Effective Date: 6/3/2014 Draft Page No. 1 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

1

Data Completeness, 

Legibility, and Accuracy –

SC&A has not found that the 

completeness and accuracy of 

the recorded bioassay and 

external exposure records, as 

well as the electronic 

database, has been verified for 

the KCP. This is especially 

important because of the lack 

of general periodic or routine 

monitoring for KCP workers, 

and also because of the lack 

of legibility of some of the 

records. This issue applies to 

both bioassays and external 

dose records.

What proportion of the 

individual bioassay and 

external records are 

illegible, and how does the 

unavailability of this data 

impair or undercut dose 

reconstruction and the 

coworker approach being 

proposed in the ER? Can 

the internal and external 

data be verified and 

validated (V&V), and what 

is the result?

a) Prior to the KCP visit, during an 

analysis of some of the claimant 

recorded dose files, SC&A found 

that approximately 50% of the 

images on NOCTS had questionable 

readability. Therefore, SC&A 

evaluated the situation during the 

KCP visit and found that the 

original files exist, appear to be 

legible, and are available for DR if 

needed. If the dose reconstructor 

has any problems reading the 

external or bioassay records, the 

dose reconstructor can contact the 

KCP and obtain a legible copy. b) 

During the KCP visit, Brent Nasca 

agreed to provide NIOSH with a 

summary of the QA/QC methodology 

used to audit the transfer of the 

written external and bioassay 

records to the electronic database. 

NIOSH has agreed to provide a copy 

of that summary to SC&A when it 

becomes available. SC&A will then 

evaluate the process.

The KCP health physicist (HP) was interviewed and 

questioned by SC&A, Board members and NIOSH regarding 

this issue at the May 2014 KCP site visit. Photocopied 

images were shown to interviewers on the HP’s computer 

monitor and it was demonstrated that legible, accurate 

records are available.

Efforts to acquire additional urinalysis records are ongoing. 

NIOSH has reviewed several documents that indicate 

urinalysis was performed beginning in 1951, and that those 

samples were analyzed by LANL. NIOSH has received an 

example urinalysis from an employee’s medical file, and the 

Team is getting access to the LAHDRA holdings to search 

for additional records. There are also some other classified 

urinalyses listings that NIOSH is attempting to capture.
Effective Date: 6/3/2014 Draft Page No. 2 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

2

Worker Location, Job 

Category, and Coworker 

Model – Because of the 

varied historic operations at 

the KCP coupled with the lack 

of specific worker locations 

and job categories, the 

application of coworker or 

generalized technical basis 

document derived doses could 

result in incorrect dose 

assignments. This could 

involve a relatively large 

number of workers because in 

many cases there is a lack of 

(or illegible) bioassay and/or 

external dose records.

Therefore, the adequacy and 

completeness of the available 

data used for the coworker 

model needs to be addressed, 

along with it applicability to 

different categories of 

workers.

How definitive were the 

KCP organization codes in 

terms of distinguishing 

what occupational groups 

were exposed to uranium 

and were given bioassays? 

Is there an adequate means 

to distinguish “machine 

operators” from “general 

laborers,” “clerical 

workers,” “supervisors,” 

and other classes of 

workers, for purposes of 

assigning TBD-6000 based 

scaling factors of 50% and 

10%, respectively? Is 

there sufficient basis for 

delimiting natural uranium 

fabrication to Depts. 3A 

and 49X? What 

proportion of the 

individual bioassay and 

external records are 

illegible, and how does the 

unavailability of this data 

impair or undercut the 

coworker approach being 

proposed in the ER (i.e., 

job categories and work 

locations)?

Based on 5/5-8/14 KCP interviews, 

there were conflicting accounts of 

how freely workers “on the plant 

floor” were able to move from one 

department to another. One 

interviewee recollected moving from 

job to job, while another disagreed, 

noting that the union restricted such 

movement. Based on past 

interviews, the organizational codes 

did not necessarily match the 

assigned jobs, which could change 

over time; however, the distinction 

between operators, supervisors, and 

administrative staff was seen as 

clear. There appears to be a clear 

delineation and access restriction 

afforded the operating area 

containing the natural and depleted 

uranium work (Depts 20 and 26). 

