”

Dr. T.F. Mancuso
Page 2 . . .

‘To further onx interest and as suggested “by Dr. Shoup £
xetursed to the record center on 3/1/72. (Friday) to. work with .
uy. Gary (amst. director) end a Mr. Gantt (Suvervisor) to identify
the-records to be transfered, = found that in the interims since -
ny last visit my name had-been removed from the ‘list of authorized
HCW people but Mr. Beets had arranged that. I could review shelf
file lists. Perhaps at a later date wa should reesteblish my
authorization through ABC, dependisig upon the outcome of the present
proposed record transfer. ae .

._ _X dentified from the Record Center shelf list those records
which sould be transfered and about this I make the following

points. - . . -
1. In our 8/31 telephone @iscussion Nr. Shoup agreed: with
me that the Health Davartment file, and Medical Records
for Bestyehan = Should certainly be transfered now be—
. causa encompasses all of the important exposure
people and data. Nedical- Records for Weldon gniy misht>

: remain in St, Louis- Was “Some Yeason,
a 2. Poss: oug. Problem: Possible Lost Re- ~
cords: When I. eved the sg! List iter

/ > a8 a guide. corl@ not find ona.camplete. set of medical
iles which we had originally titled Perminated From ---
Beldon thru 4 G6. My personal records show 1196 names
: set. It is possible that these folders were later
. intexfiled with some other group, or that.the-typist erred
-in preparing the list. “It is not’ feasifle to’ resolve this
by examining at the rec center all the individual files —
at the record center. I.therefore decided to list all .
‘ .  Wedical records:for transfer to youx,Oak Ridge files so
. that I can work with Viola and Narci to be sure there are
no lost records aid’ that each individual folder is iden>
tifiable as to locale. ~ . : . can
3. aA Serious Problem:. Possible Destruction of ‘Key Records.
J Included in the Record Center Sheif List is a ‘seperate
7 section for classified documents. I was permitted to. -
+ examine this list ahd was. shocked to.find a sizeable List
of titles for-reports originating at Destrehan dealing ~-
. with Dust Studies and other which will be criti
= te any: eventual ig. oF in |. t9 Job and ex-
. oes posure. I xecall each as being classified originally .
_: . . Peecause. it contained information about: -identity and pro- ..

. dyetion quantities of materiais which vere at-that tine -
Glassified. However, I think each of these was subsequentiy
Seclassified as the process was ‘declassified. The crucial ~
point is this: I was told that each of Se tocuments

. was d schedyied destruction . Ly :

r ) . xe center ¢ not have xequired number of qualified
observers. I believe these may be the only existing copies



T-23

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

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

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

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

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

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

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

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

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

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

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

4(



TING

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

1.3. OPPORTUNITIES FOR IMPROVEMENT

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

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

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

1.3.2 Observations — Occupational Medical Dose

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

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

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

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

Observation #2 — Special Uranium Curie
‘The equation for the special uranium curie is correct on page 31 of TBD-5 (ORAUT 2005e), and
on page 14 of TBD-4 (ORAUT 2005d), where it is stated that “The original data are reported in

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

37



7-29

Effective Date: [Revision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK 1-0028 34 of 61

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

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

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

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

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

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

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

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

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

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

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



Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Wness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010

e Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

ont
(2) Weider Spnng_ Plant workers Prem 1ISF-4bb reference
ne PreavencieS Bind types OF rau traminah ns § however
“Haare (AS No pamcol Pec Rexener of Chest x-reyS
AS A Rncten of job Category avalab@ nor 1s tard.
reference te Ang Oar HIE of K-rauy ekAMinabeon.7 Thirhg-
wurcent of Mote workels peceised hoo Sets of Chast
“rads IN Nias MONS Or Hess And VheCles olonet
Provide a reasin Air Bams The (ack OF isha records
“for_k-rau Clo Se Cshmate wyasurementS for moa years
Ot WS inkoowces & large Uncertainky inte the Close
¢eShmaies that Cannot Be reatiliy Qivankfed. A
Pp Diembaluy- large Source of _Unl@Cainhy for WSF iS
nome? and “nape 0f xrays TakeA No ee
Orvtiycol has beer feund Phat would w le oot the
poscibi Viti y ot OHew xrag Vidi S$ Or more Pregvuesyt
"heSt Ckants CE FD
Blane bioassay Oe. represent the Ovimand. Rapier
ayariable to AvankA- Uranium fatale Prtha workers
however) Mata” Arennt dtwdgS Alable for foclivtdval
Workers. (f-42)
GQ) film meAifors were plaved ar Seeced pots Haroughost
Oncess avas tb Sneas integrabes aréa monies,
And pouvbre moter Surveds$ oe used tb desect hot
SOK An & provi dé MApArmahoy tor decision’ About
prvéchve waasuces, Dara Rom Me area monitors OT
ymeier GueYys Nave Not been Pound (749
MWOKOe0P UNn€ Aaa Summanes Nave not been
Aiscover?d. ta Set Was recreated vSing mixterd_ of
WSP and SEC DesreNan Sieér workers EF Such data.
was Sed, iF Wwovld only by Rasille te inpleimnent a
SEC Por WSP yworke Ss (4D)
Q Senificant -faluce. of radidagtal Contv!s.
Svend fo) ae Sates that Some
Sr Lous emoloyeesS transferred to WS? Mwhere they
Are Me lOnger being monitored Dr _radiahen epee

with Alm” aciges FThis ances Wh & Bemet<. Prec

Name or Social Security Number of First Petitioner: ec ass


tous

[Document No, ORAUTTKBS-0028-5 | Revision No. 00 | Effective Date: 06/28/2005 | Page 29 of 43 |

3. Net counts in excess of 204 counts for 20 minutes were considered as ‘positive’
evidence of thorium tung burdens. A person who showed 204 counts for 20
minutes was considered to have at least one lung burden.

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

‘positive’ designation. (ingle 1991)

The reports of these measurements observed in the worker files are fitled “Thallium 208 in Vivo
Results.” This indicates that ?°Ti was measured as a marker for thorium. Thallium-208 is in
approximate equilibrium (with a branching ratio of 0.337) with 228Th, which might not have been in
equilibrium with the thorium series parent 282Th following chemical purification of the natural thorium
feed materials. The quantification of thorium depositions from these in vivo 2871 measurements is,
therefore, uncertain without knowledge of the degree of equilibrium of the thallium with the 22TH
parent. The record only gives a qualitative indication, background or trace, of the detection of ?*T! as

a marker for thorium.

5A2 Environmental Monitoring Period (1975 to 1984)

No personne! in vivo monitoring appears to have been conducted during this period.

5.4.3 Remediation Period (1985 to 2001)

Anin vivo measurement program was included in the design of the WSSRAP internal dosimetry
program to evaluate intakes of “*U and ***Th. Because the number of radiological workers exposed
to airborne radioactivity at the WSP site was expected to be small, WSSRAP could not justify the
expense of having its own in vivo measurement system. Instead, the program was initially based on
detection sensitivities provided by the Helgeson Scientific Services mobile counting laboratory. The
lower limit of detection cited for that system was 74 Bq (2 nCi) for natural uranium and 37 Bg (1 nCi)

for *Th in the lung (DOE 1991).

