 0.060 (36%) 

Plutonium-238 0.014 (12%) 

Plutonium-239 0.014 (4%) 

Plutonium-240 0.014 (11%) 

Source: Schleien, 1998 

Sources of photon radiation have included weapon components, analytical devices employing X-rays 

produced by radiation-generating devices, and low-activity radioactive sources such as those used to 

check or calibrate radiation detectors (ORAUT-TKBS-0013-6). 

Weapons assembly at Pantex has been performed with nuclear components of purified metals. The 

purification process separates progeny radionuclides from their parent metals, which provides some 

insight into potential sources of radiation. However, weapons-grade plutonium contains several 

isotopes of plutonium, including various amounts of Pu-238, Pu-239, Pu-240, Pu-241, and Pu-242. 

With a half-life of 14.4 years, Pu-241 immediately begins to decay to Am-241. 

Am-241 starts accumulating within the plutonium matrix as a daughter product resulting from the 

decay of Pu-241 immediately as its parent radionuclide Pu-241 decays with a half-life of 14.4 years. 

The Am-241, which emits 60-keV photons, reaches maximum activity after about 80 years, but it 

reaches about 85% of this maximum in 40 years (ORAUT-TKBS-0013-6). Thus, for nuclear weapons 

activities, Am-241 was an increasingly significant source of exposure to workers performing weapons 

disassembly, which often occurred many years after assembly (ORAUT-TKBS-0013-6). 

5.2.2.2 Beta 

The sources for beta exposures at Pantex were associated primarily with depleted and enriched 

uranium (ORAUT-TKBS-0013-6). However, beta particle-emitting radioactive materials used at 

Pantex also included tritium and thorium. Table 5-2 lists the beta-emitting radionuclides and their 

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maximum beta energies; the average beta energy is approximately 1/3 of the maximum energy. Beta 

emissions from tritium are not considered an external radiation hazard, due to their very low energy. 

Table 5-2: Pantex Plant Beta-Emitting Radionuclides 

Radionuclide Maximum Energy (MeV) 

Tritium (Hydrogen-3) 0.018 

Thorium-232 decay series 0.039, 0.334, 2.246, 1.800 

Uranium-235 decay series 0.205, 0.287, 0.304 

Uranium-238 decay series 0.189, 2.280 

Source: Schleien, 1998 

5.2.2.3 Neutron 

There have been three main types of facilities or activities at Pantex with the potential for neutron 

exposure to workers: (1) bays and cells, (2) vaults and igloos (storage facilities), and (3) transportation 

(BWXT, 2001). The specific workplace neutron fields for selected types of nuclear weapon 

components are classified. Unclassified information on neutron spectra from fission and sealed 

plutonium sources is available. 

Plutonium pits that are not associated with high explosives are referred to as “bare pits,” although all 

pits are sealed or encapsulated (Shipler, 2004). Assembly and disassembly operations that occur in 

cells comprise the only times workers have been exposed to neutrons emanating from bare pits. In the 

workplace, these spectra are significantly changed through scattering in nuclear weapon components, 

equipment, and building materials. The average energy is higher for unshielded neutrons resulting 

from plutonium and beryllium interactions than for fission neutrons (ORAUT-TKBS-0013-6). 

With a change in algorithm from 1992 to 1993, some questions were raised about the overestimation 

of neutron dose during this period (ORAUT-TKBS-0013-6). For this reason, the TBD proposes to 

employ neutron-to-photon ratios for the period prior to 1994. 

The TBD neutron-to-photon ratios are based on worker dosimeter measurements that were recorded 

using the Panasonic UD-809/UD-812 system and correspond to doses in which both the photon and 

neutron doses of the individual exceeded 50 mrem per year. From these data, a median neutron-tophoton ratio of 0.8 and a 95th percentile value of 1.7 were calculated. For dose reconstruction of 

monitored workers, NIOSH recommends the 95th percentile neutron-to-photon ratio of 1.7. 

5.2.3 Incidents 

ATTRIBUTION: Section 5.2.3 was completed by Melton Chew, M. H. Chew and Associates, Inc. 

These conclusions were peer-reviewed by the individuals listed on the cover page. The rationales for 

all conclusions in this document are explained in the associated text. 

Incidents that occurred at the Pantex Plant were documented and worker exposures were assessed 

when incidents involved radioactive sources. Incident reports are still maintained at Pantex; copies of 

many of these reports have been obtained through data capture efforts and are now also included in 

the SRDB. A list of Pantex incident/accident report titles applicable to the NIOSH-evaluated 

timeframe has been reviewed by NIOSH (Author unknown, 1970-1989; Author unknown, 1961­

2007). 

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Documented monitoring data obtained from response work is available for bounding the doses 

associated with incidents that occurred at Pantex. There is no indication that any incidents occurred 

that resulted in exceptionally high exposures/doses (like a criticality) to Pantex workers. Summaries 

of three of the most significant incidents that occurred during the evaluation time frame are provided 

below. 

An incident of plutonium exposure occurred in 1961. The details of the event are classified, but 

NIOSH has access to associated data that can be used to estimate intakes. These data include external 

dosimetry results and bioassay data from the employees involved in the incident and subsequent 

decontamination. Cell air monitoring data are also available. 

Sometime just before November 14, 1978 (exact date not known), a nuclear materials inventory of a 

Nuclear Weapons Accident Residue (NWAR) storage cylinder was attempted. The mounded earth 

overcap was removed and the cylinder was opened. Heavy rainfall occurred during the time that the 

cylinder was open, and the cylinder was flooded, soaking various radioactive waste storage cans. 

Consequently, the cans were removed, surveyed, and moved to Magazine 4-75 (also referred to as 

Igloo 75). Although no contamination was found during the initial survey, the cans were wet so the 

alpha survey was ineffective. A subsequent survey on November 14 found alpha contamination 

associated with a small hole in one 11-M can that contained mostly plutonium waste (uranium and 

tritium contamination was also possible). The igloo was secured. Potentially exposed workers were 

given bioassays on or about November 17, 1978. This event was well documented via an incident 

report, a decontamination plan, and a list of personnel involved and their bioassay results (Unknown 

author, unknown date-b; Pantex Plant, 1979; Pantex Plant, 1978). 

A release of tritium gas occurred within Cell 12-44-1 at the Pantex Plant on May 17, 1989. This 

release was the result of a nuclear component failure. Bioassays were performed on all affected 

individuals and NIOSH has access to the results (Mason & Hanger, 1989). This event was also well 

documented. Available information includes a list of personnel involved and the internal doses they 

received from tritium exposure. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

ATTRIBUTION: Section 6.0 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

A radiation dosimetry program was first established at Pantex in 1952 by the manager of the 

Radiography group. The radiation program gradually evolved as the scope of work at Pantex included 

more sources of potential radiation exposure (sealed pits containing fissile materials and increased 

plant throughput). Additionally, a major expansion of the radiation protection program occurred after 

a tritium release incident in May 1989. Overall, personal monitoring was focused on those workers 

most likely to be exposed to radiation: radiography technicians, production technicians, material 

handlers, transportation workers, quality control technicians/inspectors, and warehouse production 

workers. Other workers at Pantex had little occasion to enter radiological areas, and their potential for 

radiation exposure or intakes of radioactive materials were considerably less. 

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Sources of monitoring data for this evaluation include the SRDB, NOCTS, DoRMS, and the Optix® 

imaging system. An older database system constructed at Pantex, known as HERS, has been 

incorporated into DoRMS. The HERS database was used to maintain available personnel dose data 

applicable to the proposed 1951 through 1991 timeframe. HERS was initiated in 1989 when original 

personnel dose records were reviewed and discrepancies were identified and corrected. Individual 

workers were interviewed, and their records checked for accuracy. Missing records or anomalies were 

analyzed, with worker assistance, and appropriate notes entered into the record (Rawlston, 1991). 

Documentation of worker monitoring results stemming from non-routine sampling efforts (eventdriven or as a result of high air sampling results or surveys) was generally not loaded into the HERS 

database. As a result, these data are not reflected in the DoRMS database query outputs. However, 

these monitoring results are actively being captured in the Optix® imaging system, which is being 

used to electronically store individual worker records in a PDF format. 

The following subsections provide an overview of the available internal and external monitoring data 

for the Pantex Plant class under evaluation. The primary sources of internal radioactive contamination 

have been DU oxide and tritium. The primary sources of external radiation exposure included 

plutonium pits and DU or thorium components (Personal Communication, October 1, 2003). 

6.1 Available Pantex Plant Internal Monitoring Data 

ATTRIBUTION: Section 6.1 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

During essentially all years under evaluation, there was no Pantex bioassay program for uranium, 

thorium, or plutonium that would be considered “routine.” Instead, bioassay was performed for 

specific events and for known or suspected exposure incidents. As for the aforementioned 

radionuclides, tritium bioassay was also performed for specific events and for known or suspected 

exposure incidents. However, during the 1960s, tritium monitoring was also performed on a rotating 

sample basis and included about 10 workers per month as a means of spot-checking for potential 

uptakes associated with various jobs (ORAUT-TKBS-0013-5; Davis, 1967; Personal Communication, 

April 8, 2008). For example, in 1961 bioassay samples were collected from workers involved in a 

specific plutonium contamination event and from those involved in decontaminating the facility after 

the event (ORAUT-TKBS-0013-5). A 1967 Health Protection Survey Report describes an inspection 

of the Pantex Radiation Protection program and states that Pantex used air samples and contamination 

surveys to indicate the need for bioassay samples. The report further confirms that Pantex performed 

about 10 tritium urinalyses a month with no indication of personnel exposures (Davis, 1967). 

To support the incident/suspected exposure-driven program, all aspects of work at Pantex have always 

involved procedures and routine contamination checks (e.g., swipes, air sampling) to assist in 

identifying work locations with the potential for personnel internal exposures (Personal 

Communication, April 7, 2008; Personal Communication, April 8, 2008). According to both 

procedures and interviewed employees, evidence of potential exposures was always followed by 

additional area monitoring/media sampling (as appropriate), and also included personnel bioassay 

monitoring (if deemed necessary). Data indicating the presence of contamination, personnel exposure 

sources, or monitoring for potential internal exposures to workers (bioassays) were maintained in site 

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records. Data that did not indicate contamination and/or exposures (“negative” data) were often not 

saved for future reference, particularly in the earliest years of operations (Personal Communication, 

April 8, 2008). This Pantex recordkeeping practice, coupled with the relative cleanliness of the 

materials and work performed at Pantex, and the site’s practice of only collecting bioassay samples 

when other monitoring/events dictated a need, has resulted in apparent monitoring data gaps for many 

types of internal monitoring data over the years. 

The approach used for collection of bioassays from Pantex workers changed towards the end of the 

evaluated class timeframe. A 1991 procedure titled Analysis of Biological Samples for Uranium, 

Thorium, and/or Plutonium stated that urinalysis was to be conducted for personnel exposed to 40 

derived air concentration (DAC)-hour integrated air concentrations, as measured by breathing-zone 

monitors, or was to be estimated if not specifically monitored (Mason & Hanger, 1991a). The 

procedure also stated that “personnel working in potentially contaminated areas shall be entered into 

the routine bioassay program and shall have a routine bioassay for the suspect heavy metal 

radionuclide performed every 4 to 6 months.” The routine bioassay program for radionuclides other 

than tritium was short-lived, occurring mostly in 1991 and 1992 (ORAUT-TKBS-0013-5). Research 

did not reveal the level of air concentrations or other workplace indicators that triggered special 

bioassays before 1991 (ORAUT-TKBS-0013-5). 

Except for a single measurement made for Pu-239 and Am-241 at the Los Alamos Scientific 

Laboratory in 1978, no records of in vivo measurements made within the 1951 through 1991 

evaluation period are available. More than 200 personnel working on the B28 Disassembly Program 

were monitored by the Helgeson in vivo counter in 1989; however, the results of the in vivo counts 

were later determined to contain a positive bias and were deemed not credible (Helgeson, 1989). 

Table 6-1 shows the number of Pantex employees with bioassay monitoring doses recorded in the 

DoRMS databases from 1972 to 2004. DoRMS does not contain any internal monitoring data prior to 

1972. Data from years extending beyond the 1951 through 1991 evaluation period are being presented 

due to their potential for use in reconstructing dose for the pre-1991 period. 

Table 6-1: Pantex Employee Monitoring Doses Recorded in the HERS and DoRMS Databases 

Table 6-1 spans two pages. 

Year No. of Workers 

Monitored for Tritium* 

No. of Workers 

Monitored for Uranium* 

No. of Workers 

Monitored for Thorium* 

No. of Workers 

Monitored for 

Plutonium* 

1972 4 0 0 0 

1973 1 0 0 0 

1974 0 0 0 0 

1975 0 0 0 0 

1976 463 0 0 0 

1977 466 0 0 0 

1978 519 0 0 0 

1979 712 0 0 0 

1980 14 0 0 0 

1981 41 0 0 0 

1982 5 0 0 0 

1983 0 0 0 0 

1984 0 0 0 0 

1985 17 0 0 0 

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Table 6-1: Pantex Employee Monitoring Doses Recorded in the HERS and DoRMS Databases 

Table 6-1 spans two pages. 