While some scanned records on the 

SRDB are not legible, the original 

records are readable. Further 

review warranted to ascertain 

whether worker location and job 

category are sufficiently 

distinguishable for coworker 

modelling. 

This is primarily a TBD issue and NIOSH is planning a 

revision to the TBD. The adequacy and completeness of the 

available data is being addressed in issue 1 above. 

Interviewees during the May 2014 visit indicated that historic 

radiological operations were not that varied (e.g. five 

separate operations), and that personnel movement 

throughout the radiological facility was limited. A better 

understanding of these classified operations is desirable; 

however, NIOSH has not received any new information that 

thus far appears to conflict with the bounding assumptions 

documented in the SEC00210 Evaluation Report (ER).
Effective Date: 6/3/2014 Draft Page No. 3 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

3

Chronic vs. Acute – Default 

chronic pattern of intake used 

in the uranium coworker 

model, apparently being 

applied to most KCP workers, 

may not be applicable to a 

large number of them. 

SC&A’s review of actual 

claims reveals that workers 

that have legible bioassay 

records show patterns of 

excretion rates that indicate 

that the coworker model may 

not be necessarily claimant 

favorable for all workers.

For a given worker the 

uranium in urine bioassays 

show significant variations 

in ugm/l results from year 

to year, as well as month to 

month; additionally, for a 

given month, results varied 

noticeably among workers. 

Bioassay results for 1960 

and 1961 show 

significantly greater 

uranium readings than for 

the other years. These 

bioassay patterns indicate a 

non-negligible potential 

for acute intakes.

The operational information 

obtained during the KCP visit 

indicates that there was the potential 

for acute intakes, i.e., not all 

operations were continuous steadystate production processes. 

Therefore, this issue remains open 

as an internal dose reconstruction 

issue that NIOSH should address. 

Additionally, the cause of the 

generally higher bioassay reading 

for 1960-1961 warrants further 

investigation.

This is primarily a TBD issue and NIOSH is planning a 

revision to the TBD. The ER does not make use of the 

TBD’s coworker model. The TBD 6000 Working Group has 

also generically addressed these chronic vs. acute coworker 

model issues.
Effective Date: 6/3/2014 Draft Page No. 4 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

4

Super S Uranium – Type S, 

high-fired uranium oxide 

(UO2) may have been handled 

at KCP and needs to be 

addressed in terms of : 

1) source term and exposure 

potential; and 2) how 

solubility factors will be 

addressed. [Note: 

confirmation of 

Type S uranium would not 

confound dose estimation –

requires explicit 

acknowledgement in site 

profile).

Are there any other records 

(besides SRDB #14693) to 

verify incoming UO2

powder or other material 

as having been high-fired? 

While it was likely that some of the 

uranium handled at KCP was “high 

fired,” there is no clear evidence of 

insolubility that would preclude dose 

reconstruction with sufficient 

accuracy. Previously addressed by 

Board for Y-12 and INL; no dose 

reconstruction concerns concluded. 

Recommend closure by the work 

group.

NIOSH does not need to address a high-fired uranium oxide 

source-term and exposure potential separately from other 

KCP uranium work because, SC&A has previously agreed 

with NIOSH that high-fired uranium oxide is adequately 

bounded by the Type S solubility class (see, White Paper –

SC&A Review of LBNL Issue #3, dated 9/5/12).
Effective Date: 6/3/2014 Draft Page No. 5 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

5

Recycled Uranium - SC&A 

is aware of the potential for 

even DU to include recycled 

uranium once Hanford 

established its recycling 

program in the early 1950s. A 

cursory search of available 

documents did not reveal 

explicit mention of KCP as a 

recipient, but the potential for 

trace contaminants may exist. 

Therefore, the potential for 

exposure to radionuclides 

from recycled uranium at the 

KCP needs to be addressed. 

[Note: confirmation of 

recycled uranium by itself 

would not confound dose 

estimation – issue is explicit 

acknowledgement as source 

term).

Are there any records of 

recycled uranium or 

depleted uranium being 

received at KCP? Any 

analysis of U or DU 

showing elevated Pu or 

other trace radionuclides 

(e.g., Np-237 and Tc-99)?

It is the standing position of NIOSH 

to assume the presence of recycled 

uranium beginning in the mid-1950s 

and to account for it in dose 

reconstruction. TBD 6000, for 

example, addresses recycled 

uranium in its model calculations. 