Later, the program was based on detection sensitivities of the in vivo measurement system at the

Femald Environmental Management Project. The sensitivities (of unstated pedigree) cited for that
system were 2.0 nCi for 2°°U and 1.2 nCi for “"Ac, assumed to be in secular equilibrium with Th
(DOE 2001). Revision 7 (DOE 2001) of the WSSRAP Technical Basis Manual states:

This assumption {of secular equilibrium] will not necessarily be true in an actual worker
intake.

and

It is important to note that these ‘typical’ detection limits are highly dependent upon the
individual worker's physical features such as height and chest size. The Weldon
Spring site has sent individuals to the Femaid site for lung counts, and detection limits

were 2.5 times higher than the typical values due to the individual's physical features.

in vivo lung measurements could have been performed as a special bioassay measurement following
a suspected or actual intake. Revision 7 (DOE 2001) states that such measurements were normally
reserved for “those incidents where the intake was suspected to exceed 500 mrem CEDE ....”



got SERVE,

s
&
Ff

z
3%
“%

by,
7
“evaea

CHAIRMAN:
Paut L, Ziemer, Ph.D,
Lafayette, Indiana

MEMBERS:

Henry A. Anderson, M.D.
Madison, Wisconsin

Roy L. DeHart, M.D., M.P.H,
Nashville, Tennessee

Richard L. Espinosa
Espanota, New Mexico

Michael H. Gibson
Franklin, Ohio

Mark A. Griffon
Salam, New Hampshire

James M. Motius, M.D., Ph.D.
Albany, New York

Wanda |. Munn
Richland, Washington

Charles L. Owens
Paducah, Kentucky

Robort W. Presley
Clinton, Tennessee

Genevieve S. Roessler, Ph.D.
Elysian, Minnesota

STAFF:

EXECUTIVE SECRETARY:

Lewis V, Wade
Washington, OC

COMMITTEE MANAGEMENT:

Cori 8. Homer
Atlanta, Georgia

CEIVED 4

T-36

ADVISORY BOARD ON RADIATION AND WORKER HEALTH
4676 Columbia Parkway, MS: C-46

“ch Cincinnati, Ohio 45226
‘ (513) 533-6825

September 15, 2005

The Honorable Michael O. Leavitt
Secretary of Health and Human Services
Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Dear Mr. Secretary:

The Advisory Board on Radiation and Worker Health (The Board) has
evaluated SEC Petition -00012-2 concerning workers at the Uranium
Division at the Mallinckrodt facility under the statutory requirements
established by EEOICPA and incorporated into 42 CFR Sec. 83.13 (c) (1)
and 42 CFR Sec. 83.13 (c) (3). The Board respectfully recommends a
Special Exposure Cohort be accorded to all Department of Energy (DOE)
employees or its contractor or subcontractor employees who worked as at he
Uranium Division at the Mallinckrodt Destrehan Street facility from 1949
to1957 and who were employed for a number of work days aggregating at
least 250 work days, occurring under this employment or in combination
with work days of employment occurring within the parameters (excluding
aggregate work day requirements) established for other classes of employees
included in the SEC. This recommendation is based on the following
factors:

e These workers were employed at a facility that processed materials
during the early time period for the production of nuclear weapons,
Radiation monitoring methods for all isotopes were under development
at that time leading to significant gaps in the monitoring of these
workers in comparison to current monitoring programs.

ke « There is relatively little information available for estimating thorium,

actinium, and protactinium. NIOSH’s approach to dose reconstruction
no longer relies on individual monitoring but rather plant-wide air
monitoring data, which is, itself, not even isotope specific. These data
have to be converted into isotope specific activity using residue fraction
values which have not been validated. As such, NIOSH has not
demonstrated that it can conduct individual dose reconstructions with
sufficient accuracy.

Sf



[Document No. ORAUT-TKBS-0028-2 | Revision No. 00

[Effective Date: 06/24/2005 | Page 27 of 39

|

Table 2-10. Estimated annual discharges to raffinate pits (kg).*

Slightly enriched

Fiscal year Natural uranium | Depleted uranium uranium Natural thorium
7068 —e = —e =o
1959 = = = =
1960 46,193 — = —
1961 42,502 0 0 0
4962 8,831 46 0 0
1963 18,448 0 0 0
1964 35,243 {0} 9 2,469
1965 13,069 9 2,828 46,170
1966 48,067 ff) (20) 26,809
41967 29 o ) 30,750
Total 182,382 AG 2,808 76,198

@. From Table 7 in DOE (1986).
b. _ Fiscal year begins on July 1 of the previous calendar year and ends on June 30 of the calendar year corresponding

to the designated fiscal year.

c Discharges to raffinate pits in AEC Fiscal Years 1958 and 1959 were held in inventory as “potentially recoverable.”
Beginning in AEC Fiscal Year 1960, all previous and then current releases to the raffinate pits were treated as
discharges and removed from the operating inventory as they occurred.

Table 2-11. Estimated annual discharges to sewer (kg).*

Slightly enriched
Fiscal year Naturat uranium {| Depleted uranium uranium Natural thorium
4958 —c = — =
4959 = = ~ _
4960 3,472 = — =
1961 6,461 i) 0 0
1962 4,304 i) 9 0
1963 6,374 i) () 0
1964 3,239 9 (i) 0
1965 4,254 ft) 979 ff)
1966 1,414 () (t) (‘)
4967 205 () [9] 0
Total 26,720 () 979 0

a From Table 7 in DOE (1986).

b. Fiscal year begins on July 4 of the previous calendar year and ends on June 30 of the calendar year corresponding to
the designated fiscal year.

Cc ~~ = no values given for these years.

of groundwater contamination near the WSP site. Ongoing remediation involves active monitoring of
the groundwater in this region.

24 ACCIDENTS

No information is currently available about accidental releases of radioactive materials to the
environment during operation of the WSP. {f additional information becomes available, it will be
assessed for value and added to this section as appropriate.

Dupree (1979) cites two accidental exposures of workers which occurred during plant operations and
were described by Mason during a visit to ORAU in August 1979. in one instance, a worker overfilled
a pot with molten uranyl nitrate solution which spilled onto the floor. While attempting to turn off the
valve, he felt into the material on the floor. He was hospitalized and ultimately returned to work
approximately 11 weeks after the accident. A full report of the incident was made (MCW 1961). In the
other case, a worker inhaled soluble uranium while trapped in a dust enclosure. The notes report that

(0


[Document No, ORAUT-TKBS-0028-2 J Revision No. 00 | Effective Date: 06/24/2005 [Page 29 0f 305

Table 2-13. Guides for prescribing restricted work based on radiation exposure in 1965.

Type of radiation or Dose limit
radioactive material
Gamma 3 rem per 3 consecutive calendar months.

70 rem per 12 consecutive calendar months.

5 rem per 12 months averaged over employment beginning 1955.

Beta 10 rem beta + gamma to whole body per 3 consecutive months.

30 rem beta + gamma to whole body per 12 consecutive months.

25 rem beta + gamma to whole body per 3 consecutive months.

75 rem beta + gamma to whole body per 12 consecutive months.

Internal radioactive 50% of the acceptable body burden specified in the recommendations of the
materials (when principal | National Council on Radiation Protection and Measurements (NBS 69).

effect of the material is Time-weighted exposure concentration averaged over any 4-week period exceeds
tadiation dose to tissues) | more than 5 times the quantity in Table 1 of AEC Appendix 0524.

Uranium ‘Average urine concentrations for 3 evenly spaced samples over a 72-hr period
exceeds 0.15 mg/L and one sample exceeds 0.25 mg/L.

Time-weighted exposure air concentration averaged over 5 consecutive workdays
exceeds 0.25 mg/m’.

Concentration in exposure air averaged over a 1-hr exposure exceeds 2.0 mgimTM
(a reduction factor of 5 is allowed for a well-fitted mechanical respirator, and a
factor of 50 for positive pressure respirator).

Uptake by other than inhalation suspected or knawn, average urine concentrations
for 3 evenly spaced samples over a 72-hr period exceeds 0.10 mail.