Year No. of Workers 

Monitored for Tritium* 

No. of Workers 

Monitored for Uranium* 

No. of Workers 

Monitored for Thorium* 

No. of Workers 

Monitored for 

Plutonium* 

1986 626 0 0 0 

1987 481 0 0 0 

1988 499 0 0 0 

1989 212 0 0 0 

1990 2,341 46 0 0 

1991 1,115 431 0 0 

1992 879 239 17 12 

1993 1,078 90 0 0 

1994 1,104 138 4 3 

1995 971 37 90 33 

1996 940 69 56 17 

1997 933 89 13 18 

1998 610 12 1 2 

1999 554 13 16 1 

2000 535 33 9 8 

2001 512 65 16 1 

2002 511 57 11 10 

2003 441 87 25 9 

2004 421 109 15 0 

Notes: 

*

The numbers presented in the table reflect the number of workers for which calculated doses were compiled and recorded
 

in the HERS (originally) and DoRMS databases. 

As mentioned previously, additional limited internal monitoring data collected to assess a specific 

activity, contamination event, and/or elevated air concentration result are also available. In many 

instances these results are only available as images linked to individual personnel files in Optix® or in 

documents that Pantex has kept on file or put into long-term storage. Optix® was designed with 

employee identification as the primary sort key; as such, it is not possible to efficiently query this 

system specifically for monitoring results. Similarly, data contained solely in documents are not 

included in Table 6-1 above. 

Through data capture efforts, NIOSH has collected and reviewed many internal data-containing 

documents. Within these documents there are considerable variations in the quantity of data available 

as well as support information such as sampling and analytical methods details. Attachment One of 

this report provides a listing of the data-containing documents in the SRDB. This table is sorted by 

year, data type, and SRDB document ID number. 

Hardcopy air monitoring results applicable to specific activities have been documented and are 

available to NIOSH (see Attachment One of this evaluation report). Some pre-1991 air monitoring 

results are stored as scans of hard copies that have been included in some workers’ files (Optix®). 

Examples of available air sample results can be found in various Air Sample Monitoring Logs (Pantex 

Plant, 1959 -1967) that document air quality during the burning of high explosives at the burning 

grounds and firing sites (hydroshots). Additional data obtained from radio-controlled drones flown 

through clouds produced from hydroshots are available in Gidley, 1971; Alexander, March 1972; 

Alexander, May 1972; Alexander, August 1972; and Alexander, October 1974. 

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Additional details regarding various analyses, reporting protocols (when known), and associated 

minimum detectable activities are presented in ORAUT-TKBS-0013-5. 

6.2 Available Pantex Plant External Monitoring Data 

ATTRIBUTION: Section 6.2 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

The following discussion provides a summary of the Pantex Plant external dosimetry program as well 

as the types, quantity, and quality of data that can be used for external dose reconstruction. Details 

regarding the various analyses used and the associated minimum detectable activities are presented in 

ORAUT-TKBS-0013-6, unless noted otherwise. 

Pantex started monitoring workers for external radiation exposure in 1952 (Personal Communication, 

October 1, 2003; Personal Communication, October 8, 2003). At first, Pantex issued dosimeters only 

to workers likely to be exposed to radiation. From 1952 through 1957, the only workers considered 

likely to be exposed were radiographers (see Section 5.1.1 of this evaluation). From 1958 through 

1988, only workers specifically classified as radiation workers were monitored (Personal 

Communication, October 1, 2003). The variations in numbers of radiation workers reflect changes in 

weapon production rates (Carr, unknown date). From 1989 to the present, all Pantex workers who 

entered a radiologically-controlled area were monitored for external radiation exposure (Griffis, 

1988). Table 6–2 presents the numbers of Pantex employees monitored throughout the years. 

Table 6-2: Annual No. of Monitored Pantex Employees 

Year No. 

Monitored Year No. Monitored Year No. Monitored 

1950 0 1964 253 1978 518 

1951 0 1965 416 1979 714 

1952 1 1966 581 1980 819 

1953 1 1967 563 1981 915 

1954 2 1968 423 1982 1,002 

1955 1 1969 432 1983 1,027 

1956 1 1970 468 1984 1,113 

1957 3 1971 495 1985 1,172 

1958 19 1972 467 1986 1,129 

1959 22 1973 441 1987 1,160 

1960 69 1974 500 1988 1,121 

1961 71 1975 493 1989 1,438 

1962 64 1976 463 1990 2,090 

1963 218 1977 465 1991 2,126 

Pantex Plant dosimetry methods evolved with the development of improved technology and a better 

understanding of the complex radiation fields encountered in the workplace. The accuracy of 

dosimetry methods depends on radiation type, energy, and exposure geometry (BWXT, 2001). 

Dosimeter exchange frequency gradually lengthened and corresponded to changes in Radiation 

Protection Guidelines (RPGs) (Morgan, 1961). Table 6-3 summarizes major changes in Pantex 

external dosimetry systems and routine dosimeter assignment periods for workers; it shows the 

dosimeter type, period of use, and exchange frequency. 

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Table 6-3: Pantex Dosimeter Information from 1959-1991 

Dosimeter Type Provider Period Exchange 

Frequency 

βγ film Tracerlab January 1952 - December 1959 Weekly 

βγ film and NTA film Tracerlab January 1960 - March 1961 Weekly 

April 1961 - May 1963 Monthly 

βγ film and NTA film Eberline June 1963 - September 1964 Monthly 

βγ film and NTA film Landauer October 1964 - December 1968 2/Month 

January 1969 - December 1972 Monthly 

TLD 2-element in-house and NTA film/Landauer1 January 1973 - December 1976 Monthly 

TLD 6-element in-house January 1977 - September 1980 Monthly 

Panasonic 802 TLD in-house October 1980 - December1991 Monthly 

Notes: 

1

 The Pantex in-house two-element thermoluminescent dosimeter (TLD) was implemented in 1973 for monitoring betagamma radiation exposures only. Use of NTA film continued for monitoring neutron exposures until implementation of 

the six-element TLD system in 1977 (Personal Communication, October 8, 2003). 

The first dosimeter used at Pantex was a two-element film badge supplied by Tracerlab for measuring 

beta, X-ray, and gamma exposures (Tracerlab, 1962-1963). Beginning in 1960, Pantex used a multielement film badge that incorporated NTA film to measure beta, X-ray, gamma, and fast neutrons 

(Tracerlab, 1962-1963). From 1972 to 1976, a two-element, in-house thermoluminescent dosimeter 

(TLD) system was used to measure beta, X-ray, and gamma exposures; NTA film was retained to 

measure fast neutrons (Personal Communication, October 8, 2003; Alexander, 1973). From 1977 to 

1980, Pantex used a six-element, in-house TLD system that included personal nuclear accident 

dosimeter elements (Ihne, 1980; Personal Communication, October 8, 2003). Beginning in 1980, 

Panasonic TLD systems with automatic readers were used; the UD-802 TLD was used from 1980 to 

1993. 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in ORAUT-TKBS-0013-6. 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

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 that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

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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 as summarized in Section 7.6. 

This approach is discussed in OCAS’s SEC Petition Evaluation Internal Procedures which are 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00068 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Pantex Plant Data 

ATTRIBUTION: Section 7.1 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

Dosimetry records have been maintained at Pantex since 1952. There have been essentially only two 

primary contractors to DOE and its predecessor agencies responsible for managing the plant and its 

records during the timeframe of the NIOSH-evaluated class. Prior to October 1956 the plant was 

operated by Procter and Gamble. From October 1956 through October 1991, the plant was managed 

and operated by Mason and Hanger-Silas Mason Co., Inc. (MHSM). In October 1991, Battelle joined 

with MHSM to operate the plant. 

Pantex staff originally used forms to manually record dosimeter processing and dose information. As 

the technology became available at the Pantex Plant, paper records were augmented with mainframe 

computers and microfilm to maintain worker exposure histories (exact times unknown). Throughout 

this period, paper records were often moved into a storage status. In November 1989, a project was 

initiated to consolidate all known employee paper, electronic, and microfilm records into individual 

worker files to be maintained in both hardcopy and contemporary electronic format. This project was 

conducted by the Delphi Groupe and led to the creation of the Historical Exposure Records System 

(HERS). 

The HERS effort was completed in 1991; in 1992 the HERS files were then integrated into another 

recordkeeping system called the Dosimetry Records Management System (DoRMS). Designed to 

meet or exceed requirements set in 10 CFR pt. 835, DOE and Pantex Radiological Control Manuals, 

and DOE M 231.1-1A, this system is still used and serves as a comprehensive and centralized 

repository for Pantex Plant radiation dosimetry-related data and activities. To comply with DOE 

Records Management Order 243.1, another electronic records management application, called 

Optix®, was adopted at Pantex in 2001 to augment the DoRMS system. Among other functions, 

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Optix® is still being used to electronically store images of historical documents pertinent to individual 

Pantex workers (e.g., medical records, accident/incident memos). The documents are scanned into the 

database and stored as part of workers’ individual files (Unknown author, unknown date-c). 

A majority of the exposure data applicable to the evaluation of dose reconstruction feasibility for the 

evaluated class timeframe was collected and analyzed during construction of the HERS. The work 

performed (and documented) during this effort best describes the pedigree of the available Pantex 

exposure data and as such, a summary of this effort is included below. The HERS work was welldocumented and details regarding project execution aspects such as design, data acquisition processes, 

security, administrative controls, data transcription and reconstruction, and quality control are 

available in SRDB references (Roser, 1980; Delphi Groupe, 1990). Pantex maintains a complete set 

of HERS documentation onsite. A HERS project report (Delphi Groupe, 1990) indicates that the 

HERS project conformed to the following DOE Orders: 

•	 DOE Order 1324.2A, Records Disposition (dated September 13, 1988), 

•	 DOE Order 5484.1, Protection, Safety, and Health Protection Information Reporting System (dated 

November 6, 1987, Change 3), 

•	 DOE Order 5480.11, Radiation Protection for Occupational Workers (dated December 21, 1988), 

and 

•	 DOE Order 5480.15, Accreditation Program for Personnel Dosimetry. 

In addition to the DOE Orders, the HERS project also conformed to the following American National 

Standards Institute (ANSI)/American Society of Mechanical Engineers (ASME) requirement: 

•	 NQA-1-1986, Quality Assurance Program Requirements for Nuclear Facilities. 

A HERS project report (Delphi Groupe, 1990) indicates that the following American National 

Standards Institute (ANSI), American Nuclear Insurers (ANI), Mutual Atomic Energy Liability 

Underwriters (MAELU), and Nuclear Management and Resources Council (NUMARC) standards 

were followed: 

•	 ANSI N13.601966, American Standard Practice for Occupational Radiation Exposure Records 

Systems (R1972), 

•	 ANI/MAELU Information Bulletin 80-1A, Nuclear Liability Records Retention (Revision 2, dated 

February 28, 1986), and 

•	 NUMARC/NESP-003, Radiological Recordkeeping for Workers in the Nuclear Industry (dated 

December 1988). 

Upon completion, the HERS project provided Pantex with an electronic database containing the bestavailable personnel dose information and a complete individual occupational dosimetry file for each 

employee. All original external exposure readings were preserved. Internal results were recorded as 

individual doses. In addition to the requirements contained within the DOE Orders and the standards 

listed above, the following specific HERS project objectives are relevant to the SEC-00068 data 

pedigree evaluation: 

•	 The review of Pantex personnel occupational radiation exposure records generated prior to 

calendar year 1983; 

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•	 Computerization of all available exposure records for the period 1957 through 1983. including the 

reconstruction and verification of incomplete, missing, or unmonitored exposures for input 

(eventually, external data back to 1952 was located and incorporated); 

•	 Verification of all Pantex employee internal and external radiation exposure data for the period of 

1983 through 1989; and 

•	 Computerization and/or reformatting of prior or concurrent exposures received at other corporate 

or military facilities for the period of 1983 through 1989. 

Original personnel exposure records were provided by MHSM Radiation Safety Department to 

Delphi Groupe for this work. In addition to Pantex-maintained paper records, all Pantex-related 

records that had been stored at the Idaho National Engineering Laboratory’s System Safety 

Development Center were obtained to fill in “holes.” Exposure records from previous employment at 

other sites were also collected and incorporated into workers’ exposure files, as were workers’ offsite 

exposures while employed at Pantex. Site microform documentation was also obtained; however, 

many of the microform data proved duplicative of data on paper documents (and other microforms). 

The project records were physically transferred to a single room in Building 136, and in keeping with 

the Orders and Standards listed above, an inventory system was maintained. All records were 

administratively controlled as “Sensitive Material.” The room was kept locked when not physically 

occupied by Delphi personnel. Computer equipment used to input and process data was passwordprotected, and processes were in place to minimize the likelihood of clerical errors (e.g., duplicate 

entries). Ultimately, a complete quality-control check of all data input into HERS was performed. 

During the final phase of the project, interviews were conducted with all employees to help ensure the 

accuracy of the individual exposure files assembled for HERS. 