NIOSH will assume recycled 

uranium was present at KCP and 

dose reconstruct, accordingly. 

Recommend closure by the work 

group.

TBD-6000 Section 2.3 identifies 1952 as the start of RU 

availability. The bounding methodology used during 

uranium work after 1952 includes the exposure contribution 

from RU nuclides. This was implied by reference in the ER 

to TBD 6000.
Effective Date: 6/3/2014 Draft Page No. 6 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

6

DU After 1971 and During 

and After 1997 - The nature 

and extent of work with 

depleted uranium after 1971 

and again during and after 

1997, as well as any intakes 

that may have resulted, 

remains to be adequately 

established. 

A search of classified 

records is waranted: What 

were nature and 

radiological hazard 

(exposure potential) and 

controls related to DU 

work? Where was work 

performed and who was 

potentially exposed? How 

were workers monitored 

and what was the exposure 

history? What was 

incident history and how 

were they handled, and by 

whom? What was 

contamination control 

experience? What was 

difference in above, for 

1958-1972, vs. after 1997? 

An interview conducted during 5/5-

8/14 KCP visit, indicates that 

uranium machining equipment 

remained in place and was not 

D&D’d until 1975. Depleted 

uranium “ballast” parts were used 

in the KCP telemetry program in the 

1980s (and possibly beyond) and 

show up in KCP waste inventory; 

not clear if they were fabricated 

onsite. Further review of “ballast” 

source term activity warranted.

NIOSH requests that SC&A be more specific as to the DU 

work information missing from the ER after 1971 to the end 

of the evaluated period (12/31/93). NIOSH is not aware of 

any DU work that is not bounded by the methods 

documented in the ER. The period after 1993 did not qualify 

for evaluation.
Effective Date: 6/3/2014 Draft Page No. 7 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

7

Radioactive Waste - Further 

evaluation is warranted in 

regard to the processes and 

isotopes contributing to liquid 

radioactive waste shipments 

from the Kansas City Plant, 

the time period during which 

these activities and shipments 

occurred, and the potential for 

unmonitored internal 

exposures from spills, leaks, 

cleanup, and routine 

handling/storage of 

contaminated drums. 

Any incidents involving 

radwaste spills, leaks, or 

contamination? How were 

radwaste handled, 

controlled, and shipped to 

and from KCP? Who 

handled radwaste and how 

were they monitored; what 

was the exposure history at 

KCP? What was the 

composition of the waste 

handled and what was the 

exposure potential to 

workers? How much 

radwaste was handled and 

on what frequency? 

Several KCP interviews on 5/5-8/14 

indicated that DU and MgTh 

turnings were collected in small 

barrels with oil, and staged in a 

“dump room” for disposition. 

Interviewees did not recall instances 

of leakage or contamination from 

these drums or from the waste 

disposal process, itself. However, 

LANL documentation indicates 

instances of leakage upon receipt. 

Further review is warranted, with a 

particular focus on whether leakage 

was limited to uranium.

NIOSH has reviewed liquid radioactive waste shipment 

records (e.g. SRDB 123835). More records [Solid Waste 

Information Management System (SWIMS)] have also been 

requested (SWIMS example SRDB 123881). NIOSH is not 

aware of any processes or unmonitored internal exposures 

from spills, leaks, cleanup and routine handling/storage of 

contaminated drums that are inadequately bounded with the 

methodologies described in the ER utilizing models 

developed with approved TIBs and TBD 6000.
Effective Date: 6/3/2014 Draft Page No. 8 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

8

Metal Tritides – It needs to 

be established the degree to 

which metal tritides were 

present and how doses would 

be reconstructed to account 

for this potential source of 

exposure, with particular 

attention to any incidents that 

may have occurred (i.e., only 

one isolated incident?).

What metal tritides were 

handled at KCP? How 

were they handled, where 

were they handled, and 

what was the exposure 

potential for workers? 

KCP interview of 5/5-8/14 indicates 

that several types of metal tritides 

were likely handled at KCP in 

sealed components. Historically, 

there appears to be only one 

instance where a component leaked, 

resulting in tritium contamination 

involving erbium tritide in 1987, but 

with no evidence of intake. Further 

review is warranted of incident 

records to confirm no evidence of 

contamination involving tritium and 

tritide containing components. 