2.5.1.4 Badging

According to Mason (1955) heaith protection program document, “each employee except office
females wears (a) combination film badge-security badge.” The stated procedure was to change
these badges biweekly “or more often as indicated.” Film monitors were placed at selected points
throughout process areas to serve as integrating area monitors, and routine meter surveys were used
to detect hot spots and provide information for decisions about protective measures. Data from these
area monitors or meter surveys have not been found at this point.

The MCW (1965) health protection program document states that personnel in operating areas of the
plant and in some laboratories wore badges continuously while at work and exchanged them monthly
for processing. Permanent badges were assigned to persons who frequently went into badged areas.
Spare badges were available for persons having a casual need to enter badged areas. Badges other
than operations badges were exchanged on a 3-month schedule.

2.6.1.2 Radiological Exposure and Access Control

Workers at the WSP had the potential for exposure to airborne radionuclides from uranium or thorium
ore processing and to external radiation from the onsite radioactive materials. Film badges and
bioassay were used to evaluate actual exposures throughout the operational history. Measures were
taken to control potential exposures to below AEC standards. According to Mason (1955) these
measures involved:

4. instituting a work permit program (aimed primarily at protecting maintenance workers in
hazardous areas), which involved establishing time limits and survey meter checks for areas
with radioactive materials



AIsr Meehing

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Vuty_&, 2005"

Ce BDA PB BY NH

NY NN NNN S&F Fe Be Be Be Be eB Be Be
Aw Fen S&F SO eR DA RB YW HR EK DS

18

worst-case assumptions are to be made. And I
really want to stress the latter part of this
because it's always possible to make worst-case
assumptions that are subjective, that you can
say well, it can't possibly be bigger than
this. But I -- as -~ as we look at the
situation, the worst-case assumptions do have
to have some scientific basis, and that's also
how we read the regulations. And I'll come
back to that at the end of my presentation
because I think there are some quite difficult
regulatory issues to be addressed in regard to
maximum doses.

But first let me go to the technical issues.
Why do we think that reasonable dose estimates
are unlikely to be possible. Well, Mont Mason
himself said that radon dose data are not
sufficient except for minimum and maximum
estimates. And it's not simply a question of
the number of radon measurements that were
taken. We all agree that there were thousands
of radon measurements that were taken. It is
that the radon exposures were primarily puff
exposures. For instance, when the drums of ore

were being opened, or when the drums of

5L


TS

[Document No. ORAUT-TKBS-0028-5 | Revision No. 00__| Effective Date: 06/28/2005 [Page 35 of 43 _|

potentially exposed workers (Section 5.3.1.1.1). The work group data have been reconstructed from
urine data for all WSP workers by cost center code. Tables 5-7 to 5-16 (Section 5.3.1.1.5), list the
median, the 95th percentile, and the maximum values of the uranium urine data per year for Monday
samples and Friday samples by cost center and calendar year. The worker's urine data reports
provide the cost center (Section 5.3.1.1.5).

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

« Natural uranium, before 1961
« Natural uranium, recycled, 1961 to 1962
e Enriched (1%) uranium, recycled, 1963 to 1967

Because the feed uranium and uranium during processing were purified to some degree, itis
reasonable to assume that the contributions of the long-lived uranium progeny, i.e., “°Th and “Ra,
were small in most areas of the WSP. However, for workers in Building 101 where the uranium
concentrates were initially processed, the concentrations of *°Th and ”°Ra should be assumed to be
5% of the *°°U activity and 1% of the *°U activity, respectively as described in Section 5.2.2.

Because site-specific particle size data are not available, the default value of 5 ym AMAD should be
used.

if the absorption type of the uranium to which the worker was exposed cannot be discerned from the
data in the worker's file, the DR should use the absorption type that is the most claimant-favorable.

5.6.1.2 Thorium Intakes

No quantitative in vitro or in vivo bioassay results have been observed for thorium (Sections 5.3.1.2
and 5.4.1). However, dust studies for thorium operations (Section 5.5.1.4) indicate that airborne
thorium dust concentrations exceeded the MAC for several of the operations studied.

The suggested approach to assess natural thorium intakes is to use the approach in Section 5.3 of
the Fernald TBD for internal dosimetry (QRAU 2004a). Application of the Fernald approach to WSP is
based on the assumption that the thorium operations at Fernald are reasonably applicable to thorium
operations at WSP. Assumptions and information used for the Fernald approach that also appear to
be valid for WSP are:

4. Few, if any, in vitro analyses exist in worker files. The in vivo results that exist are not
quantified for thorium, and there is not enough information available to quantify the thorium
deposition from the in vivo results.

2. Although respiratory protection equipment was available and its use required, it cannot be
assumed that the respirators were always used or that there was a tight seal to the face when
they were used. No respiratory protection factor is assumed.

3. The MAC of 100 dpmim® (4.5 x 10" uCi/em*) was used at Fernald for control purposes. The
MAC of 70 dpm/m® was used at WSP for control purposes, or a factor of 0.7 less than the
control level at Fernald.

4. Workers could have been exposed to airborne thorium above the MAC level. It is assumed
that 100 hr/yr at 10 MAC accounts for intermittent exposures to high levels of airborne thorium.



T-24

|Effective Date: [Revision No. |Document No. Page No.
February 10, 2009. i] SCA-TR-TASKI-0028 29 of 61

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

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

3.2. SPECIFIC ISSUES

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

3.2.1 Occupational Medical Dose ORAUT-TKBS-0028-3

Background and Introduction

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

Finding #6: Inconsistence in Frequency of X-ray Exams
TBD-3 (ORAUT 2005c, page 8) assumes annual x-rays for all periods, and in Section 3.1.2

(page 7), it recommends annually from 1955 through 1966. However, in the same paragraph it
states, “A review of pre-1970 files indicates that, approximately 30% of the time, workers

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

42



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

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

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

Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

Cot)
mse are important AtFWe WS SHE weCay SE WHE
radi plooical hazardsS mau nol have been Olly
Comived ,inveshanied , Or documented data ths. oF
ibs Ocurén ce. CIP)
@Accicetts mic not have been documented
SofRoienrty or Be watiup Avalable. Accideyts anc
iMviolentS tovld have lead Jo Acute Intakes 4+/pr

Contam inaten That great Lge exceeded normal fevals.ie1))

Attach to Form B if necessary.

Name or Social Security Number of First Petitioner: | “otelee



TI

‘Effective Date: [Revision No. |Document No. [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 13 of 61

Different Solubility Classes Listed for the Same Element

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

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

Missed Dose and Coworker Data Not Adequately Addressed

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

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

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

Badging Policy Not Consistent

The TBD does not provide sufficient and/or consistent information concerning the badging
policies at the WS site. This raises the question of what badging criteria were actually used in

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



 £ixe. prook. and. ye.

Dr. 2.2. Nancuso
Page 3

hese coouments make tp the shelf list section designatea
ise Mr. Gary explzined he had no classification authority and
not ‘have access to these documents himself. Unless some action
is taken preaptiy te safeguard thése documents they will be destroyed
at the first opportinity.

t ao not know the correct procedure to safeguard, and aventuel]
Gaclassify and transfer these documents, Although I classified some
of then originally my present non-official status Probably has no Zore
Bs a minimus, F expect that you or AI Becker should fequest through
Dr, Benson, ox Dick Evans, ox Floyd Beets at O.R., that Mr. Gary
at the St. bovis Federal Record Center be instxucted@ not-t> destroy
V216l. The next step will be follow-up with security to learn the
procedure for getting the documents declassified or confirming that
they are already declassified, so they can be tranSferad to you.

i Failed to record the total volume IF listed Zor transfer but
remenber it was of the ordex of 200 cubic feet stored in individual
1 cubic foot ‘shelf boxes in which it will be shipped... By vecollection
is_thak all. of.this was’ contained: in about 12°x 4 \drewer cabitiets at
Weldon. -I certainly agree with Marci that there should be no problem
with storage spaca for these boxes at Oak RLdge. “Incidentaliy, while
at Oak Ridge I reassured myself that’ the building was essentially. --

iS’ protected." However, at sone, point it may be wise

3 ER ;

% people to reapprove this area for the
stonaga of critical records. Some of the existing or proposed records
may qualify for fixe proof Files under REC vegulations. . .