During the HERS data review, Delphi noted that there were pervasive typographical errors in 

hardcopy records (primarily incorrect data transcription from vendor reports). Delphi’s project 

procedure was to not modify any of the hardcopy records in any way. When possible, however, 

corrections were made to these types of errors for input into the electronic database if the corrections 

were well-substantiated and did not compromise the project’s policy of recording employee doses that 

were conservatively high (Delphi Groupe, 1990). All such changes were explained in “comments” 

and “remarks” fields of the HERS database for accountability. All original data have been kept for 

comparison. Project-specific procedures used for data transcription, error correction, and 

reconstruction rules are detailed in Attachment 1 of Delphi Group, 1990. 

7.1.1 Internal Monitoring Data Pedigree Review 

ATTRIBUTION: Section 7.1.1 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

While the quantity of Pantex internal data collected during the proposed class time is relatively low, it 

is consistent with the internal exposure potential associated with work conducted at the Pantex Plant 

(Vespe, 1965; Davis, 1967; DOE, 1989). 

As noted in Section 7.1, the HERS project collected and reviewed available data records per 

applicable DOE Orders and several industry standards. Analytical methods used for tritium bioassays 

collected during the proposed class timeframe were consistent with prevailing industry standards. 

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Data available for estimating internal doses due to potential uranium, plutonium, and thorium 

exposures are predominantly from sampling/analyses performed in 1989 and later. These data also 

were obtained per industry standards and are suitable for conservatively estimating doses for the class 

under evaluation. 

Upon request, Pantex provided original hardcopy records in addition to database printouts, ensuring 

NIOSH’s ability to confirm data. Per Dose Reconstruction Training (ORAUT-TRNG-0051), dose 

reconstructors compare these data sets when performing dose assessments. The analytical work 

performed for the HERS project, the availability of original records, and the training negate the need 

for an additional internal consistency check of manually-entered data. 

7.1.2 External Monitoring Data Pedigree Review 

ATTRIBUTION: Section 7.1.2 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

NIOSH has found that Pantex policies for the collection and maintenance of employee external 

monitoring data provide alpha, beta, and gamma external exposure records that are sufficient to 

estimate external dose in terms of the pedigree parameters described in Section 7.1. Measurement 

methods used for external exposures made during the evaluated timeframe were consistent with 

prevailing industry standards. With the exception of neutron exposure data obtained from NTA film 

(see Section 7.3), the data obtained from the evaluated class timeframe are sufficient in quality and 

quantity to be used to evaluate external doses. Subsection 7.3.4 describes a method to bound potential 

neutron exposures. 

As previously described and noted for internal dosimetry records, the HERS project collected and 

reviewed available external data records per applicable DOE Orders and several industry standards. 

Upon request, Pantex provided original hardcopy records in addition to database printouts which 

allows for data confirmation. Per ORAUT-TRNG-0051, dose reconstructors compare these data sets 

when performing dose assessments. The work performed for the HERS project and having the 

original records in place negate the need for an additional internal consistency check of manually 

entered data. 

7.2 Evaluation of Bounding Internal Radiation Doses at the Pantex Plant 

ATTRIBUTION: Section 7.2 and all of its related subsections were completed by Eva Hickey, Pacific 

Northwest National Laboratory (PNNL). These conclusions were peer-reviewed by the individuals 

listed on the cover page. The rationales for all conclusions in this document are explained in the 

associated text. 

Internal radiation dose for members of the class under evaluation would have occurred primarily 

through inhalation and ingestion of radiological contamination from the following sources: 

•	 Molecular tritium leakage through welds in weapons components known as reservoirs; 

•	 Disassembly of aged uranium components from certain weapons programs (The uranium was 

most likely depleted, but there was both some natural uranium and possibly very small amounts of 

enriched uranium depending on the weapon design. It is unlikely that significant amounts of 

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removable depleted uranium oxide would have been on the components during assembly because 

components were new and clean during assembly operations.); 

•	 Burning of DU-contaminated HE components at the burn pads; 

•	 Explosion of DU during hydro tests, which would have produced some thermally-oxidized DU; 

•	 Machining of DU-contaminated metal (associated with one weapon design); 

•	 Handling thorium metal, thorium alloys, or materials impregnated with a thorium compound 

during assembly and disassembly of certain weapons; 

•	 Plutonium in the encapsulated pits; and 

•	 Elevated radon levels from the cells and gravel gerties. 

Table 7-1, taken from ORAUT-TKBS-0013-5, shows the job titles and associated work descriptions 

for the Pantex Plant. The table is included here for reference as a means to demonstrate that the data 

and methods used to reconstruct doses was bounding and covered all Pantex employees. 

Table 7-1: Pantex Job Titles and Job Descriptions with the Possibility for Occupational Intake 

Table 7-1 spans two pages. 

Job Title Work Description Possibility for Intake 

(1 highest)a 

Production Technician, Assembler, 

Assembly Operator, Assembly 

Fabrication 

Assemble, disassemble, reassemble, inspect components 1 

Quality Assurance Technician I 

Conduct NDE evaluations with linear accelerators, X-ray 

machines, etc.; conduct telemetry testing; perform 

confirmatory measurements on components, assemblies, 

containers, etc. 

1 

Quality Assurance Technician II Perform NDE, electronic, destructive, telemetry, and 

radiation measurement testing 1 

Radiation Safety Technician (RST) 

(entry) 

Perform monitoring and sampling; collect samples; assist 

RST in monitoring personnel 1a 

RST 

Perform monitoring and sampling; collect samples; 

perform radiation and contamination surveys; conduct 

surveillance work 

1 

RST (Senior) Respond to contamination or radiation alarms; perform 

surveillance, monitor radiation conditions in workplace 1 

Firing Site Technician Includes hydroshot operators, driver, anyone involved 

with cleanup of hydroshot contamination 1 

Not known, possibly drivers or 

teamsters 

Includes burning of HE and cleanup of ash at burning 

ground 1 

Material Handler (pits and cans) Operate material handling/moving equipment; transport 

material; load and unload materials and containers 2 

Operations Manager, Production 

Supervisor 

Supervise personnel engaged in manufacturing, assembly, 

packaging, material control, etc. 2 

Quality Control Inspectors/ 

Auditors 

Conduct special audits; different from quality assurance 

technicians 2 

Security, protective force, guard Perform per job title 2b 

Engineer, engineering Perform variety of tasks associated with design, testing, 

procedure development 2c 

Machinist Machining on DU for one weapon design only 

See Section 5.2.2.4 of 

ORAUT-TKBS-0013­

5 

Metrology laboratory staff Perform nonradiological metrology calibrations Environmental only 

Fireman Perform per job title Environmental only 

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Table 7-1: Pantex Job Titles and Job Descriptions with the Possibility for Occupational Intake 

Table 7-1 spans two pages. 

Job Title Work Description Possibility for Intake 

(1 highest)a 

Computer Programmer, Electronic 

Data Processing Analyst Perform computer programming, maintenance Environmental only 

Secretary, Administrator, Technical 

Writer, Non-operations 

Management, Planner 

Perform per job title Environmental only 

Tool and Dye Maker Perform per job title Environmental only 

Food Service Perform tasks associated with operation of cafeteria Environmental only 

Stores Stockman, Clerk, Supervisor Perform tasks associated with general stores Environmental only 

Notes: 

a.	 Based on actual contact with components, contamination, or RSTs assisting potentially contaminated personnel. 

b.	 In general, security personnel had little chance of intakes; however, some small intakes from contamination in cells or 

igloos were possible. The default assumption is to place security personnel in Category 2, but Environmental only 

intakes may be assumed in cases where the security personnel tasks did not involve entry into cells, Gravel Gerties, 

igloos, or locations with resuspended contamination. 

c.	 Engineering tasks covered a wide range, and most had no potential for intakes. However, some tasks might have 

involved observations during assembly or disassembly work or observations during hydroshots. Environmental only 

intakes may be assumed in cases where the engineering personnel were not considered radiological workers (i.e., were 

not assigned to wear dosimeters or had no recordable dose). 

The following subsections address the ability to bound internal doses, methods for bounding doses, 

and the feasibility of internal dose reconstruction for all employees working at the Pantex Plant from 

January 1, 1951 through December 31, 1991. 

7.2.1 Evaluation of Bounding Operational Internal Monitoring Data 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation. Although 

the evaluation period for this report is through December 1991, when looking at intakes and resulting 

doses during various time increments, data and other references after 1991 were used to estimate 

doses up through 1991. For this reason (even though times are stated to 1991), data on other 

references to support the basis of the analysis may be after 1991. 

7.2.1.1 Urinalysis Information and Available Data 

Uranium: During most of the history of Pantex, uranium bioassay was event-driven. All records 

related to bioassay were reviewed and evaluated in ORAUT-TKBS-0013-5. Most uranium exposure 

data are for DU; however, the Pantex-produced Internal Dosimetry Technical Basis and Quality 

Assurance Document mentions natural uranium (Pantex Plant, August 2001). Uranium contamination 

at Pantex is either uranium metal or air-oxidized uranium from assembly and disassembly or from 

DU-contaminated HE components at the burn pads and explosion of DU during hydro tests. The data 

used for bounding doses is provided here and the methods used are summarized in Section 7.2.3. 

A review of new data obtained since the issuance of ORAUT-TKBS-0013-5 determined that uranium 

doses at Pantex are still bounded by the methods in ORAUT-TKBS-0013-5. No new additional 

bioassay data were obtained. 

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The most comprehensive set of depleted uranium intake data found in the Pantex records is related to 

a contamination incident in February 1989 (Radiation Protection Department, 1990). The bioassay 

data were analyzed at the Y-12 plant under state-of-the-art quality control requirements. Because this 

data set is large, of known high quality, and documents intakes from exposures that are expected to be 

above normal operational exposures, this data can be used for bounding potential uranium doses for 

assembly/disassembly workers belonging to the evaluated class. The bioassay samples were taken in 

late 1989 and early 1990, approximately one year after the contamination incident was identified. The 

document titled Historical Exposure Records System (HERS)-developed by the Delphi Groupe, Inc. 

(Radiation Protection Department, 1990) contains bioassay data from these urinalyses. This is the 

oldest set of data that provides isotopic determination of uranium alpha activity in urine samples, and 

it contains sufficient data to perform statistical analysis. 

Martin Marietta Energy Systems processed the bioassay samples at the Y-12 Plant Laboratory. The 

minimum detectable activity (MDA), 0.03 pCi per isotope per sample, was calculated from the 

formula in Health Physics Society American National Standard-Performance Criteria for 

Radiobioassay (HPS, 1996). The calculation included a 1,000-minute count, a detector efficiency of 

0.0985, and an average recovery of 75%. The average chemical recovery for the data for this incident 

was 70%. Recoveries less than 25% were considered not accurate due to counting statistics associated 

with low recoveries. A dose assessment was not provided with the data set. Data with a negative 

value indicated that the background was higher than the activity in the sample (Martin Marietta, 

1990). 

No bioassay data were found for Pantex workers involved in the burning of DU-contaminated high 

explosives or hydroshots; however, the doses can be adequately bounded by doses calculated from air 

sampling data (discussed below under Airborne Levels). 

Tritium: Interviews with former Pantex employees confirmed that when tritium containers arrived, 

detectable tritium contamination was possible (Personal Communication, April 8, 2008). From 1972 

to the present, Pantex has had a routine tritium bioassay program for workers (i.e., at-risk workers). 

Pantex monitored on a monthly basis and analyzed tritium bioassays onsite. In addition, one-twelfth 

of the worker population received a urinalysis each month. A review of 1972 through 1980 bioassay 

results helped identify a MDA, although actual documentation of the MDAs was not found (Mason & 

Hanger, 1972-1984). For 1972, records show a consistent use of 0.25 μCi/L as a less-than value 

(Mason & Hanger, 1972-1984). 

The available tritium monitoring data was statistically analyzed and adjusted to apply current dose 

methods. From available procedures, program reviews, and interviews conducted, it is evident that 

Pantex tritium monitoring has been appropriately focused on workers with the highest likelihood of 

exposure. As such, the data obtained from this monitoring can be used to bound tritium doses for all 

Pantex workers. Methods detailing the application of this data to monitored and unmonitored workers 

are provided in ORAUT-TKBS-0013-5. 

In addition to information previously considered in ORAUT-TKBS-0013-5, additional bioassay data 

(found since the TBD was issued), were reviewed (Pantex Plant, 1962-1971). Tritium urinalyses were 

conducted in 1960 through 1971 using a T series airborne monitor fitted with a kit for aerosolizing 

tritium from a urine sample. Sampling was conducted on about 10 workers per month who were 

judged to be at highest risk for tritium exposure. The intent was to provide a relatively insensitive 

check on the workplace exposure conditions; doses apparently were not calculated. Because of the 

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insensitivity of the method for urinalysis, these data show that general monitoring was conducted 

during this period and corroborates that the approach using the post-1971 data is bounding; however, 

the results were not used by NIOSH in the development of the dose reconstruction method for Pantex 

workers. 