Interviews conducted during the May 2014 site visit 

confirmed that the presence of metal tritides at KCP were 

solely related to contaminated parts being returned without 

adequate decontamination. A second occurrence of metal 

tritide contamination at KCP was described by an 

interviewee, and records of that occurrence will be reviewed 

by NIOSH.NIOSH has been made aware of “Weekly 

Activity” documents obtained during the May 2014 visit that 

indicate KCP performed an operation where tritium water 

was transferred from one-gallon polyethylene bottles to 4-

ounce bottles. These documents indicate that KCP obtained 

procedures from Sandia to perform urinalysis and that KCP 

was “set-up” to handle tritium water (equipment operating 

satisfactorily and calibrated) before they received the first (8) 

gallon shipment in August 1964. This water was received 

from Sandia and certified at 226 μCi/l. There are also 

indications within these reports that KCP ordered (7) 

additional gallons of of tritium water in December of 1964. 

NIOSH also recently reviewed a document (SRDB 128438 

pdf 3) that seems to indicate KCP handled or prepared a 

tritiated phosphor within an exhaust hood, utilizing safe 

handling precautions. This document indicates this work 

occurred prior to October 1968. NIOSH will continue to 

request and review documents that address KCP’s tritium 

operations.
Effective Date: 6/3/2014 Draft Page No. 9 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

9

External Coworker Dose –

Legibility, accuracy, and 

completeness of the databases 

(original and electronic) for 

use in developing a coworker 

external dose model has not 

been verified. Preliminary 

review indicates the lack of 

legibility and raises questions 

concerning the completeness 

of the external dose records

a) The dose/intake tables 

in the KCP TBD were 

derived using the data 

from the KCP plant 

electronic database, which 

was sent to NIOSH on a 

flash drive with the PII 

[redacted] (SRBD 

#14707). 

b) The external dose 

records for 1969 are all 

zero, which is unusual 

since the adjacent years 

show positive readings. 

However, SRBD #14707 

shows that there [fewer 

than 9] bioassayed in 1969, 

with results being very 

low; this may indicate that 

there was very low 

exposure potential during 

1969.

a) See Issue #1 above concerning 

QA/QC of transferred data.

b) To date, neither NIOSH nor 

SC&A has found the reason for all 

the recorded external doses for 1969 

being zero. During the KCP visit, 

Brent Nasca agreed to try to 

determine the cause of the records 

for 1969 being all zero. Brent will 

contact SC&A if he finds anything.

The legibility of monitoring records was verified during the 

May 2014 site visit and NIOSH is satisfied that there are 

methods available to obtain reliable monitoring results.
Effective Date: 6/3/2014 Draft Page No. 10 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

10

Non-penetrating Dose - It 

appears that there are periods 

(especially 1950-1963) where 

the details of non-penetrating 

exposure, dose, and records 

are lacking, making it difficult 

to evaluate non-penetrating 

doses to workers and for 

developing a coworker model. 

The proper dosimetry 

calibration, measurement, 

and recording of nonpenetrating dose, as well as 

how it will be used during 

DR, are especially 

important for skin cancer 

evaluation (which 

constitutes a significant 

fraction of the claimants’ 

cancers analyzed during 

DR).

SC&A’s research of KCP claims 

files indicate that before 1964, there 

was a column labeled “RADS” that 

may have been used for recording of 

the beta dose. However, this has not 

been addressed in the ER or site 

profile documents. The relationship 

between recorded RADS, 

ROENTGENS, REM, and BETA 

RAD, as recorded at the KCP, needs 

to be defined, and how these 

quantities will be applied during DR 

(i.e., how will the non-penetrating 

dose be calculated from the 

recorded data) to determine if 

appropriate data was recorded for 

DR purposes.

The ER provides a method to place an upper bound on nonpenetrating doses with sufficient accuracy. NIOSH is aware 

of the dosimetry used from 1950 to 1963, and that KCP 

records show 5000 entries for non-penetrating doses during 

this time. NIOSH is satisfied that the maximally exposed 

work group and work scenario are represented with the 

available data, and can bound doses to others in the evaluated 

class with their data.
Effective Date: 6/3/2014 Draft Page No. 11 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

11

N/P issues – The KCP 

neutron-to-Photon (n/p) ratios 

as recommended by NIOSH 

are not technically correct and 

require additional 

investigation in order to 

develop a technically-sound 

approach for dose 

reconstruction.