= continue work on my xepoxt to you as time permits and hope
to mail it by 9/8/72. ~“t would like to.visit 0-R. again soon to review
data from the computer center but think it.best to weit the outcome

‘of the expected transfer of-xrecoxis from St. Louis so I can help in

sorting and identification. I will.svbmit an invoice after completing



TS

[Document No. ORAUT-TKBS-0028-5 | Revision No. 00 _ | Effective Date: 06/28/2005 L_Page 27 of 43_|

Table 5-16. Uranium urine data summary by cost center for 1965.

Monday samples (mg/L) "Number of ‘riday samples (mg/L) Number of
Cost center [Median | 95thpercentile | Maximum records Median | 95th percentile ximum records
110 0.018. 0.034 0,042 “at 0.078 0.094 “0.162 19
20 0.017 0.025 0.047 156 0.014 0.072 0318 “A02—
50 0.017 0.035 0.347 a1 0.017 0.036 0.049 35
780 0.026 0.045_ 0.052 45 0.024 0.102 0.446 26
200 0.015 0.024 0.028 19 0.016 0,069 0.088, 16
290 0.010 O015 0.027 26 0.010 0.025. 0.039 18
310-321 O.0T7 0042 0.065 29 O012 0.024 0.024 ay
350 0.007, 0.018 0.027 "36. 0.005_ 0.012 0.024 9
370-379 0.008 0.022 0.045 165 0.070 0.055 0.193, 20
380-390 0.010 0.026 0.080 “46 0.077 0.026 0.033 2
392 0.004 6.070 O05 28 0.006 0.0% 0076 %
10-460 0.008 0.039 0.078 65 0.017 0.045 “0.068 25
500-510 0.006 0015 6.016 60 0.005 0012 0.016 34
520 0007 0.078 0.020 37 0.008 0022 0.030, Ec
530 0.006 6.078 0.022, 19 0.012 0.022, 0.022 T
550-569 0,007 0.018 0.027 709 0.007 0.074 0.026 7
600-690 0.006 0.014 0.016 65 0.005 DO 0.017 3_
STO Elec 0,008. 0.024 0.087 26 0.008 0.027 0.031 2
370 Mill 0.012 0.030 0.048 35 O.012 0,048 0.060 z
370 Misc 0.010, 0.024 0.087 88 0.008 0.025 0,039 63
370 Mins 0017 0.025 0.069 69 0.012 0.028 0.067 48
70 Pipe 0012 0.020 0,024 37 OTT 0027, 0.042, 2e_
her 0,070, 6.020 0.075 65 0.008 0.033 0.055 az
Table 5-17. Uranium urine data summary by cost center for 1966.
‘Monday samples (m: Number of Friday Samples (mg/L) Number of
Cost center ledian | 95th percentile laximum records Median { 95th percentile | Maximum secords
T10 0.015 0.030 0.089 i] 0.025 0.053 0.055 12
720 0.008 [0.030 0.052 730 0.015. 0.048 “0.100 “83.
i 0.006 0.018 0.079 25 0.01 0.054 6.054 cE}
80 0.012, 0036, 0.036 20 0025 0.048 0.048 9
100 0.006 0.027, 6.027 7 00tt 0.024 0.024 9
290 0.006 6.024 0.024 2 0.006 0.036 0.036. 2
10-321 0.009 0.027 0.022 20 0.016 0.459 0.459" 17
360 0,002 _ 0,008, 0,608 TS 0.002, 0.005, “0,009 6
370-379 0.006 0027 0.046 tor 0.008, (0.050 0.052, 6t
360-390 0.007 6.027 "0.025 26 0.008 0.029 0.029 13
400-460, 0.006_ 0025 0.085 Ed 0.008 0032 0045, 24
500-510 6,002 0.008. O017 26 0.004, 0.008 0.010 35
520 0.006 6.025 0.078 34 0,004 0.024 "0.024 Ey
530 0.005 O01” 0.021 24 0.004 0.022 0.022 12
50-569, 0005, G72 0.020 72 0.004 0012 0.026 38
610-690 0.006 O.0Tt 0.012 “18 0.004 0,008. 0.008 4
370 Elec 0.012, 0.027, 0.027 cK] 0.009 0.086 0.036 10
370 Mill 0,008 0.024 0.027 ~32 0.008 0.034 0.071 6
[370 Mise 0.008 0027 0.026. 53 0.010 0.033 0.036. 2g
1370 Wins 000g. O02 0.086 4% 0,009 0.080 0.055 2
70 Pipe 0.006, 0.015 0.024 22 0.015, 0.088 6.088 13
‘Other 0,006 0.019 0.027 56 0.004 0.025 o213 a7

5.3.1.2 Thorium

There is no indication discovered so far that a routine urine-sampling program was implemented for
thorium. No urine bioassay data for thorium have been found in the worker files.



7-4

[Document No, ORAUTTKBS-0028-1 | Revision No. 00__| Effective Date: 06/28/2005 [Page 8 of 117 _]

of5U in natural uranium ore concentrates represents less than 5% of the activity in natural uranium,
and because the WSP processed only a small amount of slightly enriched uranium.

Radionuclide concentrations in WSP outdoor areas are based on limited environmental
measurements at the site. The total amount of uranium emitted to the atmosphere has been
estimated from monitoring data (Meshkov et ai. 1986) and from a nuclear materials balance study
(DOE 1986). Based on methods and data in these two reports, the estimated uranium activity emitted
from the Plant ranged between 1 and 5 Ci/yr. An estimate of radon release, based on the amount of
uranium processed during the operational period, ranges from 12 to 34 Cifyr, assuming radium activity
was 1% of uranium activity, radon was in equilibrium with radium, and all radon was released.
Beginning in 1981, annual environmental monitoring reports provided estimates of air concentrations
of particulate radionuclides and of radon at the WSCP and WSQ. These estimates reflect emissions
during the later maintenance period, and throughout remediation activities. The TBD analysis used
these data to derive annual estimates of intake for 1957 to 2004.

Measured air concentrations of radon during the operational period are not reported in the literature.
Therefore, a simplistic screening-leve! mode! was used to estimate air concentrations at the WSCP.

Because no site-specific ambient gamma data were available for the WSCP during the operational
period, this analysis evatuated ambient dose rates for the Feed Materials Plant in Fernald, Ohio, as
reported in ORAU (2004). The reported net average dose rate for 1956 to 1970 was 0.18 mrem/hr, or
1,576 mrem/yr for continuous exposure. When this dose rate estimate is applied to the WSP
operational period, the WSP site background rate of 99 mrem/yr (Bechtel 1986) is added to derive an
ambient dose rate of 1,675 mrem/yr for continuous exposure. This corresponds to a 2,000-hr
exposure of 382 mrem. Between 1982 and 2000, thermoluminescent dosimeters monitored ambient
exposure at many perimeter locations around the WSCP, the WSRP, and the WSQ. These data are
summarized in this TBD, which summarizes estimated ambient onsite dose for the WSRP, WSCP,
and WS@Q for periods between 1957 and 2004.