Plutonium: Bounding doses from plutonium can be calculated for Pantex employees. However, these 

calculations are not based on bioassay data obtained from the evaluated timeframe. Section 7.3 of this 

evaluation addresses the methods used for bounding doses. 

There is a very limited amount of bioassay data for plutonium found in the documents captured by 

NIOSH (see Attachment One). As discussed in Section 5.2 of this evaluation, this is because 

plutonium was in the encapsulated pits of the nuclear weapons and strict workplace monitoring 

practices were in place to ensure the integrity of the encapsulation, including contamination smear 

checks during assembly and disassembly (Pantex Plant, August 2001). Interviews with former and 

current Pantex staff validate the assumption that exposure to plutonium was carefully controlled 

(Personal Communication, April 8, 2008). 

Although no documented trigger levels for bioassay were found for the time between 1958 (the time 

when plutonium was introduced at Pantex) and the early 1990s, it appears that bioassay was 

performed whenever there was an indication of contamination on the weapons or if the continuous air 

monitors had positive results (Personal Communication, April 8, 2008; Personal Communication, 

April 7, 2008). 

The potential for plutonium internal exposures has been minimal at Pantex, and therefore routine 

bioassay was not performed; exposure to plutonium would have been acute rather than chronic. 

Bioassay was performed and analyzed offsite when an incident occurred that might have resulted in an 

intake of plutonium. Bioassay results were found for the years 1961 (an incident of known plutonium 

release), 1963, 1966, 1968, the early 1980s, and 1994 to the present. Doses were not found for all 

years during the 1960s; this is probably because the prevailing recording level was not reached. 

Thorium: Bounding doses from thorium can be calculated for Pantex employees. However, these 

calculations are not based on thorium bioassay data from the NIOSH-evaluated timeframe. When 

ORAUT-TKBS-0013-5 was prepared, information indicated that thorium was not onsite until 1980. 

New information indicates that thorium was onsite as early as the 1960s. Section 7.2.3 of this 

evaluation addresses a methodology for assessing a bounding dose for thorium using uranium data for 

time periods before and after 1980. 

As with plutonium, Pantex used strict workplace thorium monitoring practices, such as smear checks 

of components, to verify the integrity of the thorium. Bioassays would only be taken if there was 

evidence that a contamination event had occurred. There is no evidence that workers potentially 

exposed to thorium were routinely monitored. 

7.2.1.2 Airborne Levels 

As described in ORAUT-TKBS-0013-5, air monitoring or sampling data have not been directly 

utilized for reconstructing doses for tritium, plutonium, or thorium for Pantex Plant dose 

reconstruction, but has been used for reconstructing some uranium exposures. In many cases, there 

are numerous sources of air sampling and monitoring data that demonstrate that there was no (or very 

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little) surface or airborne contamination in the work place. If an upset condition existed, the need for 

bioassay was evaluated in accordance with the Pantex Radiological Program requirements. 

Air samples taken from the burning grounds are available for bounding doses to workers present in 

that work area. The burning grounds have operated since 1952 (DOE, 1997). Air sample results from 

the burning grounds cover 1960 to 1967, with no results for 1963 (Pantex Plant, 1959-1967). Two 

categories of results are listed: during burning and during clean-up. Some results are recorded as 

disintegrations per minute per cubic meter and others as counts per minute. For air samples taken 

during burning, 24 were listed as zero or background, nine had results that ranged from 4 to 112 

dpm/m3

, and 17 had non-zero results in counts per minute (in the logs, the results are written as 

d/m/m3

) (Pantex Plant, 1959-1967). Section 7.2.3 summarizes the methods used to determine the 

bounding doses at the burning grounds. 

As with the burning grounds, air monitoring data at the firing sites can be used to bound the doses to 

those workers. Pantex has used firing sites for HE quality control and research since 1952. Some of 

the test firings at Firing Sites 4, 5, and 10 involved DU through 1985 (DOE, 1997; Mason & Hanger, 

1990, Chapter 7). According to a former employee who worked at the firing sites from 1959 to 2000 

and was supervisor of the firing site since 1960, the first hydroshot that involved DU occurred in late 

1959 or 1960 (Personal Communication, October 11, 2006). 

 The analysis in ORAUT-TKBS-0013-5 found data providing air concentrations inside and outside the 

bunker at Firing Site 4 for October 1959 to January 1962 (Pantex Plant, 1959-1967). The data list 94 

results for inside the bunker and 79 results for outside. Eighty-five percent of the results are recorded 

as 0 dpm/m3 with the lowest non-zero value recorded as 1 dpm/m3 (only one significant figure was 

recorded). Additional air sample data for Firing Site 5 in 1973 were found. Those air sample 

concentrations were compared to the 1960s concentrations and were less at both the median and 95th 

percentiles. The method used to bound doses is addressed in Section 7.2.3. 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses 

The ambient environmental dose would be accounted for by the available operational personnel and 

area monitoring data. Additionally, a thorough evaluation of environmental dose assignment to 

Pantex workers has been demonstrated and provided in ORAUT-TKBS-0013-4. Therefore, further 

evaluation of this dose was not performed as part of this evaluation. 

7.2.3 Methods for Bounding Internal Dose at the Pantex Plant 

Uranium: As mentioned previously, assembly and disassembly line workers represent a group of 

Pantex workers whose uranium exposure potentials are expected to be as high as or higher than other 

employees at the Pantex Plant. Although in some cases these workers do not have bioassay data in 

their records (presumably because they were not involved in contamination incidents determined to 

involve intake potential), data are available for use to bound internal uranium doses for the evaluated 

class. NIOSH has described (in Section 5.2.2.3.1 of ORAUT-TKBS-0013-5) the details of the 

analysis of the available 1990 uranium urinalyses collected as a result of a contamination incident. 

ORAUT-TKBS-0013-5 addresses how this data can be used to conservatively bound doses to 

appropriate employees, including assembly/disassembly workers, RSTs, and Quality Assurance 

technicians. In addition, a summary of default intakes is also provided in Table 7.2 of ORAUTTKBS-0013-5. 

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When bioassay data are available to assess intakes for workers whose jobs had a lower potential for 

intake, but who might have had incidental exposure to contamination from disassembly activities, an 

adjusted dose based on a percentage of the intake to maximally exposed monitored production 

technicians can be assigned. 

Depleted Uranium Intakes from Burning of Contaminated High Explosives: There were no 

bioassay data found that could be attributed to burning HE. However, intakes can be determined and 

bounded using available air sample results and additional assumptions related to intake. Section 

5.2.2.5 of ORAUT-TKBS-0013-5 details how to assess intakes from burning of contaminated HE. 

Because the employees that worked at the burning sites were likely different than the 

assembly/disassembly workers, it is necessary to consider a separate dose bounding approach for this 

set of workers. The summary of doses can also be found in Table 7.2 of ORAUT-TKBS-0013-5. 

Intakes from Hydroshots: No bioassay data were found that could be attributed to intakes from 

hydroshots; however, bounding intakes can be determined using available air sample results and 

additional assumptions related to intake. Section 5.2.2.6 of ORAUT-TKBS-0013-5 explains how to 

conservatively assess intakes from hydroshots. Because the employees that worked at the firing sites 

were likely different than the assembly/disassembly workers, it is necessary to consider a separate 

dose bounding approach for this set of workers. A summary of doses can also be found in Table 7.2 

of ORAUT-TKBS-0013-5 

Tritium: ORAUT-TKBS-0013-5 addresses tritium in four periods: 1956 to 1971; 1972 to 1982; 1983 

to 1988; and 1989 to present. In addition, recent reviews addressed exposure to metal tritides. The 

assessment of metal tritides revealed that the doses would be very small (less than 1 mrem per year), 

and therefore does not impact the bounding doses in the previous analysis. 

The discussion that follows summarizes how the bounding doses for tritium were calculated in 

ORAUT-TKBS-0013-5. Review of new data obtained since the effective date of ORAUT-TKBS0013-5, June 22, 2007, confirms that the dose reconstruction methods addressed in ORAUT-TKBS0013-5 are suitable for bounding potential exposures to tritium for this proposed class. 

The most complete set of tritium information consists of maximum and average doses for 1972 to 

2001 (Table 5-3 in ORAUT-TKBS-0013-5). Because tritium doses rather than actual bioassay results 

were found in the worker files, methods to convert from recorded dose to uptake (for input into IMBA 

or the tritium tool) were used to determine bounding doses. ORAUT-TKBS-0013-5 provides the 

details for assigning dose to workers for the following: 

• Tritium intake from dose records, 1972 to 1982 

• Tritium intake for missed dose and unmonitored workers, 1956 to 1971 

• Tritium intakes, 1983 to 1988 

• Tritium intakes, 1989 to Present 

• Tritium missed dose, 1972 to 1988 

• Tritium missed dose, 1989 to Present 

• Unmonitored workers, 1956 to 1971 

• Unmonitored workers, 1972 to Present 

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Because the data from the T series of air monitors adapted for analysis of urine was too insensitive, all 

workers prior to 1972 were considered unmonitored. However, because few disassemblies occurred 

during the early period compared to the 1972 through 1982 time period, and because the reservoirs 

were newer, assigning a dose to all category 1 (from Table 7-1) workers of twice the maximum dose 

observed from the 1970s results is assumed to be conservative and bounding. 

ORAUT-TKBS-0013-5 also addresses assigning doses to the four employees involved in the tritium 

release event that occurred in 1989. Because there was only one individual that had an acute tritium 

exposure, other workers are given the dose from the event assessed as environmental dose. 

Unmonitored Workers: When bioassay data are available to assess intakes for workers whose jobs 

had a lower potential for intake, but who might have had potential incidental exposures associated 

with tritium, an adjusted dose based on a percentage of the intake to maximally exposed monitored 

individuals can be assigned. 

Plutonium: In assessing doses from plutonium, because the pits were sealed, and incoming shipments 

were monitored for contamination upon arrival and at several stages during the assembly or 

disassembly, it was assumed that exposure to plutonium would be acute rather than chronic and that 

the potential for intake was rare. As mentioned in 7.2.1.1, because plutonium bioassay monitoring 

was driven by workplace monitoring that indicated possible contamination spread, routine plutonium 

bioassay monitoring was not performed until very late in the history of the plant, and only limited 

data are available for plutonium bioassay from the evaluated timeframe. There were no recorded 

doses associated with 106 bioassays collected from 1991 to 2003. 

Because intakes were rare, for the period 1992 to 2000 (1991 for the evaluated class), the criterion for 

investigation of possible acute intake (including obtaining special bioassay) can be used to support 

establishing bounding intake estimates for the proposed worker class evaluated in this report. During 

this period, when the number of disassemblies was highest and the plutonium was oldest, the criterion 

for investigation was any workplace indicator, indicating that an intake of 40 DAC-hour (290 pCi) 

might have occurred. These intakes can be assigned to the workers with the highest exposure 

potential as the mode of a triangular distribution with a minimum of zero and a maximum of 10 times 

the mode. The factor of 10 for the upper limit of the distribution is set to account for the possibility of 

more than one intake per year and the possibility that the air-sampling system is not representative. 

The bounding intake for the period from 1991 through 2000, therefore, is 400 DAC-hr (2900 pCi, 

acute intake) per year of employment for the high-risk tasks. 

The Pantex Internal Dosimetry Technical Basis and Quality Assurance Document states that 

plutonium at Pantex should be considered an aged weapons-grade mixture. The intake activities are 

for the total alpha activity of the mixture. For the purpose of bounding the plutonium dose, a 20-year 

aged mixture, inhalation Type S, can be assumed (ICRP, 1994) because the source is aged plutonium, 

oxidized from the metal state. 

For the period from 1958 (the year that plutonium was introduced to Pantex) to 1991 (except 1961, as 

discussed below), air sample levels that would have triggered bioassay are not known; however, fewer 

disassemblies occurred and the plutonium was newer, meaning that there was less potential for 

oxidation and therefore, personnel exposures to plutonium. Assemblies would have involved newly 

sealed plutonium metal. Consequently, the possibility of intakes and the severity of intakes would 

have been less. However, because the documentation of the number of disassemblies and the 

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contamination levels are not available, unmonitored workers may be assigned an intake that is the 

same as the intake from the 1991 to 2000 period. Hence, the bounding intake for the period from 

1958 to 1991 for this period is also 2,900 pCi, acute intake, per year of employment in the high-risk 

task. 

ORAUT-TKBS-0013-5 also addresses assigning doses for the workers involved in the 1961 Cell 

Incident, which produces the bounding doses for those specific workers. 

Thorium: Thorium at Pantex exists as thorium metal, thorium alloys, or materials impregnated with a 

thorium compound (see Section 5.2.1.4). Workers handle these forms during assembly and 

disassembly of certain weapons. Because of the relative hazard of thorium, Pantex has used and 

continues to use strict workplace monitoring practices, such as smear checks of components, to verify 

the integrity of the thorium components. It is assumed that workers could have encountered oxidized 

thorium components during disassembly of weapons. Pantex has never conducted machining of 

components containing thorium. 