A few recorded positive 

neutron doses with 

accompanying zero photon 

doses were used by 

NIOSH to derive an n/p 

value of 1.0. However, the 

value of n/p in this case 

would be n/0.000 =

undefined. A zero photon 

dose with a small positive 

neutron dose indicates that 

the dosimetry system did 

not register the photon 

dose, because every 

neutron field is 

accompanied by a photon 

field from neutron-gamma 

capture reactions in the 

surrounding materials. 

Although the 

recommended n/p value of 

1.0 may be claimant 

favorable, it is not based 

on a scientifically valid 

dataset.

NIOSH’s proposed method is not 

technically correct. This is still an 

issue that NIOSH needs to address.

Based on OTIB-024 the n/p ratio for alpha reaction in 

uranium and thorium would result in n/p ratios less than one, 

therefore the ratio stated in the ER is bounding.

The KCP Site Profile advises the use of an n/p ratio approach 

rather than the use of NTA film with a correction factor for 

neutron dose assignment. The data used to recommend the 

n/p ratio of one are from the post-NTA film era as noted in 

Section 6.4.3 of the Site Profile. The occurrence of positive 

neutron dose during the post-NTA era is very rare indicating 

a low potential for neutron exposure. It is also noted (from 

Table 4 in the Site Profile) that the same neutron sources 

were operational during the NTA and post-NTA dosimetry 

eras; therefore, using the modern data set to recommend an 

n/p ratio for the earlier era should be valid.
Effective Date: 6/3/2014 Draft Page No. 12 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

12

Fading of NTA - The fading 

of the NTA film as a function 

of time, temperature, and 

humidity has not been 

addressed, nor were there any 

correction factors provided. 

Lower-energy moderated 

neutrons could have gone 

undetected, and if detected, 

would show even more fading 

as compared to the higherenergy neutrons, such as those 

used for calibrating the NTA 

film. Quarterly exchange of 

NTA film, such as was used at 

KCP, can result in complete 

loss of countable track and 

yield zero dose recordings for 

low-level and/or low-energy 

neutron exposures. These 

factors could be indicative of 

why there were very few 

recorded neutron doses, and 

insufficient data to derive a 

technically-sound n/p value.

Lower-energy moderated 

neutrons could have gone 

undetected, and if detected, 

would show even more 

fading as compared to the 

higher-energy neutrons, 

such as those used for 

calibrating the NTA film. 

Quarterly exchange of 

NTA film, such as was 

used at KCP, can result in 

complete loss of countable 

tracks and yield zero dose 

recordings for low-level 

and/or low-energy neutron 

exposures. These factors 

could be indicative of why 

there were very few 

recorded neutron doses, 

and insufficient data to 

derive a technically-sound 

n/p value.

During the KCP visit, records of 

outside vendor neutron dosimetry 

were located. Most of the results 

were recorded as minimum 

detectable level (M). However, with 

quarterly exchanges, the fading of 

NTA film tracks could significantly 

contribute to positive doses not 

being recorded. NTA film fading and 

its impact on DR is still an issue that 

NIOSH needs to address.

The NTA film fading is a common issue and has been 

discussed at multiple sites. A correction factor could be 

developed for KCP; however, it would take significant 

research and may not be justifiable since essentially all the 

neutron doses during the NTA era are "zero." NIOSH will 

perform dose reconstructions using data from the post-NTA 

era and will not use the NTA data.
Effective Date: 6/3/2014 Draft Page No. 13 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

13

Mg-Th Alloy operations –

In the ER NIOSH identified 

the Mg-Th operations period 

as May 1, 1957 through April 

30, 1979, as well as a residual 

period after operations ceased 

and before D&D. For the 

operational period, NIOSH 

proposes to use engineered air 

concentration limits coupled 

with ORAUT-OTIB-0070 to 

bound internal doses. The 

operations, timeframe, data 

adequacy/completeness, dose 

estimation approach, as well 

as the representativeness of 

1970 BZ sampling for null 

exposure, need to be 

validated. For the residual 

period, NIOSH proposes to 

assume 3E-11 uCi/ml lower 

air limit and deposition, resuspension, and depletion 

models to assign intakes. 