1.2.4 Occupational Interna) Dosimetry

The WSP Occupational Internal Dosimetry TBD (ORAUT-TKBS-0028-5) discusses the internal
dosimetry program and develops estimates of potential intakes. Radionuclides of concern at the site
include naturally occurring isotopes of uranium (““U, “°U, and ”*°U) and their decay products
(primarily “°Th and “’Ra). Due to the amount of material processed, the primary radionuclides of
concern for internal radiation dose are the uranium isotopes. Because WSP processed some natural
thorium, dose reconstructors should consider Th and its decay products, "Ra and ”°Th.

The primary modes of intake were chronic and acute inhalation. The internal dosimetry program
required routine monitoring of environmental radon and thoron and their decay products when an
individual was likely to receive an annual intake of 10% or more of the annual limit of intake.
According to Revision 7 of the Internal Dosimetry Program Technical Basis Manual (DOE 2001), that
threshold was never exceeded. Bioassay (urine) data estimate the activity of the radionuclide
excreted in the urine following an inhalation. This TBD discusses these data, including history,
sensitivity, and pertinent nuances of methods and data.

Urine bioassay data represent the primary information available to quantify uranium intake for the
worker who is the subject of a claim. However, data are not always available for individual workers.
These data can be supplemented by workgroup monitoring data, because essentially continuous
bioassay monitoring of a worker was simulated by sampling at least one worker in the group each
week, with Monday ~ Friday - Monday sampling for “exposed” workers.



T-718

Effective Date: (Revision No. |Document No. Page No.
February 10, 2009 0 SCA-TR-TASK}-0028 14 of 61

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

Lack of Sufficient Coworker Data Development for External Dose

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

1.2 SUMMARY OF STRENGTHS

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

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

The various authors were fairly consistent in the information they presented across the six TBDs,
and made reasonable attempts to locate substitute data when it was missing for the WS site. This
data was sometimes extrapolated from later WS site data, the Fernald site TBDs, or generic DOE
documents, and these methods may be appropriate in some situations. However, because of the

frequent lack of WS site-specific data/information, SC&A has concerns with using this approach.

These concerns are expressed as findings in this report.

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

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

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

3e



e

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

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

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

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Employees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupational Health Epidemiological Studies and EEOICPA Program Records.
HHS/CDC/NIOSH.” These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to all forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to
provide required information may not be considered by HHS.

Name or Social Security Number of First Petitioner: ___|


[Document No. ORAUT-TKBS-0028-3 [Revision No. 00 | Effective Date: 06/24/2005 | Page 13 of 14]

Variation in applied voltage generally falls within +5% of the machine setting. Beam intensity is
approximately proportional to the 1.7 power of the kilovoltage, resulting in an uncertainty of
approximately +9% in relation to beam intensity for voltages in the 110- to 120-kVp range. Variations
in tube current are normal and generally smait. As the tube current drops, beam intensity falls in
direct proportion. Large decreases in beam output would be readily detectable and would indicate the
need for machine maintenance or, as a temporary measure, an increase in the current or voltage to
provide the necessary intensity for proper radiography. ORAU (2005) estimates the variation in tube
current to be approximately + 5% for this parameter.

Exposure time can significantly affect the dose received from radiography (exposure times are a
fraction of second). Even a smail variation in exposure time due to timer error can significantly
change beam output. Because early x-ray machine timers are known to have been inaccurate, ORAU
(2003 and 2005) assume uncertainty in beam output due to timers to be +25%.

SSD can contribute to variability because the entrance skin exposure is determined by this distance.
Variations result from accuracy of positioning as well as patient size (thickness). As expressed in
ORAU (2003 and 2005), this is generally thought to vary by no more than a few centimeters, with an
upper limit of 7.5 om (+10%).

A potentially large source of uncertainty for WSP is the number and type of x-rays taken. As noted
above, reports indicate the performance of only an annual chest x-ray examination, but no official
protocol has been found that would rule out the possibility of other x-ray views or more frequent chest
examinations. At this time, dose reconstructors should assume an annual chest x-ray for 1958

through 1964.

Consistent with ORAU (2003 and 2005), the TBD analysis calculated the statistical root mean square
to estimate total uncertainty. The root mean square is the square root of the sum of the squares of
the individual uncertainty values, and equals 28.9%. An estimate of 30% uncertainty is larger than the
default NIOSH guidance standard deviation recommendation of 20% (NIOSH 2002). Therefore, dose
reconstructors should multiply all final estimates by 1.3 to account for uncertainty, conservatively
assuming that all variables acted to increase dose.



Special Exposure Cohort Petition

under the Energy Employees Occupational
{ness Compensation Act

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Appendix —- Continuation Page

Continuation Page — Photocopy and complete as necessary.

(Cont)

Division who were Ot Matlinckmd+ lorhuren [94q Fo
1968. And (+ has ea nokd fat pporxhon$ shite to
Ue WsP ano tHwre 7s ho reason’ fo be tfeve Mat
yohens puere. aliflerent hehween the hwo Ilvanous.
Ol Nj OSH oléfevmined Mare as fn Sufhicient
jntormabon to eNhor €Shmate the MAY mM PadighOn
aose Shr eyenj hipe of Cancer Ter whith Fyliahan cloves
are recorshuck dy Wat tovld Nave ben incurred Under
plavsiblé Ureumstances by Anu Member Of He _ Cassy oF
Ystmate He ractiaben doses of members of tHe class
more _preciselu| Vhan a MAKimum MbSe eSh’mdate.
A) detailed documentohen of radviahen hazarcts, Surveys ind
polehal evposuesS weve not MAdiin-~Qualiable Or clo Not
lewist for the WS Site esacidlty Pr Ho apo raked
Reso ja57- as See is! wr bemited ppnishonal -per ock
ES sie data C= i2

ACK FE youhiae poysonned FeGress Contaminaren foave,
fonsistent And document bylaine Opliccs

Ofeynetm
Covreckon -factors OMNPeheNSIVE Dr aNS& OreAr a.m H
ACompass’d tae Major isotypes brdiught’ om sie and
ONSHe Cavironmental Moni toning prearam pr UNmon tered
Workers beads he caas iA Some Q eMaAon A dara iz)

2D tack nt morronaa aavioment Qnck procedures “by check
workers kar nee inworkplaces And poi leaving
trolled are. y was ¢ 2) 0.
Thorne is no indiCaken hat Survey (nShrumercts were
Available And revbnely used “ho Monro, wockars QS they leer
Qeeraronal Seas oF dhe WS ste. (TB 47-149
(93) 4nare iS No SUbStanbal Ste-wide shnowhenc. thonitenng
Gata avaiable ~Ayr te opersh ena penod +o ASSUS QW
re. ined site Lunwiron O$e
assessment. (T19,
(Zio? ble Frachon of WS work free Was not bioassay
a _rouhie basis dunng ogerahonalQenod. (T1D
@ Bosh dic monitoring data. de not dishnou ish Vio.
Source. OF Emissions (Pe)

Name or Social Security Number of First Petitioner: [. x

{0



TIS

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

Individual Exposures versus Average Exposures

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

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

1.1.2 Findings Specific toa TBD

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

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

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

Insufficient Data for Unmonitored Werkers’ Internal Environmental Dose

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

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

D>


Fuz

[Document No. |Page No.
SCA-TR-TASK1-0028 9 of 61

iRevision No.
0

ffective Date:
February 10, 2009

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

Summary of Issues

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

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

The majority of material handled at the WS site was natural uranium. In addition, some RU, EU,
and DU were also handled at the WS site, along with natural thorium. NIOSH acknowledges
this in the WS site TBDs and makes some provisions for it, but concludes in general that because
uranium is the most prevalent, it will dominate dose reconstruction. However, it cannot be
assumed that because the majority of the material handled was natural uranium, then the other
radionuclides are of a minor issue. Some workers involved in specific processes that handled
these other radionuclides (and workers in the vicinity) had the potential of receiving substantial
doses from these other radionuclides.