From 1980 to present, the methods for assigning intakes of thorium are the same as for plutonium 

because of similar workplace conditions. Specifically, there were fewer disassemblies containing 

thorium; thus, the plutonium methods are claimant favorable for thorium. The following summarizes 

the method provided in ORAUT-TKBS-0013-5 for bounding doses from thorium for this period. 

For workers who had the highest possibility of intake for each year from 1980 to 1991, a single acute 

intake of 40 DAC-hr (48 pCi) of Th-232 (in equilibrium with progeny) was assumed. For Category 2 

workers in Table 5-2 of ORAUT-TKBS-0013-5, 0.1 times the intake was assigned. These intakes are 

modes of triangular distributions with a minimum of zero and a maximum of 10 times the mode to 

account for the possibility of more than one intake per year and the possibility that the air-sampling 

system is not representative. 

A check on the reasonableness of the above estimates was made by analyzing Th-232 bioassay results. 

Two hundred fifty-eight worker urine samples were analyzed between 1992 and 1996 (Excel, 1991­

2005). Only one result arguably exceeded the detection level; the median of the distribution was 

0.000 pCi/L and the 95th percentile was 0.004 pCi/L (less than detectable). One hundred fifty-one 

worker fecal samples were analyzed between 1996 and 2000 (Excel, 1991-2005). About half were 

above the analytical detection level, but only four exceeded the expected natural excretion of 

approximately 0.32 pCi/d (ICRP, 1975). An acute intake of 48 pCi would result in less than 0.32 

pCi/d excretion over about six days after the intake, so the intake estimate above and the fecal data 

agree reasonably well. 

Prior to 1980 there is evidence of one disassembly involving thorium in a similar manner as DU. 

Because DU contamination and thorium contamination would have been in the oxide form and 

behaved similarly in the workplace on a mass basis (including mass loading in the air), it was assumed 

that the bounding intakes for inhalation Type S and insoluble ingestion of thorium oxide were the 

same as the bounding intakes for DU on a mass basis. When default Type S DU inhalation intake of 

19 pCi/d is converted to mass, equated to the mass of Th-232, and converted to the activity of Th-232, 

the intake of Type S Th-232 is 5.2 pCi/d. Similarly the ingestion intake of insoluble Th-232 is 12 

pCi/d. Equilibrium of progeny with the Th-232 is assumed. Because thorium components were rarer 

than DU components, the assumption of daily intake is bounding. 

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Radon: The assessment of radon doses looked at actual measurements taken at Pantex in 1969 and 

1990 (McFall, 1969; UNC Geotech, 1990). The 1990 data resulted in slightly higher values than the 

1969 data; thus, the 1990 data were used for the assessment. The equilibrium factor was revised as 

described below. 

A value of the equilibrium factor F is often an assumed value of 0.4 in homes, as recommended by the 

ICRP (1981) and the United Nations Scientific Committee on the Effects of Atomic Radiation 

(UNSCEAR, 1993). UNSCEAR (1988, Annex A) reports an extensive analysis of equilibrium 

factors, noting that at more than 0.6 air changes per hour, the average was 0.33, while for less than 0.6 

air changes per hour, the average was 0.51. UNSCEAR (1988) also reports that equilibrium factor 

drops dramatically with decreasing ambient aerosol concentration, so that the cleaner the air, the lower 

the equilibrium factor. This lower equilibrium factor is correlated with higher unattached fractions, 

which lead to rapid plate-out (UNSCEAR, 1988). The DOE reviewed equilibrium factors outdoors 

and in homes, workplaces, underground uranium mines, and other underground mines (DOE, 1999). 

The only non-mine workplaces reported there were turbine buildings at nuclear power plants, which 

had relatively low equilibrium factors of 0.30. Uranium mines had average equilibrium factors of 

0.27, but have high air-exchange rates to minimize radon concentrations. Non-uranium mines had 

average factors of 0.55, ranging from 0.3 to 0.7. 

Air exchange rates in cells and bays were not made available to NIOSH, nor are there any 

measurements of equilibrium factors at Pantex in the 1969 and 1990 surveys. The clean air needed for 

the kind of work performed in underground cells and bays at Pantex would argue for a low 

equilibrium factor. However, in the absence of any Pantex-specific information, a conservatively high 

value of equilibrium factor must be chosen. The Pantex-measured radon concentrations were 

converted to equilibrium-equivalent concentrations by multiplying the radon concentration by an 

equilibrium factor of 0.8, greater than almost any observed indoor value. The remote possibility that 

F could be greater than 0.8 is accounted for in the use of a lognormal uncertainty with a geometric 

standard deviation (GSD) of 3. 

Workers in earthen or underground buildings were assigned radon intakes using the median value for 

earthen or underground buildings from the higher 1990 measurements, 0.8 for the equilibrium factor, 

with a GSD of 3 which exceeds the measured GSD of 2.5. Using actual measurement data combined 

with conservative assumptions provides a method to bound the intakes from radon for workers in 

earthen or underground buildings. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

Based on available data and the re-evaluation of the hundreds of documents in the SRDB related to 

Pantex, specifically in the area of internal dose, NIOSH concludes that the methods described in 

ORAUT-TKBS-0013-5 provide reasonable approaches to conservatively bound doses for all members 

of the class under evaluation. New information, revealed since the TBD was issued, confirms that 

internal dose assessment was performed on an appropriate, as-needed basis. As proven based on the 

available program documentation, the Pantex Plant operations were performed under strict 

radiological cleanliness controls and continually performed workplace monitoring to determine 

whether contaminated weapons were brought onsite or in the case of an inadvertent release of 

radioactive materials. 

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7.3 Evaluation of Bounding External Radiation Doses at the Pantex Plant 

ATTRIBUTION: Section 7.3 and its related subsections were completed by Jerome Martin, Dade 

Moeller and Associates. These conclusions were peer-reviewed by the individuals listed on the cover 

page. The rationales for all conclusions in this document are explained in the associated text. 

The principal sources of external radiation doses for members of the proposed class were plutonium 

pits and depleted uranium and thorium components. Secondary sources of external exposure included 

other radioactive materials present in smaller quantities (typically microcurie levels) as calibration 

sources or in larger quantities (up to curie levels) as radiography sources (ORAUT-TKBS-0013-2). 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding Operational External Monitoring Data 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the class under evaluation. 

7.3.1.1 Personnel Dosimetry Data 

As required by AEC/ERDA/DOE regulations, Pantex provided dosimeters for measuring external 

radiation exposures to workers (AEC, 1958). Pantex Safety Standard 321 specified that dosimeters be 

assigned to all workers who had the potential to exceed 10% of the Radiation Protection Guideline 

(RPG) in effect at the time (Phillips, 1963; Personal Communication, April 7, 2008; Personal 

Communication, October 8, 2003). The dosimeters that were assigned were considered state-of-theart dosimeters that were supplied by a qualified commercial service (National Bureau of Standards, 

1955). Dosimetry records documented the names and/or badge numbers of the workers monitored 

along with their periodic exposure results. All of these records are maintained by the Radiation Safety 

Department, both in hardcopy and electronically in DoRMS (ORAUT-TKBS-0013-6). 

Photon 

Primary photon-emitting radioactive materials used at Pantex included uranium, thorium, americium, 

and plutonium. 

Since first used, the film badges and TLDs assigned at Pantex have been capable of measuring photon 

exposures in the workplace with sufficient accuracy to permit the calculation of bounding photon 

exposures. There is strong evidence that workers who had the highest potential for radiation exposure 

were monitored with state-of-the-art dosimeters (National Bureau of Standards, 1955) and the 

measured photon doses were reasonably accurate and complete (ORAUT-TKBS-0013-6). Dosimetry 

records maintained by the Radiation Safety Department have been independently reviewed by the 

HERS project to verify accuracy and to ensure complete documentation (Rawlston, 1991). 

The dosimeter technology and the dosimeter responses as a function of photon energy are described in 

Section 6.5.2 of ORAUT-TKBS-0013-6, where NIOSH demonstrates that the responses adequately 

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support dose calculations for the energies associated with the work performed at Pantex. Table 6-17 

of ORAUT-TKBS-0013-6 lists the maximum individual photon dose by year. If these maximum 

doses are adjusted for missed dose and the dosimeter uncertainty correction factor, they represent the 

bounding photon doses. As discussed in the available Pantex radiological monitoring program 

documentation, personnel with the potential for exposures to exceed AEC exposure guidelines, as 

described in Pantex Radiation Protection procedures, were selected for monitoring; therefore, NIOSH 

has concluded that these doses will serve to bound any potential external exposures to unmonitored 

workers at Pantex. It is NIOSH’s view, based on the previously stated information regarding the 

Pantex monitoring program and available data, that sufficient data are available to support the 

establishment of bounding photon doses to the proposed class in this evaluation. 

Beta 

The film badges and TLD used at Pantex were designed to detect beta exposures through the open 

window of the badge holder. Beta doses measured in the workplace were generally low, unless very 

close work was being performed (ORAUT-TKBS-0013-6). The main reason that higher beta doses 

were not recorded is that beta dose rates decrease rapidly with distance from a source and dosimeters 

were worn on the upper torso, approximately one foot or more from the source. It is possible that beta 

doses to the hands and arms were higher than those recorded for the whole-body for some workers in 

some circumstances. Therefore, the recorded beta doses are not necessarily bounding. A method for 

estimating bounding beta doses is addressed in Section 7.3.4 of this evaluation. 

Neutron 

Plutonium and highly-enriched uranium pits emit fast neutrons. The neutron emission rate is a 

function of the mass of fissionable material and specific design features. Neutron radiation fields are 

discussed in more detail in Section 6.5.4.3 of ORAUT-TKBS-0013-6. 

Prior to 1977, neutron doses were measured by NTA film; however, NTA film underestimates, and 

therefore does not reliably measure, neutrons with energies less than 500 keV. The six-element inhouse TLD system used from 1977 to 1980 responded well to thermal neutrons, but it underresponded to neutrons above 10 keV (DOE, 1977); thus, this system did not measure a significant 

fraction of the neutrons in the Pantex workplace during that timeframe. The response of the 

Panasonic UD-802 TLD to thermal and fast neutrons was measured (Robertson, 1983) using a bare 

and moderated californium-252 source. These measurements showed that the UD-802 significantly 

under-responded to fast neutrons. The data currently available to NIOSH does not permit 

quantification of the amount that neutron doses are underestimated in these cases/situations for the 

many varied neutron radiation fields and spectra during the associated time periods. Therefore, all 

available personnel monitoring neutron doses measured before 1993 are likely to underestimate the 

associated neutron exposure and therefore are not considered reliable for the purpose of dose 

reconstruction under this radiological dose reconstruction program. The Department of Energy 

Laboratory Accreditation Program (DOELAP) accredited the Panasonic UD-809/UD-812 TLD 

system in 1993 for all neutron categories applicable at Pantex. Neutron doses measured at Pantex 

since this time with this new system are considered reliable for use in this radiological dose 

reconstruction program, and these measurements provide a basis for using neutron-to-photon dose 

ratios to permit estimating worker neutron doses for the periods prior to the accreditation. Based on 

NIOSH’s review and evaluation of the weapons systems handled at Pantex, and the assembly of the 

list that permits comparison across all times associated with this evaluation, NIOSH is able to 

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establish that the neutron-to-photon dose ratios, applied to bounding photon doses, result in calculated 

neutron doses that are considered bounding across all time periods. The method used to bound 

neutron doses is addressed in Section 7.3.4. 

7.3.1.2 Area Monitoring Data 

Beginning in 1959, area monitor film badges were used to continuously measure radiation exposure 

doses in specific areas of concern, including assembly cells and vaults. The use of area monitor 

dosimeters continued for many years and the records from these dosimeters are available in the 

Radiation Safety Department files. The data from these dosimeters were used by the Radiation Safety 

Department to help determine which work areas had potential for significant exposure to workers. 

Area monitoring dose data represent an option to estimate unrealistically high bounding personnel 

radiation doses. 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses 

A thorough evaluation of the ambient environmental dose, applicable to the performance of individual 

dose reconstructions, for Pantex has been provided in ORAUT-TKBS-0013-4. However, for the 

purpose of this SEC evaluation, the Pantex ambient environmental dose would be accounted for, and 

bounded from, the occupational monitoring data for personnel working at the Pantex site; therefore, 

further evaluation of ambient environmental dose is not necessary or included in this evaluation. 

7.3.3 Pantex Plant Occupational X-Ray Examinations 

Pantex required pre-employment and routine physical examinations as part of its Occupational Health 

and Safety program. The Medical Department maintained a log for each worker of what appears to be 

all X-ray examinations. An inspection of the logs for selected long-term workers showed that there 

were no consistent patterns in the frequency of their examinations. Based on this inspection, practices 

apparently varied among workers, probably based on occupation and job responsibilities. Table 7-2 

summarizes these variations and makes conservative assumptions that give bounding doses. 

Additional details are provided in ORAUT-TKBS-0013-3. 