Thoron dose assumed to be 

5.1 WLM/yr coupled with 

TBD-6000 modeled air 

concentrations. These 

assumptions and models need 

to be evaluated.

What was the operational 

experience with Mg-Th 

alloy operations and what 

airborne resuspension of 

particulates was 

experienced? What was 

the basis for the 

engineered air 

concentration limits? 

What exposure potential 

for thorium existed during 

operations?

May 5-8, 2014 interview indicates 

that Mg-Th alloy work commenced 

as early as 1954. No additional air 

sampling data was identified. 

Further review of operational 

experience (with attention to 

incident reporting of fires) and dose 

reconstruction method is warranted. 

NIOSH has reviewed the ER and remains satisfied that the 

bounding method is feasible. NIOSH is also requesting 

additional recently located urinalysis records to determine if 

modification of the bounding method is required.
Effective Date: 6/3/2014 Draft Page No. 14 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

14

Post-1993 monitoring –

Need to validate 1993 cutoff 

date for ER based on NIOSH 

finding of “no apparent, or 

potentially, inadequatelymonitored exposures,” which 

was based on a review of 

claims after 10 CFR 835 was 

implemented.

What was exposure 

monitoring experience 

post-1993, and how was 10 

CFR 835 implemented and 

when was it in full effect?

4/17/2014 - NIOSH 

responded to this issue by 

stating that a qualitative 

assessment of claimants’ 

records showed it was 

possible to assign any 

unmonitored works to one 

of 3 categories (TBD, 

p.26) for external dose, 

and one of 4 categories 

(TBD, p.22) for internal 

dose.

SC&A analyzed NIOSH’s 4/17/2014 

response to this issue and sampled 

several case files in view of it. To 

date, SC&A has not located 

definitive information that dose 

cannot be reconstructed beyond 

1993; however, SC&A recommends 

that this issue be left open until the 

other SEC issues are resolved.

During the petition qualification phase ORAUT performed, a 

qualitative assessment that considered job titles and work 

information contained in the CATI. Claim information was 

reviewed for indications that a specific EE’s work duties 

were not represented by the four worker “exposure 

categories” presented in the site profile for assignment of 

dose to unmonitored workers. As stated in petition 

qualification documentation, dose reconstruction methods 

and assumptions would be evaluated through 1993, and if 

subsequent NIOSH evaluation into areas such as 

decontamination following operations indicated potential 

inadequately monitored exposures post 1993, NIOSH would 

extend the evaluation period into the 10 CFR pt. 835-era, as 

appropriate. Since it was determined by NIOSH that all doses 

could be estimated with sufficiency accuracy through 1993, 

the evaluation period remained unaltered in the final report. 

NIOSH is aware that DOE performed a "Radiological 

Protection Appraisal" of KCP in April 1993, and determined 

that KCP complied with most of the requirements of the 

DOE RadCon Manual. The few parts they were not in 

complete compliance with were not significant in terms of 

employee monitoring (SRDB 108258). NIOSH is also aware 

that KCP was actively complying with Article 511 of the 

Manual and appropriately removing personnel from the 

monitoring program (SRDB 108258). To illustrate, KCP 

monitored 59 personnel in 1994 using DOELAP accredited 

dosimetry, with only two personnel receiving measureable 

exposures. The two exposures were < 100 mrem TEDE 

(SRDB 11987).
Effective Date: 6/3/2014 Draft Page No. 15 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

15

Thorium oxide operations –

Need to validate that KCP 

laboratory operations 

involving ThO2 were bench 

scale in nature, and therefore, 

had negligible exposure 

potential.

What operations involved 

thorium oxide at KCP? 

What was inventory of 

ThO2 at any given time 

(NMMSS?). Was there a 

radiological control or 

monitoring program?

DOE inventory review indicates a 

standing inventory of “non-alloyed” 

(i.e., non-MgTh) thorium at KCP in 

the 1970s-1980s. No associated 

KCP program has yet been 

identified, or attendant bioassay 

program and related bioassays. One 

interviewee from 5/5-8/14 visit 

recalled a “room devoted to 

thorium;” that it was in “powder 

form.” However, other interviewees 

to date do not acknowledge any 

programmatic activity involving 

thorium other than MgTh (and 

formulation of laboratory-scale 

standards; one interviewee noted 

that thorium oxide powder was 

retained for use as an ICAAP 

standard). Further review is 

warranted.