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


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

liiness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010
r ) Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

Fi @ont)
bund for Moium. HErever WSF Shodiés Prhonum
opevahons indicate airborne Yhdnum GuSt ConceatPangnrs
yceedock MAC for Several Operanon Swdies CLD

Q)Wwelden Spenq plant was idenhbed As a Site Hhat likeb+
TVceived recy Cla Uranium in relanvely Smal avanhher
‘of malenals afier lab) Tus natenal Contained hae
amounts of resicwal trans utanic elements Cinch ding
pluipaium Anclk neptoniimy, fission products Sich a
dechnehum), and yeactor-procluced_uran um iDipeS
(Such a& V-23e6), She reords donot incwde tha level oF
detail needed Hr accurate Shmaks of He amount oF
’euiCed meatenal received And Prcesged Ot WSIS
Kixbwn Vhat the plant received Shipments from oir
Doe Shes that processed And Shippect recy Cla yraniunr
“from feS0a (Ors _ 1962-196 T, byt AmounTS of rewiclod
VOaniun Versus Navral uranium ace not known (ED
@wasies olisposed of-in We guar, Owning WSP_
DpUahKOns present A diy se _sdurce OP PaArkcviate
emissions inthe gir As A rewlt OF entrapment OF
Contamina uind-epoed surface Sel or rvbbie.
Radon-222 dnd Radm+220 genevard from Ra-22ledaned
PA 124 pespechvely jn dhe Wuams alo preenkal &
“dituse Sorce OF Aicborne fadiotuclides . Wogh of he
qusoosalS ater (FSO were pot Svomerged. GD TD
@ Uranium and ¢henum effluents From vandus Sacks
were wot direcHys measured. Trove TS a lack. Of infymahm
waldple for gvankAying Source Sreaahs
(0) E8hmate_Of Hheroy please Fom Wr Weldon Spning
Plant wang operahonal un dd was notmadle, } in part
because Het type OP thorium matenat proceso} snot
Sufbcigntly dened in accessible, Gocumentahen (TD)
CD No _inditshen discovereh 30 far Fhat & Mune Vnne-
Smelling program was implemented fir thorium, No
unad bivaSsaC. Ostia. for Phorum have been found th
CS Let



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

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

Special Exposure Cohort Petition — Form B
Basis for Proposing that Records and Information are Inadequate for Individual Dose —

Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.4 @ I/We have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area
monitoring.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that perenne radiation exposures were not monitored.

OWeasured dir conv-enhanoas of radon durng He opyratonnd
wnod at Weldon Senna are natreporied Yn ta
Inerahre. Ane no sie “pecific Ambient gamma.
da were available for He Weldon Spning Chemical
Plant duning the ope rahenst penod . Fudthormore,y) 0st
Nas not bendable ty resolve whether Frore is
sufficient taclon data valable fr_cletermine J pb-
SeCHIC radon es4posuré (TA)

@ Ne Quank fave ia vitro bicdssag pesvlfs havebeen

F.2  &f \/Wehave attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or

destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached

documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
eee class have been lost, altered illegally, or destroyed.

oSsille lost wi \ records Las pre PouSly

Covid not find one Complete Sét of Mecl’Cal
which Nac been engmalty beled Termindled
“Prom _Weidon tar _ 428} 6e- CED

J DeppSures were more nan walized ar the Weldon
Sonig whi tacwdadk “tnon'um in Blaigs 103, 30 and 10

Name or Social Security Number of First Petitioner:



¥\

[Document No, ORAUT-TKBS-0028-2 | Revision No. 00___| Effective Date: 06/24/2005 [Page 23 of 39 |

The natural uranium was received as ore concentrates, from which uranium was extracted and
converted to various compounds and metal forms and shipped off the site. Depleted uranium was
received as metal and various intermediate chemical forms, processed on an intermittent basis, and
used primarily in product development activities. Slightly enriched uranium was processed on an
intermittent basis only, and was typically received in the form of scrap metal or residues. Natural
thorium was received in either a nitrate or an oxide form and processed on an intermittent basis in the
refinery (DOE 1986a). Table 2-7 summarizes the total receipts by fiscal year of operation.

Table 2-7. Annual uranium and thorium mass receipts (kg) (DOE 1986a).

Naturaf uranium Depleted uranium Stightly enriched Natural thorium
Fiscal year” material material uranium material material

7958" 8,000,407 128 04 44
1959 72,898,013 41,255 0 0
4960 16,032,283 - 30,203 0 0
7961 15,546,776 94,260 0 0
4962 16,009,091 22,225 0 )
1963 18,873,351 0 94,695, 0
1964 47 265,323 13,117
7965 2,769 441,977 313,699
1966 6,936 27,700 614,693
1967 0 12,890 0

Totals 422,015,977 467,823 842,585 941,347

a, Fiscal year begins on July 1 of the previous calendar year and ends on June 30 of the calendar year corresponding
to the designated fiscal year.
b, Includes startup period in FY 1957.

In 1999, DOE initiated the complex-wide Recycled Uranium Mass Balance Project (DOE 2000a),
which identified WSP as a site that likely received recycled uranium in relatively small quantities of
materials after 1961. The significance of these receipts of recycled uranium is that this material
contains trace amounts of residual transuranic elements (including plutonium and neptunium), fission
products (such as technetium), and reactor-produced uranium isotopes (such as *°°U) (DOE 2000a).
Site records do not include the level of detail needed for accurate estimate of the amount of recycled
material received and processed at WSP. It is known that the plant received shipments of uranium
materials from other DOE sites that processed and shipped recycled uranium from fiscal years 1962
to 1967 (the period of recycled uranium shipment), but the amounts of recycled uranium versus
natural uranium are not known. Due to the lack of information about recycled uranium quantities, the
May 15, 2000, DOE report addressing WSP recycled uranium (DOE 2000a) assumes that all uranium
receipts after 1961 (71,413,060 kg) were recycled, which is a large overestimate of the actual quantity
because the same document reports that the majority of material processed through WSP was natural
uranium.

2.2.4 Site Remediation

In 1985, DOE proposed designating control and decontamination of the chemical plant, raffinate pits,
and quarry as a major project to be called the Weldon Spring Site Remedial Action Project
(WSSRAP). In July 1986 a DOE project office was established on the site, and the project
management contractor for the WSSRAP was a partnership of MK-Ferguson Company and Jacobs
Engineering Group, Inc. The quarry was placed on the EPA NPL in July 1987. The chemical plant
and raffinate pits were added to the NPL in March 1989.