Table 7-2: Pantex Plant Worker X-ray Examinations 

Time Period Examination Type Frequency Default Dose Reconstruction Recommendation 

1952-1981 

Posterior-anterior 

(PA) Chest 

For all workers, preemployment and annually The log of X-ray examinations can be used to identify 

occupation-related examinations for PA chest, AP 

lumbar spine, and LAT lumbar spine examinations. If 

specific log data is not available, pre-employment PA 

chest, AP lumbar spine, and LAT lumbar spine 

examinations, as well as annual PA chest 

examinations will be assumed. 

Anterior-posterior 

(AP) Lumbar spine 

For male workers, preemployment 

Lateral (LAT) 

Lumbar spine 

For male workers, preemployment 

1982 - 2004 PA Chest 

For all workers, preemployment and every 5 

years. 

The log of X-ray examinations can be used to identify 

occupation-related PA chest examinations. If specific 

log data are not available, pre-employment PA chest 

and an examination every 5 years will be assumed. 

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7.3.4 Methods for Bounding External Dose at the Pantex Plant 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon Dose 

• Beta Dose 

• Neutron Dose 

Photon Dose 

Photon doses for monitored workers have been measured with state-of-the-art dosimeters throughout 

the history of Pantex (see section 7.3.1.1 of this evaluation). Additionally, Pantex employees 

performing duties with the highest exposure potentials have consistently been monitored when 

performing their duties (Personal Communication, April 7, 2008; Personal Communication, October 

8, 2003). The resultant monitoring data have been retained over the entire course of the evaluated 

class timeframe, and as such, these data permit estimation of bounding photon doses for the NIOSHevaluated class. 

As discussed, the available data associated with monitored workers can be used to bound the 

unmonitored workers because unmonitored workers had lower exposure potential positions. NIOSH 

has, however, analyzed the database of monitored worker photon dose data (Strom, unknown date) to 

provide statistically valid dose values that can be assigned to unmonitored workers, who would have 

been monitored by today’s standards. It is recommended that doses be assigned to unmonitored 

workers that are equal to the arithmetic mean dose for monitored workers for each year of 

employment, as the results of this analysis can be used to assign doses that are more precise than a 

bounding value for unmonitored workers. 

Beta Dose 

Monitored workers exposed to beta-emitting components could have received external beta doses that 

would have been measured by film badges and TLDs. However, the beta dose from depleted uranium 

decreases rapidly with distance from the surface, so that in many cases the beta dose measured may 

have been less than the limit of detection (LOD). If a claimant’s records show zero or no reported 

dose for a monitoring period, a missed dose can be assigned based on the LOD/2 method (OCAS-IG001). 

As discussed above for beta and photon dose, the available data associated with monitored workers 

can be used to bound the unmonitored workers because unmonitored workers were not monitored due 

to their lower exposure-potential positions. As was the case in the photon evaluation, NIOSH has 

analyzed the database of monitored worker beta dose data (Strom, unknown date) to provide 

statistically valid dose values for assignment to unmonitored workers. Beta doses equal to the 

arithmetic mean of beta doses for monitored workers can be assigned to unmonitored workers for each 

year of employment, as the results of this analysis can be used to assign doses that are more precise 

than a bounding value for unmonitored workers. 

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Neutron Dose 

Photon doses (with appropriate corrections for lead apron use and dosimeter response uncertainty) 

were reliably measured from 1994 forward and can be used with a neutron-to-photon dose ratio of 1.7 

to calculate neutron doses for the years prior to 1994 (ORAUT-TKBS-0013-6; Strom, unknown date). 

The average neutron-to-photon dose ratio determined from reliable collective neutron and photon 

doses measured since 1994 is only 0.25 (see Table 6.1 in ORAUT-TKBS-0013-6). Thus, this method 

for calculating neutron doses prior to 1994 will result in average neutron doses to workers that are 

approximately 6.8 times the expected doses, which will be bounding (ORAUT-TKBS-0013-6) for the 

class evaluated in this report. 

Typically, there should not be a significant neutron exposure to unmonitored workers. However, for 

an unmonitored worker with some evidence of potential neutron exposure, neutron doses can be 

estimated by applying a median neutron-to-photon dose ratio of 0.8 as determined by the log 

probability analysis of grouped Pantex and neutron dosimeter data, as determined by Strom. This 

median value, when applied to the assigned photon dose for monitored workers, will yield a bounding 

neutron dose to unmonitored workers. 

An alternate method has been developed for conservatively estimating missed neutron doses. Neutron 

and gamma dose-rates associated with various weapon configurations are available for LANL and 

LLNL-designed nuclear weapons systems handled at Pantex. Dose-rate data for individual weapons 

have been located at Pantex to cover the weapon configurations encountered during assembly and 

disassembly operations. These dose-rate data, coupled with the exposure times derived from timeand-motion studies of the nuclear explosive operations, allow the calculation of exposure-time 

weighted neutron-to-photon dose ratios. Using the neutron-to-photon dose ratios, the missed neutron 

doses can be estimated based on the measured photon doses and assigned to the personnel performing 

the nuclear explosive operations. These data allow determination of bounding neutron doses. 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

The data sources for photon, beta, and neutron doses, as well as occupational X-ray examinations and 

ambient environmental external doses (ambient environmental dose accounted for in the available 

personnel monitoring data), have been examined and found to be adequate for bounding external 

doses for the Pantex proposed worker class evaluated in this report. The measured photon dose data, 

with appropriate corrections for lead apron use and dosimeter response uncertainty, provide reliable, 

bounding photon doses. The available beta-dose data can also be used to calculate/establish bounding 

beta doses. A conservative neutron-to-photon dose ratio, based on reliable neutron monitoring data 

and information regarding the weapons systems over the years of Pantex operation, and coupled with 

the application of the bounding photon doses, permit bounding the neutron doses. The available 

medical X-ray information, monitoring types, and monitoring frequencies support the ability to bound 

the medical X-ray dose. The bounding doses for monitored workers can be used with co-worker study 

statistics to assign bounding doses to unmonitored workers because the monitored workers are 

considered the maximally exposed work group within the proposed worker class (based on historical 

Pantex radiological program documentation). The combination of these dose calculation methods 

makes it feasible to bound the external dose (reconstruct the dose with sufficient accuracy) for the 

Pantex proposed worker class evaluated in this report. 

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7.4 Evaluation of Petition Basis for SEC-00068 

The following subsections evaluate the assertions made on behalf of petition SEC-00068 for the 

Pantex Plant. 

7.4.1 Unmonitored Workers 

ATTRIBUTION: Section 7.4.1 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

SEC-00068: One argument we make is that too few workers were monitored for statistical purposes 

for generalizations to the rest of the workforce to be valid. Until 1979 the majority of the Pantex 

workforce went completely unmonitored. The assumption that the most exposed workers were 

monitored was found not to be valid at IAAP, as above, and is likely not valid at Pantex. 

NIOSH has obtained credible information stating that prior to 1988, Pantex issued dosimeters only to 

workers likely to receive 10% or more of the radiation protection guidance. There is also strong 

evidence that a majority of the workforce was not exposed to radiological sources during that time 

period. From 1952 through 1957 the number of badged workers was particularly low, as industrial 

radiography and medical X-rays were the only significant sources of radiation exposure onsite during 

that time. Variations in the number of badged radiation workers from 1958 through 1988 reflect 

changes in weapons productions rates and the quantity of radioactive materials present onsite. 

Reviews conducted of the Pantex Plant health protection and monitoring programs have repeatedly 

found that monitoring levels are consistent with exposure potentials. Interviews with Pantex safety 

officers and health physicists working within the class timeframe also supported a proper correlation 

between exposure potentials and monitoring levels. 

7.4.2 Effectiveness of the Health Protection and Industrial Health Programs 

ATTRIBUTION: Section 7.4.2 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

SEC- 00068: ... real questions regarding the efficacy of the HP and IH programs at this site as 

reflected by workers’ histories and the Tiger Team report. 

Excerpts from a 1990 ‘Tiger Team” report at the Pantex Plant relayed information related to (and 

critical of) the following: health physics support staffing levels and training; questions regarding 

quality assurance for radiation monitoring data; health and safety program inadequacies; the control of 

radioactive sources; maintenance of employee exposure records; contamination reports; and 

discussion of pre-employment or new employee baseline bioassay monitoring. 

Although the report contains information which indicated that the Pantex Plant radiological program 

was deficient in implementing DOE Order 5480.11 requirements, the report did not find that radiation 

exposures and radiation doses were not monitored, either through personal or area monitoring. With 

the exception of neutron monitoring, the Tiger Team review did not indicate that occupational 

exposure monitoring data obtained were deficient, inaccurate, or unsuitable for use in bounding doses 

to Pantex workers. 

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7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation 

ATTRIBUTION: Section 7.5 was completed by Tim Adler, Oak Ridge Associated Universities 

(ORAU). These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

During the feasibility evaluation for SEC-00068, an additional issue was identified that needed further 

analysis and resolution. The issue and its current status are: 

•	 ISSUE: Due to inadequacies in measuring devices used, all neutron doses measured before 1993 

are likely to be underestimated and unreliable. 

RESPONSE: Neutron doses measured at Pantex with a new system since 1994 are reliable and 

these measurements are suitable for use in bounding the doses received by Pantex workers. 

Photon doses (with appropriate corrections for lead apron use and dosimeter response uncertainty) 

were reliably measured and can be used with a neutron-to-photon dose ratio to calculate 

conservatively-bounding neutron doses for the years prior to 1994 (ORAUT-TKBS-0013-6). 

7.6 Summary of Feasibility Findings for Petition SEC-00068 

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

Plant from January 1951 through December 1991. NIOSH found that the available monitoring 

records, process descriptions and source term data available are sufficient to complete dose 

reconstructions for the evaluated class of employees. 

Table 7-3 summarizes the results of the feasibility findings at Pantex Plant for each exposure source 

during the time period of January 1, 1951 through December 31, 1991. 

Table 7-3: Summary of Feasibility Findings for SEC-00068 

January 1951 through December 1991 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal1

 X 

 - Uranium X 

 - Tritium X 

 - Plutonium X 

 - Thorium X

 - Radon X 

External X

 - Gamma/Photon X 

 - Beta X 

 - Neutron X 

 - Occupational Medical X-ray X 

Notes: 

1

 Internal includes an evaluation of available urinalysis (in vitro), airborne dust, and lung (in vivo) data. 

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As of August 1, 2008, a total of 357 claims have been submitted to NIOSH for individuals who 

worked at the Pantex Plant and are covered by the class definition evaluated in this report. Dose 

reconstructions have been completed for 244 individuals (~68%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00068 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

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

employees in the SEC. 

NIOSH’s evaluation determined that it is feasible to estimate radiation dose for members of the 

proposed class with sufficient accuracy based on the sum of information available from various 

resources. Modification of the class definition regarding health endangerment and minimum required 

employment periods, therefore, is not required. 

9.0 NIOSH-Proposed Class for Petition SEC-00068 

Based on its research, NIOSH accepted the petitioner-proposed class with a slight modification of the 

petitioner-requested definition (i.e., “worked in all facilities” was changed to “worked in any 

facility/location”) to define a single class of employees for which NIOSH can estimate radiation doses 

with sufficient accuracy. The NIOSH-proposed class includes all employees who worked in any 

facility/location at the Pantex Plant in Amarillo, Texas, from January 1, 1951 through December 31, 

1991. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00068. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

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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 that it would be feasible to reconstruct the dose for the class 

proposed in this petition. 

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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, Rev. 01; Office of 

Compensation Analysis and Support (OCAS); Cincinnati, Ohio; August 25, 2006; SRDB Ref ID: 

29929 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0; 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

OCAS-TIB-009, Estimation of Ingestion Intakes, Rev.0; Office of Compensation Analysis and 

Support (OCAS); Cincinnati, Ohio; April 13, 2004; SRDB Ref ID: 22397 

ORAUT-OTIB-0002, OTIB: Maximum Internal Dose Estimates for Certain DOE Complex Claims, 

Rev. 02; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; February 7, 2007; 

SRDB Ref ID: 29947 

ORAUT-OTIB-0006, OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; 

December 21, 2005; SRDB Ref ID: 20220 

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

01; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; October 11, 2005; SRDB 

Ref ID: 19434 

ORAUT-OTIB-0018, OTIB: Internal Dose Overestimates for Facilities with Air Sampling Programs, 

Rev. 01; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; August 9, 2005; SRDB 

Ref ID: 19436 

ORAUT-OTIB-0019, OTIB: Analysis of Coworker Bioassay Data for Internal Dose Assignment, Rev. 

00; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; December 29, 2004; SRDB 

Ref ID: 19439 

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ORAUT-OTIB-0049, OTIB: Estimating Doses for Plutonium Strongly Retained in the Lung, Rev. 00; 

Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; February 6, 2007; SRDB Ref ID: 

29975 

ORAUT-OTIB-0060, OTIB: Internal Dose Reconstruction, Rev. 00; Oak Ridge Associated 

Universities (ORAU); Oak Ridge, Tennessee; February 6, 2007; SRDB Ref ID: 29984 

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

Rev. 01; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; June 28, 2006; SRDB 

Ref ID: 29986 

ORAUT-PROC-0061, PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 02; Oak 

Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; January 2, 2008; SRDB Ref ID: 

39338 

ORAUT-TKBS-0013-1, TBD for the Pantex Plant – Introduction, Rev. 02; Oak Ridge Associated 

Universities (ORAU); Oak Ridge, Tennessee; May 11, 2007; SRDB Ref ID: 20152 

ORAUT-TKBS-0013-2, TBD for the Pantex Plant – Site Description, Rev. 02; Oak Ridge Associated 

Universities (ORAU); Oak Ridge, Tennessee; May 8, 2007; SRDB Ref ID: 20153 

ORAUT-TKBS-0013-3, TBD for the Pantex Plant – Occupational Medical Dose, Rev. 02; Oak Ridge 

Associated Universities (ORAU); Oak Ridge, Tennessee; February 1, 2007; SRDB Ref ID: 20154 

ORAUT-TKBS-0013-4, TBD for the Pantex Plant – Occupational Environmental Dose, Rev. 01; Oak 

Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; June 22, 2007; SRDB Ref ID: 20155 

ORAUT-TKBS-0013-5, TBD for the Pantex Plant – Occupational Internal Dose, Rev. 01; Oak Ridge 

Associated Universities (ORAU); Oak Ridge, Tennessee; June 22, 2007; SRDB Ref ID: 26727 

ORAUT-TKBS-0013-6, TBD for the Pantex Plant – Occupational External Dose, Rev. 01; Oak 

Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; June 22, 2007 SRDB Ref ID: 11068 

ORAUT-TRNG-0051, Dose Reconstruction Training, Rev. 03; Oak Ridge Associated Universities 

(ORAU); Oak Ridge, Tennessee; March 1, 2007; SRDB Ref ID: 38738 

AEC, 1958, Chapter 0524 Permissible Levels of Radiation Exposure, AEC manual effective February 

1, 1958; U.S. Atomic Energy Commission (AEC); 1958; SRDB Ref ID: 10678 

Alexander, March 1972, Analysis of Drone Sample from Hydro Shot, March 8, 1972; R. E. Alexander; 

March 14, 1972; SRDB Ref ID: 13316 

Alexander, May 1972, Fluorometric Analysis of Drone Samples Taken on April 27, 1972 and April 

28, 1972; R. E. Alexander; May 10, 1972; SRDB Ref ID: 13317 

Alexander, August 1972, Hydro Shots Analyses, memo includes data attachment for June/July 1972; 

R. E. Alexander; August 4, 1972; SRDB Ref ID: 13313 

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Alexander, 1973, Special Report on Possible 7.3 Rad Dose to [Name Two Redacted] During Period 

Covering July, August, and September, 1973; R. E. Alexander, J. M. Hess, and C. E. Canada; July 9, 

1973; SRDB Ref ID: 11511, pp. 3-10 

Alexander, October 1974, Analysis of Hydro Samples; R. E. Alexander; October 24, 1974; SRDB Ref 

ID: 13318 

Brake, 1989, Review of Chest Count Results for Dates Between September 22 and October 6, 1989, 

correspondence with attached results; Richard Brake; November 17, 1989; SRDB Ref ID: 11091 

BWXT, 2001, Safety Information Document in Support of the National Environmental Policy Act 

Documents for Pantex Plant, Amarillo, Texas; Babcock and Wilcox Technologies (BWXT); October 

2001; SRDB Ref ID: 21859 [Note: This document contains Unclassified Controlled Nuclear 

Information (UCNI).] 

BWXT, 2004, Pantex Plant Radiological Investigation Report, final; BWXT Pantex, L.L.C.; January 

2004; SRDB Ref ID: 20778 

Carr, unknown date, Pantex History 1942 to 1992; B. H. Carr; unknown date; SRDB Ref ID: 14338 

Copeland, 1989, Breathing Zone Monitoring of Personnel Involved in the Decontamination of Bldg. 

12-26, Bay 17, Interoffice memo; R. J. Copeland; April 18, 1989; SRDB Ref ID: 14197 

Corley, 1981, A Guide for Environmental Radiological Surveillance at the U.S. Department of Energy 

Installations, DOE/EP-0023; J. P. Corley, D. H. Denham, R. E. Jaquish, D. E. Michels, A. R. Olsen, 

and D. A. Waite; July 1, 1981; Not currently included in the SRDB 

Davis, 1967, Health Protection Survey Report, Pantex Plant for December 13-15, 1967; Claude E. 

Davis; 1967; SRDB Ref ID: 13310 

Delphi Groupe, 1990, Historical Exposure Records System (HERS), HERS Project Reports; The 

Delphi Groupe, Inc.; 1990; SRDB Ref ID: 14293 

DOE, 1977, Sixth ERDA Workshop on Personnel Neutron Dosimetry, held in Oak Ridge, Tennessee; 

U.S. Department of Energy; July 11-12, 1977; SRDB Ref ID: 18884 

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

of Energy; December 21, 1988; SRDB Ref ID: 8073 

DOE, 1989, Health Physics Review of Pantex Plant, October 30-November 3, 1989; U.S. Department 

of Energy (DOE); 1989; SRDB Ref ID: 42517 

DOE, 1995, Final Environmental Impact Statement for the Continued Operation of the Pantex Plant 

and Associated Storage of Nuclear Weapon Components, U.S. Department of Energy; DOE/EIS0225; October 1995; http://www.globalsecurity.org/wmd/library/report/enviro/eis-0225/index.html 

DOE, 1997, Linking Legacies: Connecting the Cold War Nuclear Weapons Production Processes to 

their Environmental Consequences; U.S. Department of Energy (DOE); January 1997; SRDB Ref ID: 

57 of 67 

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DOE, 1999, DOE Standard Internal Dosimetry, DOE-STD-1121-98; U.S. Department of Energy 

(DOE); December 1999; SRDB Ref ID: not currently uploaded in the SRDB 

DoRMS, 2005, Information obtained from DoRMS, information gathered by Mark Prather of Pantex; 

November 17, 2005; SRDB Ref ID: 20774 

Drummond, 1971, Memo regarding Uranium/Release of Radioactive Effluents from Facilities; John 

C. Drummond, Mason & Hanger; January 18, 1971; SRDB Ref ID: 13311 

Excel, unspecified date, Log Probability Analysis of Grouped Pantex Photon and Neutron Dosimeter 

Data; Microsoft Excel spreadsheet; date not specified; SRDB Ref ID: 21850 

Excel, 1991-2005, Pantex Bioassay Data, results in Excel spreadsheet ranging from 1991 through 

2005; January 7, 1991-July 13, 2005; SRDB Ref ID: 19642 

Gidley, 1971, Cloud Sampling Data-62 Hydro Test; M. D. Gidley; May 4, 1971; SRDB Ref ID: 

13315 

Griffis, 1988, Dosimeter Badge Status Change-Pantex Plant, interoffice memo; D. W. Griffis; 

January 18, 1988; SRDB Ref ID: 14235 

Hakkala, 1960, Urine Analysis, Western Union Telegram; Barney Hakkala. Tracerlab; January 22, 

1960; SRDB Ref ID: 14292 

Hefley, 1994, 1994 Lapel Air Sample Data, various 1994 dates; Teresa Hefley; 1994; SRDB Ref ID: 

14316 

Helgeson, 1989, Report of In Vivo Counting for Mason & Hanger Silas Mason Co., Inc. Pantex PlantWork Performed on September 22 through October 6, 1989; Helgeson Scientific Services; November 

3, 1989; SRDB Ref ID: 14337 

HPS, 1983, Health Physics Society American National Standard-for Dosimetry-Internal Dosimetry 

Programs for Tritium Exposure-Minimum Requirements, ANSI N13.14-1983; Health Physics Society; 

1983; SRDB Ref ID: 31910 

HPS, 1996, Health Physics Society American National Standard-Performance Criteria for 

Radiobioassay, HPS N13.30-1996; Health Physics Society; May 1996; SRDB Ref ID: 23441 

ICRP, 1959, Report of Committee II on Permissible Dose for Internal Radiation, Publication 2; 

International Commission on Radiological Protection; SRDB Ref ID: 11106 

ICRP, 1968, Report of Committee IV on Evaluation of Radiation Doses to Body Tissues from Internal 

Contamination Due to Occupational Exposure, Publication 10; International Commission on 

Radiological Protection; SRDB Ref ID: 11108 

ICRP, 1975, Reference Man: Anatomical, Physiological and Metabolic Characteristics, Publication 

23; International Commission on Radiological Protection; SRDB Ref ID: 22735 

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ICRP, 1982, Limits for Intakes of Radionuclides by Workers, Part 3, Publication 30; International 

Commission on Radiological Protection; SRDB Ref ID: 22733 

ICRP, 1994, Human Respiratory Tract Model for Radiological Protection, Publication 66; 

International Commission on Radiological Protection; SRDB Ref ID: 22732 

ICRP, 1995, Dose Coefficients for Intakes of Radionuclides by Workers, Publication 68; International 

Commission on Radiological Protection; SRDB Ref ID: 22731 

Ihne, 1980, Report of Investigation of a Radiation Exposure Incident at the Pantex Plant During 

September 1979, interoffice memo; Richard J. Ihne; March 10, 1980: SRDB Ref ID: 14310 

Ikenberry, 1983, Documentation of Tritium Dose Calculations, interoffice memo; T. A. Ikenberry; 

February 16, 1983; SRDB Ref ID: 13346 

Los Alamos, 1954, Analytical Procedures of the Industrial Hygiene Group, LA-1858; Los Alamos 

Scientific Laboratory; December 1954; SRDB Ref ID: 13981 

Martin Marietta, 1990, Pantex Plant Bioassay Samples, 1990 bioassay data identified by employee 

badge number; Martin Marietta Energy Systems, Inc.; correspondence date is July 9, 1990; SRDB Ref 

ID: 14196 

Mason & Hanger, 1962, Decontamination of Building 12-44-6 Following Radiation Accident on 

November 6, 1961; Mason & Hanger-Silas Mason Co., Inc.; February 16, 1962; SRDB Ref ID: 11088 

Mason & Hanger, 1972-1984, Various Tritium Urinalysis Data and Reports; Mason & Hanger-Silas 

Mason Co., Inc.; January 18, 1972-August 13, 1984; SRDB Ref ID: 14331 

Mason & Hanger, 1972-1981, Various Urinalysis Results; Mason & Hanger-Silas Mason Co., Inc.; 

various dates throughout March 27, 1972-November 9, 1981; SRDB Ref ID: 25314 

Mason & Hanger, 1989, Various Tritium Urinalysis Data and Reports; Mason & Hanger-Silas Mason 

Co., Inc.; May 17, 1989-June 23, 1989; SRDB Ref ID: 14656 

Mason & Hanger, 1990, Pantex Plant Site Environmental Report for Calendar Year 1989; Mason & 

Hanger-Silas Mason Co., Inc.; May 1990; SRDB Ref ID: 13440 

Mason & Hanger, 1991a, Analysis of Biological Samples of Uranium, Thorium, and/or Plutonium, 

internal operating procedure; Mason & Hanger; January 4, 1991; SRDB Ref ID: 12319 and 14023 

Mason & Hanger, 1991b, Internal Dose Assessment, procedure; Mason & Hanger-Silas Mason Co. 