Interviewees were asked about operations involving ThO2 at 

the May 2014 site visit and no large-scale operations were 

identified. The Industrial Hygienist provided additional 

documents during the May 2014 site visit that NIOSH will 

review after they are ADC reviewed.
Effective Date: 6/3/2014 Draft Page No. 16 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

16

Application of TBD-6000 –

Need to validate proposed 

application of TBD-6000 

methodology to determine if 

recommended concentrations 

bound internal doses for 

workers that had less 

exposure potential, or were 

unmonitored, for internal 

exposures to natural uranium 

(NU), thorium, and thoron.

The major items of 

concern are:

a) 1950-1955 - Application 

of TBD-6000 during NU 

processing. b) Use of the 

TBD-6000 methodology 

for unmonitored workers 

less exposed than operators 

for:

1955-1958 - Residual 

period of post NU 

processing.

1979-1984 - Residual 

period for post uranium 

operations. c) Use of the 

TBD-6000 methodology 

for unmonitored workers 

less exposed than operators 

for:

1957-1979 – Mg-Th 

operational period. 1979-

1984 – Thorium and 

thoron during residual 

period of post Mg-Th 

operations.

a) SC&A’s review of the application 

of TBD-6000 for the exposure to NU 

during the period of 1950-1955 at 

KCP found that the approach 

adopted in the SEC to be 

scientifically sound and claimant 

favorable, as long as there were no 

other radiological operations taking 

place in the Main Manufacturing 

Building during this time period. b) 

SC&A’s review of the use TBD-6000 

methodology for unmonitored 

workers uranium intakes for the 

1955-1984 time period found that 

the approach adopted in the SEC 

PER to be scientifically sound and 

claimant favorable, as long as there 

were no other radiological 

operations taking place in the Main 

Manufacturing Building during this 

time period.

SC&A finds that NIOSH’s use of 

TBD-6000 addresses the concerns 

for uranium exposures. c) However, 

the Mg-Th operational and residual 

periods warrant further review of 

dose reconstruction methods for 

thorium and thoron, as outlined in 

Issue #13.

Interviewees were asked about access controls and freedom 

of movement throughout KCP during the May 2014 site visit. 

NIOSH remains satisfied that the methodology documented 

in the ER is bounding. The TBD 6000 Working Group has 

also generically addressed the use of the surrogate modeling 

used in the ER.
Effective Date: 6/3/2014 Draft Page No. 17 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

17

D&D activities –

Need to validate scope and 

monitoring status of D&D 

activities; ER assumes D&D 

confined to 1984-1986 period 

and applies assumed air 

concentration parameter for 

general employee exposure.

Was D&D confined only 

to 1984-1986 and involved 

only Rockwell workers? 

What operational or 

facility changes occurred 

at KCP that would have 

involved D&D? Is there 

adequate monitoring data 

for Rockwell D&D 

workers? Was there a 

potential for exposure of 

KCP workers during 

D&D?

Interviews have not identified any 

significant D&D other than that in 

1984-1986. Other D&D related 

activities involved contaminated 

equipment, e.g., DU machining. No 

evidence has been found of exposure 

potential for plant workers during 

D&D. Further review of weekly 

activity reports and other sources of 

operational information is 

warranted. 

Interviewees were asked about the possibility of other D&D 

activities by Rockwell International or other contractors 

during the May 2014 site visit. NIOSH remains satisfied that 

the ER’s description of D&D activities is bounding.
Effective Date: 6/3/2014 Draft Page No. 18 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

18

Accidents, Incidents, and 

Fires in Worker’s Record -

The status of the recording of 

accidents, incidents, and fires 

in the worker’s records needs 

to be determined. Specifically, 

NIOSH needs to establish 

whether internal intakes and 

external doses from accidents, 

incidents, and uranium fires 

were included in the records 

NIOSH has available for dose 

reconstruction or whether they 

need to be obtained and 

accounted for separately from 

the standard recorded intakes 

and doses. This would include 

the 1987 erbium tritide and 

the 1989 Pm-147 incidents, as 

well as intakes from uranium 

fires.