The purpose of the WSSRAP was to eliminate potential hazards to the public and environment and to
make surplus real property available for other uses to the extent possible. The scope of work
included dismantling the 44 WSCP buildings and structures and disposing of both radiologically and
chemically contaminated structural materials and soils. The project also disposed of as much material

19



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

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

OMB Number: 0920-0639 Expires: 07/31/2010
C ) Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

Fl (com)
with he WWNondm- 232 pdcenrt (T3V
(There Was Vee ytenhal of infémal radructicle
ty pos.re from _produchen by ldingS Bidg 103 Consiseed of
‘UNeat dust (YetlasCake ank V0-Y) a*226h-23%)po-219,
‘And _pb-210, Ep-222 Bnd 43 Sheet Wed Cota onl,
Yh- 232 And its delay products Stachq” Ta Novetviber 1463.
Bldg 105 Consiséd_ Fn- 222 and 1S “decay prduct® wakix,
eles possilde. There Are No Mmeaseremevds for hese”
Cyne ess (F389 .
GDNIOSH hasnt been Oble Po spech radiinucliclé FSHOS
“for _K-bS uranivom €xtrachon Gn cwding processing Steps
and fillvahon SttpS). Olant & {qveivedk’ K-WS rastdves’.
C4) Uracawsis Ont détede d Uranium And was notable
fp aucurareup assign does Eyed on mvhyres of
fadionqucl dé.
Gp Aes and IQA, Sn eshmaed EE Coo m3 OF
ontaminatved MoH | tAvipment Ane So! Lrre placed
ta We Weldon Spang Guar anda mech OF Hee
Waste nol Submerged. TMWS) airborne Concentrangas &
Uranium And tapdvm Mvtbrg from USe OF WS®
were probabli¢ neable bre 1403 which ts _
supoordedk boy “MiaSure h Cocentrakens OF urdniunn ia
Ate aie 1A Fo And 1902, (FD
Gb) Bn 1459, BEC recommended Mains! PéSpirater ose
xcept in emerabne- SVAN. Whoh OSHA Yisitd fn the
iAo0'S All Current respirators were te lee Olisppseck OF
bxaus? Hey were Nek agmropnate Tor Hu hazarck.
Troe. Was oka Set policy “Foc persona prplechve
Tomerttk CTA) ~ a
aa Anim) Wohres WhiCn rSsottect fn lol tearing OF
Coie AluminuM Clad thereby released &sSipy Powe.
GD Relevant dee Ar TSUSHOn ~uposure_and CYpoS res
to -toxics AS Well ns idlenb Graken." of 6pPdsed VS. hon-
Bnvsed p0pvBhen are in Complete.
Cy Mme Beard has alreaty pelommsnded  3pecia
Pons re SlatyS_ he glonte Denployess in He Uranium

epee!
ity

__ Altech to Rorm Bite

sat



gee

[Document No. ORAUETKBS-0028-4 | Revision No. 00 | Effective Date: 08/28/2005 | Page 13 of 35 |

However, the digestion phase of the refinery process would have released the trapped radon during
the operational period. Offgases containing radon isotopes from this process were conveyed to the
acid recovery plant at the WSCP. The discharge from the acid recovery plant was the prime source of
radon emission and perhaps the only point source for radon isotopes.

Wastes disposed of in the raffinate pits were not a significant source of airborne radionuclides,
particulate or gaseous, during the operational period due to the presence of water in the pits. It is
unlikely that a significant portion of the sediments became sufficiently dry to be considered a source
term during this period when they were being managed, even though Bechtel (1984a) reported that
Pits 1 and 2 could become dry during the summer months. NLO (1977) concluded that the inherent
consistency of the raffinate material precluded sufficient drying, and the pits did not pose a significant
source of airborne contaminants.

Wastes disposed of in the quarry during WSP operations present a diffuse source of particulate
emissions to the air as a result of entrainment of contaminated wind-exposed surface soil or rubble.
Radon-222 and ”2°Rn generated from ”°Ra and **Ra, respectively, in the quarry also present a
diffuse source of airborne radionuclides. Although most of the material initially dumped in the quarry
in 1959 was at an elevation below the average natural water level of 457 feet above mean sea ievel
(MSL) reported in 1967, later disposals maintained a fill elevation of about 480 feet MSL, such that
most of the waste was not submerged (Weldon Spring Raffinate Pits and Quarry Task Force Report
1967).

Uranium and thorium effluents from the various stacks were not directly measured. The total amount
of uranium emitted to the atmosphere has been estimated from monitoring data (Meshkov et al. 1986)
and from a materials balance study (DOE 1986). The reported atmospheric discharges from the
materials balance study were engineering estimates derived from airflows and other process factors
along with stack monitoring data, and are summarized in Table 2-8 in Part 2 of this Site Profile.

Based on these two methods, the estimated amount of uranium activity emitted from the plant ranges
between approximately, 4 and 5 Ci/yr. Meshkov et al. estimated release rates for uranium decay
products (Th, “Ra, 7"°Pb) as a fixed percent of the estimated amount of 8 released, assuming
the activities of “°Th, 22°Ra, and 2"°Pb in the original uranium concentrate were 5%, 1%, and 1%,
respectively, of that of 2°U. An estimate of radon release based on the amount of uranium processed
during the operational period ranged from 12 to 34 Ci/yr (assuming radium activity was 1% of the
uranium activity, radon was in equilibrium with radium, and all radon was released).

4.2.2.2 Post-1974 Source Terms (Monitoring and Remediation Periods)

During the monitoring and remediation periods, from 1975 to the present, diffuse emissions
predominate as the source of radionuclides to the air at the WSCP, WSRP, and WSQ. Beginning in
4981, annual environmental monitoring reports have provided estimates of air concentrations of
particulate radionuclides and of radon at the WSCP and WS@Q. These estimates reflect emissions
during the later monitoring period and throughout remediation activities.

4.2.3 Annual intake of Radionuclides

As noted in Section 4.2.2, releases of radioactive particulates or radon to the atmosphere have not
been fully quantified at the WSP for the operational period or the monitoring and remediation periods.
Meshkov et al. (1986) attempted to quantify point source emissions for the operational period by
considering monitoring data and the results of a materials balance study. However, in considering
exposure to radionuclides, material released from stacks provides only a partial picture of how
radioactivity becomes airborne. Diffuse sources resulting from wind entrainment or other mechanical



04-29-09 PO1:07 IN

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

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

Ss ecii tS Cohort Petition — Form B

oe

General Instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT all information clearly and neatly on the form.

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there is more
than one petitioner, then each petitioner should complete those sections of parts A — C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-
pose. A maximum of three petitioners is allowed.

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

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

Q A Labor Organization, StartatD on Page3

ityou O An Energy Employee (current or former), StartatC on Page 2
are: PKA Survivor (of a former Energy Employee), StartatB on Page 2
OA Representative (of a current or former Energy Employee), StartatA on Page 1

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

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

A.1 Are you a contact person for an organization? Q Yes (Go to A.2) Q No (Go to A.3)
A2 Organization information:

Name of Organization

Position of Contact Person
A3 Name of Petition Representative:

Mr./Mrs./Ms, First Name Middle Initial Last Name

A4 Address:
Street Apt # P.O. Box
City State Zip Code

A5 Telephone Number: ( ) -

A6 Email Address:

A.7  Q Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

Name or Social Security Number of First Petitioner:


TSi

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

same for all thorium isotopes. According to [CRP Publication 78 (ICRP 1997), the biokinetic
behavior is the same for U-234, U-235 and U-238 (see Tables A.10,6, A.10.7 and A.10.8,
page 127). The same applies for thorium Th-232 and Th-228 (see Tables A.9.8, A.9.9, and
A.9.10, page 107).