Inc.; May 23, 1991; SRDB Ref ID: 12549 

McFall, 1969, Radon Film Badge Reports, various reports; Eugene D. McFall; January 1969-June 

1969; SRDB Ref ID: 13457 

Meyer, 1959, Analytical Results of Urine Specimens, collected on October 27, 1959; Dean D. Meyer, 

University of California; November 10, 1959; SRDB Ref ID: 14537 

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Mitchell, 2003, Rhetoric to Reality: A Cold War Context Statement for the Pantex Plant, 1951-1991; 

Kris C. Mitchell, BWXT Pantex; September 2003; SRDB Ref ID: 24171 

Morgan, 1961, Dosimetry Requirements for Protection from Ionizing Radiation; K. Z. Morgan; 1961; 

SRDB Ref ID: 8345 

Name One, 2006a, Petition Form B; [Name One, Name Two, and Name Three Redacted]; September 

6, 2006; OSA Ref ID: 100557 

Name One, 2006b, Letter of Transmission for SEC Petition; [Name One Redacted]; September 6, 

2006; OSA Ref ID: 101753 

National Bureau of Standards, 1955, Intercomparison of Film Badge Interpretations, from 

"Isotopics"; National Bureau of Standards; April 1955; SRDB Ref ID: 3640 

NIOSH, 1990, Abstract from Mortality Update for the Pantex Weapons Facility: Final Report HealthRelated Energy Research Branch, a 1990 NIOSH epidemiologic study; OSA Ref ID: 100559, pp. 11­

12 

Pantex Plant, unknown date, Radiation Safety Presentation, printout of slides; Pantex Plant; date not 

specified; SRDB Ref ID: 26391 

Pantex Plant, 1959-1967, Air Sampling Monitoring Logs, various locations; Pantex Plant; various 

dates between October 27, 1959-July 24, 1967; SRDB Ref ID: 13944 

Pantex Plant, 1962-1971, Various Monthly Urinalysis Reports, T-329, T-449, and T-446; Pantex 

Plant; October 24, 1962-December 1, 1971; SRDB Ref ID: 25391 

Pantex Plant, 1964-1968, Various Air Sample Surveys and Monitoring Logs; Pantex Plant; March 3, 

1964-December 24, 1968; SRDB Ref ID: 25292 

Pantex Plant, 1971, Various Monthly Urinalysis Reports, T-449, T-446, and T-329; Pantex Plant; 

January 29, 1971-December 1, 1971; SRDB Ref ID: 14101 

Pantex Plant, 1975-1977, Various Cell Air Monitoring Records; Pantex Plant; October 1975-January 

1977; SRDB Ref ID: 25297 

Pantex Plant, 1978, Igloo 75 Incident Bioassay Results; Pantex Plant; samples submitted on 

November 17, 1978; SRDB Ref ID: 25337 

Pantex Plant, 1979, Clean-up Procedure for Contaminated Igloo 4-75, Internal Operating Procedure; 

Pantex Plant; January 17, 1979; SRDB Ref ID:14202 

Pantex Plant, 1982-1984, Various Cell Air Monitoring Records; Pantex Plant; February 1982­

November 1984; SRDB Ref ID: 25303 

Pantex Plant, 1992, Technical Basis for the Internal Dosimetry Program and the DOE Pantex 

Facility, Rev. 01; Pantex Plant; February 14, 1992; SRDB Ref ID: 13312 

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SEC-00068 08-05-08 FINAL Pantex Plant 

Pantex Plant, August 2001, Internal Dosimetry Technical Basis and Quality Assurance Document, 

RSD-TBD-0001; Pantex Plant, Radiation Safety Department; August 23, 2001; SRDB Ref ID: 11070 

Pantex Plant, September 2001, Job Descriptions; Pantex Plant; September 17, 2001; SRDB Ref ID: 

14311 

Personal Communication, June 20, 2003 & May 27, 2004, Personal Communication with [Name Four 

Redacted]; communication with Pantex Safety Engineer; June 20, 2003 and May 27, 2004; SRDB Ref 

ID: 14542 

Personal Communication, June 29, 2003, Personal Communication with [Name Four Redacted], 

communication with Pantex Safety Engineer; June 29, 2003; SRDB Ref ID: 11079 

Personal Communication, September 23, 2003, Personal Communication with [Name Ten Redacted], 

communication with former Pantex employee; September 23, 2003; SRDB Ref ID: 11084 

Personal Communication, September 24, 2003a, Personal Communication with [Name Nine 

Redacted], communication with Pantex Training Manager; September 24, 2003; SRDB Ref ID: 11078 

Personal Communication, September 24, 2003b, Personal Communication with [Name Six Redacted], 

communication with retired Pantex Training Manager; September 24, 2003; SRDB Ref ID: 11083 

Personal Communication, October 1, 2003, Personal Communication with [Name Eight Redacted], 

communication with a member of the Pantex Radiation Safety Department; October 1, 2003; SRDB 

Ref ID: 11077 

Personal Communication, October 8, 2003, Personal Communication with [Name Five Redacted], 

communication with former Pantex Radiation Safety Manager; October 8, 2003; SRDB Ref ID: 

11081 

Personal Communication, June 16, 2004, Personal Communication with [Name Four Redacted]; 

communication with Pantex Safety Engineer concerning Pantex Burning Pad and Firing Sites; June 

16, 2004; SRDB Ref ID: 13467 

Personal Communication, October 11, 2006, Personal Communication with [Name Eleven Redacted]; 

communication with Pantex Safety Engineer; October 11, 2006; SRDB Ref ID: 27015 

Personal Communication, April 7, 2008, Personal Communication with [Name Seven Redacted], 

communication with a former Pantex Weapons Engineer; April 7, 2008; SRDB Ref ID: 45919 

Personal Communication, April 8, 2008, Personal Communication with [Name Five Redacted]; 

communication with site expert; April 8, 2008; SRDB Ref ID: 46110 

Peterson, 2002, Tritium Doses from Chronic Atmospheric Releases: A New Approach Proposed for 

Regulatory Compliance, S. R. Peterson and P. A. Davis; Health Physics, Volume 82, Number 2, pp. 

213-225; SRDB Ref ID: Not yet in SRDB 

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Phillips, 1960, Possible Accidental Inhalation of U-238 Dust-Machine Shop, Bldg. 12-5, report with 

attached radiobioassay data sheet; Herman Phillips and Don Dufek; February 12, 1960; SRDB Ref ID: 

14118 

Phillips, 1963, Film Badge Dosimeters, correspondence; Herman Phillips; November 8, 1963; SRDB 

Ref ID: 25340, pdf p. 14 

Radiation Protection Department, 1990, Historical Exposure Records System (HERS)-developed by 

the Delphi Groupe, Inc.; Radiation Protection Department; March 1990; SRDB Ref ID: 14531 

Rawlston, 1991, Final HERS Phase III Status Report, memorandum to W. E. Ivie; J. E. Rawlston; 

September 12, 1991; SRDB Ref ID: 14258 

Robertson, 1983, Performance Comparisons of Selected Personnel Dosimetry Systems in Use at 

Department of Energy Facilities; R. L. Robertson, K. L. Holbrook, R. C. Yoder, R. A. Fox, R. T. 

Hadley, B. T. Hogan, and C. D. Hooker; October 1983; SRDB Ref ID: 10718 

Roser, 1980, Incident Investigation Follow-Up Survey, June 24-26, 1980, Pantex Plant; Herman E. 

Roser; June 24-26, 1980; SRDB Ref ID: 14298 

Schleien, 1998, Handbook of Health Physics and Radiological Health, 3rd Edition; Bernard Schleien, 

Lester A. Slaback, and Brian Kent Birky (editors); 1998; SRDB Ref ID: 22737 

Shipler, 2004, Verification of Telephone Conversation with Dillard Shipler and Jerome Martin 

8/17/04, correspondence to [Name Six Redacted]; Dillard B. Shipler; August 18, 2004; SRDB Ref ID: 

13481 

Snyder, 1993, An Evaluation of Meteorologic Data Differences Between the Pantex Plant and 

Amarillo, Texas, PNL-8718; S. F. Snyder, Pacific Northwest Laboratory; June 1993; SRDB Ref ID: 

11071 

Strom, unknown date, Log Probability Analysis of Grouped Pantex Photon and Neutron Dosimeter 

Data; Dan Strom; unknown date; SRDB Ref ID: 21850 

Tracerlab, 1962-1963, Twin-Film Service Radiation Dosage Reports; Tracerlab; dates ranging from 

January 1, 1962 through April 25, 1963; SRDB Ref ID: 14348 

Wilson, 1999, Sources 4A: Code for Calculating (alpha, neutron), Spontaneous Fission, and Delayed 

Neutron Sources and Spectra, LA-13639-MS; W. B. Wilson, R. T. Perry, W. S. Charlton, T. A. 

Parish, G. P. Estes, T. H. Brown, E. D. Arthur, M. Bozoian, T. R. England, D. G. Madland, and J. E. 

Stewart; September 1999: SRDB Ref ID: 11114 

UNC Geotech, 1990, Results of the U.S. Department of Energy Indoor Radon Study, DOE/ID/12584­

75 Vol. 1; UNC Geotech; August 1990; SRDB Ref ID: 12287 

Unknown author, unknown date-a, Various excerpts from the 1990 Tiger Team Assessment of the 

Pantex Plant Amarillo, Texas, DE000634; OSA Ref ID: 100559, pp. 12-19 

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Unknown author, unknown date-b, Igloo 4-75 Cleanup Records, includes personnel cost estimates, air 

filter readings, nasal swipes, shower swipes, grid swipes; author not specified; date not specified; 

SRDB Ref ID: 14296 

Unknown author, unknown date-c, Summary of Dosimetry Record Keeping at the Pantex Plant; 

author not specified; date not specified; SRDB Ref ID: 44510 

Unknown author, 1961-2007, Radiation Safety Incident Reports, Scanned to Optix; unknown author; 

1961-2007; SRDB Ref ID: 41183 

Unknown author, 1970-1989, Pantex Incident Reports: 1970 to 1989; unknown author; 1970-1989; 

SRDB Ref ID: 14323 

Unknown author, 1998a, Table 6.1-1 History of External Radiation Exposures at the Pantex Plant, 

extracted from an October 1998 Safety Information Document; OSA Ref ID: 100559, pp. 1-4 

Unknown author, 1998b, Table 6.1-2 History of Internal Radiation Exposures at the Pantex Plant, 

extracted from an October 1998 Safety Information Document; OSA Ref ID: 100559, pp. 4-5 

Unknown author, 1998c, Table 6.1-3 Percent of Total Doses Attributed to Neutron Radiation, 

extracted from an October 1998 Safety Information Document; OSA Ref ID: 100559, p. 6 

Unknown author, 1998d, Three Pantex Incident Descriptions, extracted from an October 1998 Pantex 

Safety Information Document; OSA Ref ID: 100559, pp. 8-10 

UNSCEAR, 1988, Sources and Effects of Ionizing Radiation, 1988 report to the General Assembly, 

with Annexes; United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR); 

1988; SRDB Ref ID: not currently uploaded in the SRDB 

UNSCEAR, 1993, Sources and Effects of Ionizing Radiation, 1993 report to the General Assembly, 

with Scientific Annexes; United Nations Scientific Committee on the Effects of Atomic Radiation 

(UNSCEAR); 1988; SRDB Ref ID: not currently uploaded in the SRDB 

Vespe, 1965, Health Protection Survey of the Pantex Plant, memorandum; Vincent C. Vespe; July 27, 

1965; SRDB Ref ID: 14278 

Wilson, 2004, The Hanford Uranium Bioassay Program; R. H. Wilson; April 28, 2004; SRDB Ref 

ID: 11557 

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Attachment One—SRDB Data for Bounding Internal Dos

Potential SRDB Data to be Used for Bounding Internal Doses 

Internal Dose, Bioassay Data Air Monitoring Contamination Monitoring Radiation Surveys 

Year 

H3 Th U Pu High Volume Cell Air Lapel Alpha 

H3 Gamma Neutron 

1959 25358 13944 

‘59 14537 

1960 14118 25306 13944 1961 14226 13944 11088 14205 

‘61 14304 14226 

‘61 14330 ‘61 25342 ‘61 25306 ‘61 25358 

1962 14333 13944 

‘62 25391 

1963 25391 14329 14330 14319 14319 

‘63 25358 25358 ‘63 14537 

1964 25391 13944 25292 

1965 25391 25358 13944 25292 

‘65 14537 

1966 25391 14330 13944 25292 

‘66 25358 25358 

1967 25391 14537 13944 25292 1968 25391 14537 14330 25292 14217 14217 

1969 25391 25286 1970 25391 25286 1971 14101 25286 

 ‘71 25391 

1972 14331 **25314 25293 25286 25291 25776 

 ‘72 

1973 14174 

 ‘73 25293 

1974 **25316 **25316 **25316 25279 

 ‘74  ‘74 

1975 25297 25440 

 ‘75 25436 

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Potential SRDB Data to be Used for Bounding Internal Doses 

Internal Dose, Bioassay Data Air Monitoring Contamination Monitoring Radiation Surveys 

Year 

H3 Th U Pu High Volume Cell Air Lapel Alpha 

H3 Gamma Neutron 

 ‘75 

1976 **25314 25297 25440 

‘76 **25316 **25316 **25316 25782 

1977 25301 25440 

 ‘77 **25316 **25316 **25316 25786 

1978 **14194 **14194 **25314 14119 25301 25324 25440 

 ‘78 **14312 **14312 

 ‘78 **25314 25337 

 ‘78 **25316 **25316 **25316 

1979 14296 14296 25301 14252 14207 14207 14207 

‘79 25305 25281 25281 ‘79 14296 

1980 25305 25440 

 ‘80 25776 

1981 **25314 **25314 25283 25511 

 ‘81 25305 25783 

1982 25303 25513 

1983 14331 17084 14537 25303 14148 14148 

 ‘83 14334 25466 25466 25440 25466 

1984 25303 25779 

1985 25298 14207 14207 25472 

 ‘85 25779 

1986 25298 14158 14158 

 ‘86 25439 25439 

1987 25298 14129 14129 

 ‘87 25471 25471 

1988 1989 14654 14197 14207 14207 14157 

 ‘89 14656 14208 14208 20761 20761 

1990 25362 14187 25468 25508 

 ‘90 14196 25472 

‘90 14206 25511 

‘90 14531 25513 

‘90 19642 25780 

1991 25351 19642 25360 25359 25484 

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Potential SRDB Data to be Used for Bounding Internal Doses 

Internal Dose, Bioassay Data Air Monitoring Contamination Monitoring Radiation Surveys 

Year 

H3 Th U Pu High Volume Cell Air Lapel Alpha 

H3 Gamma Neutron 

‘91 25483 

Notes: ** indicates that the data are CEP data 

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