How complete is the ER 

compilation of radiological 

incidents at KCP? Are 

there any dose estimation 

implications (e.g., “missed 

dose”) for history of 

radiological releases or 

contaminations from such 

incidents? What is 

frequency and significance 

of uranium fires during 

operations? How was 

post-incident monitoring 

addressed and by whom 

(Rockwell?). 

Routine recording of workplace 

incidents was not identified until 

“weekly activity reports” were 

found in microfilm format during 

5/5-8/14 KCP visit – a search for all 

such available reports has been 

requested. A limited sampling of 

such weeklies for the mid-1960s 

found routine reporting of 

workplace fires, spills, and 

accidents.

The KCP HP was asked about the inclusion of dose 

investigations with monitoring records during the May 2014 

site visit. A dose investigation that includes a statement 

about it being added to an employee’s records (SRDB 

128233) was shown to the HP and he stated that this was a 

KCP standard practice. Interviewees were also asked about 

their recollection of accidents, incidents and fires. NIOSH 

remains satisfied that the ER’s description of D&D activities 

is bounding.

The personnel information in documents pertaining to the 

1987 erbium tritide (SRDB 108267) and the 1989 Pm-147 

(SRDB 6216) incidents has been reviewed against NOCTS 

claimant identifiers, and linked to NOCTS claims data as 

appropriate. The TBD 6000 Working Group has also 

generically addressed the inclusion of fires and other 

incidents into exposure models. 
Effective Date: 6/3/2014 Draft Page No. 19 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

19

Potentially Unmonitored 

Exposures – The ER 

mentions the concerns of a 

petitioner about potentially 

unmonitored exposures in 

Section 7.4.4. However, the 

response in the ER was that 

NIOSH has determined it has 

sufficient information to 

document potential exposures 

and bound associated doses. 

Since these are specific items, 

it would be appropriate to 

address the monitoring 

requirements, impacted 

workers, and available records 

associated with each exposure 

potential to determine dose 

reconstructability for these 

potential exposures.

Review indicated 

unmonitored exposures 

involving (selected): 

plutonium, tritium, 

weapons grade uranium235, uranium-233, 

electron beam welders, 

accelerators, cesium 

irradiator, and Electro 

Curtain. 

Determine source term 

existed and exposure 

potential addressed (or 

unaddressed) in ER.

Inventory review and interviews 

indicate no plutonium and weapons 

grade uranium-235 and uranium233 were present at KCP, except in 

gram quantities in sealed sources, or 

as isolated fugitive contamination in 

returns. External radiation sources, 

e.g., electron beam welders, 

accelerators, cesium irradiator, and 

Electro Curtain, would have been 

monitored through film and TLD 

badges. Potential tritium exposure 

will be addressed in as a separate 

issue. Further review of operational 

records and incident reports are

warranted.

The concerns of a petitioner about potentially unmonitored 

exposures were listed in the ER as follows: “Many surface 

and airborne uranium isotopes, plutonium, tritium, weapons 

grade uranium-235, uranium-233, neutrons and other 

ionizing radiation from industrial X-ray gauging devices, 

electron beam welders, neutron generators, neutron 

plutonium-beryllium sources, accelerators, cesium irradiator, 

medical X-ray, and Electro Curtain”.

NIOSH addressed exposures to the evaluated class from 

many of the listed sources throughout the ER. Those items 

not addressed in the ER such as weapons grade uranium-235 

were omitted because there is no indication that they were on 

site. NIOSH has questioned former employees and searched 

SRDB documents for information regarding all of the 

petitioner’s concerns; however, only verified exposures are 

addressed in the ER.
Effective Date: 6/3/2014 Draft Page No. 20 of 20

NIOSH RESPONSES T0 SC&A KANSAS CITY SPECIAL EXPOSURE COHORT PETITION SEC-00210 ISSUES MATRIX (MARCH 2014)

No. SEC Issue Lines of inquiry Post-data capture NIOSH response

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

20

NEW ISSUE: TRITIUM Onsite review of weekly 

activity reports indicates 

that KCP handled bulk 

quantities of tritium 

beginning in 1964, which 

were obtained from LANL 

and involved the filling of 

hundreds of small bottles 

for a yet undetermined 

purpose. No operational or 

monitoring records have 

been found for this period.

Recommend that the WG open a new 

issue and further review continue.