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

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

Missed Dose

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

Coworker Dose

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

An item of importance that applies to both missed and coworker dose data is the fact that in the
everyday operations at the WS site, urine samples were not necessarily collected, as stated in
some of the documents. For example, TBD-5 (ORAUT 2003e, page 17) quotes the following
from MCW 1965b:

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

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

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



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

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

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

GR, veshgaben Cf RU And defau4+s ty fernald. Ru fem
Aifferent Doe facunes Cmianed different
Concentrarens of radionuclides. “Mme ku data are
lndevnalicy 'aConsistent and inconsistent wir Dok.
documerteahae. 205 Canrobuben tp edterngl and
indernat closes Covld be Slemipaint (T-al + T-839

3) There is wer Uitte loferrdahen Available Conceming
WS Site ocCupshenal medital_procedureS ehviement x-fo)
KOM) Preaueincc etc. Wo mention is made” oF Hw tranenti)
of take exands perhrmel No inditanen that photo-
Fivorparathy -Pxanns Were _condvded at WSCP GRtit-as
G8) Blau SZ. Uranium was vWeewed aS AaChemical fi

And not aA tadiolava@l hazard, Jitle Achal ons
environmental Ve ASuceMment data exist -for She
Parry U¢acs OF WS opershens , specidtle) ~for- Un -
mentored workers on site Premises, buf ovtsice
jomediate pperAKngareas. Chae)

NO _ WS sie operational Measure mertts TAe
GA NIOSH has indicated Strat effluent databace tthe
J450s has not_heen foun. (tav
@) Lack. of any thenum data dS there's No basis
“fo eShmate Yhniaum releases prior fo 1407, €uen
WMough thenum Was cst Stored And VSed At 'WSCp
a 4Ar back As 1958. Signhcant gusnphes OF jnenun,
Ang: u7 IG88°.
25 eeause. tyre TS no AgvPrent -Hnurmrenral
“WwasurementS performed. during Or OPler events y it iS
Not possible fy Validate level Glen vicon mental
eyocbure. from the jacident. Zoe
GQ OQunvy pai Oenil , ws workers were Not
Bivassajed’ for phhur rAdionvcloes No Hatnun 6c
fadon_air Ana eviag UARL IG8S. Limrled m Site Vianium
Sam pling (F202
GE Urn Samoles were Nok Ne@ssanty Collected
Ata ru, FOMTAWARW mrahpns AFHhe WS Site. WMNnaLASIS
Ghardas nvagzed del not ppyvile SutBicient into to have

Name or Social Security Number of First Petitioner:

(2



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Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page hotocopy and complete as necessary.

E\ Ci Com)

(2b) lip t S080 of WS ste workers were Not mubnely

Monitored. (1-16)
@) Lacie of SIF moenttynng Stations Qnd lack of Siahons
within particular geographic. weaken at WSC. Cle)
Ig) Raton _incloor Cimlentratons QuvemgZel Pour Ames
at of putside_radon Ceoncentrakes. fly)
@ Limits ve deteckgn wert Nigh in tacleroears Which
Could spit in signihlant missed doses(r71)

G Mo WS sit® documents have been located that
suff ciently Apiciress dhe Change in fim Lalo? respanse
as a Funch®n bf rani onuclide Peposure,  LSpeTAI4 Te—
(oa energy photons and Chae s in_beta tnergiéS a)

Maucea Hssion in ViahiuM What Could emit radanon
Nor norma; NConlered And erpose WS worlarsdrd
TranspprderS whe May not Nave ben balgedy and s+
Could “have Created Tnhalable rab @WcHhvE Maen al -for
which hipassaus were not performed. G=19)

G3) Dnidividvals oc Cecdin groups of workers may have
Speen typpsea to majenals that Contained opener
ConCentrar ons of olher forms 0 Uranm and
(AdiNnvclicteS, eSpeciaihy in er néar_ Plant Jocanms. G20)
Gaworers tepvsed toVadionuclide’s from recycled
UanivmM (plutenicm, neptunivom , U-23le, kssiom Products;
Such As TC-99. Some Worvers or rtain GrouOS_ Mac
have_receved signi®ant porhin of teic Mmhatakeu
dose fem Ru And Irs AssociateaA ContamrnaantS foc
a sigmifant Anount of Hme rap

CGDSCAR Nas hot ound Anu neoten closes recorded
Or talumns labeled for enhY Of nevhon doses fn
CER or DOE databases. $+ Can net be cleterm nck
Lf nevi blm badaés were issued or read what
the MSUHS were ard (Ff they wee recorded In
Workers! Ales. 7-22)

Ca) Ladd 0€ suf aCient+ ihn formaton data_orv

Name or Social Security Number of First Petitioner: zz:


[Document No. ORAUT-TKBS-0028-2 | Revision No. 00 [Effective Date: 06/24/2005 | Page zou

the worker suffered from “CNS effect’ (presumably central nervous system effect). Mason further
speculated that this reaction was due to the chemical toxicity of the uranium exposure. There are no
notes about longer-term effects on either employee.

2.5 HEALTH PROTECTION PRACTICES
2.5.1 Operational Period (1957 to 1967)

The heaith protection program in place when operations began at the WSP in 1957 is not specifically
detailed in any of the technical reports available at this time. However, since MCW transferred many
of its activities and personnel from the Destrehan Street site in St. Louis at the startup of the WSP, it
is likely that the program in place closely resembled that documented by Mason (1955). If anything,
changes to the health protection program were likely more effective due to experience gathered in
previous years of involvement in uranium-processing operations. According to a descriptive report of
the Mallinckrodt contributions between 1942 and 1967 (Fleishman-Hillard 1967), the design of the
WSP “took advantage of the Company's and the Atomic Energy Commission's (AEC’s) accumulated
wealth of experience concerning the handling of health and contamination problems encountered in
uranium processing.” The WSP layout was planned with the goal of minimizing the spread of
contamination; advanced dust-contro! systems were used, and on-site health facilities were provided.
This 1967 document states, “...existing health programs were continued... at the new site, and a
number of supplemental programs were initiated at the Weldon Spring plant.”

A 1965 revision of the Summary of Health Protection Practices for the MCW Uranium Division is
documented in MCW (1965). The policies and basic principles underlying the health protection
program are described, and information is included about survey meter checks, film-badging
procedures, bioassay procedures, and restrictions on work assignments based on previous
accumulated exposures. it is fikely that this represents a revision of the 1955 program, but it is not
clear what or when specific changes were made over the intervening years.

Both the 1955 and 1965 documents rely on AEC standards of radiation exposure fo the extent that
health protection decisions were made about worker rotation based on a comparison of monitored
personne! exposures with these standards for radiation workers (i.e., individuals in controlled areas).
Table 2-12 summarizes the 1955 document's list of tolerated cumulative doses in use at MCW. In
addition, the 1955 document states that the goa! was to keep each individual cumulative exposure at
no greater than one-half of the tolerance when averaged over 3 months. The methods claimed for
controlling exposure are shielding, semi-remote operations, and worker rotation.

Table 2-12. Tolerated dose limits in 1955.

Type of radiation Tolerated dose limit
Beta 500 mrep wk, whole body or part
Gamma 300 mR/wk, whole body or part
Beta & Gamma 500 mrep/wk, whole body or part
Not specified 7,500 mrep /wk hands and forearms

@. tep = roentgen-equivaient physical, an obsolete unit of absorbed dose
for types of radiation other than X-rays and gamma rays;replaced by
the gray.

Table 2-13 lists the WSP guides for prescribing restricted work so that AEC standards would not be
exceeded (MCW 1965). Work restriction involved temporary relocation of the affected personnel from
usual duties until the cumulative average was at an acceptable level.

tal



ILle

Effective Date: Revision No. |Document No. Page No.
February 16, 2009 0 SCA-TR-TASK1-0028 31 of 61

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

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

3.2.2 Occupational Environmental Dose ORAUT-TKBS-0028-4

Background and Introduction

In TBD-4 (ORAUT 20054), most of the environmental dose to WSCP workers is attributed to
uranium and thorium. Internal dose from exposure outside the process areas is assumed to be
due mainly to facility releases and resuspension from contaminated soils, or from waste storage
and holding areas (WSQ and WSRP). Source terms are derived mainly from limited process
knowledge and calculated or estimated maximum releases from stacks and vents. Because
uranium was viewed mainly as a chemical hazard rather than a radiological hazard, little actual
onsite environmental measurement data exist for the early years of operations, especially for
unmonitored workers on the site premises, but outside the immediate operating areas. Most
effluent data utilized in the TBD were derived from several annual environmental reports for the
years 1981 to 2002, inclusive. Most releases and subsequent doses were presumed to be
primarily from natural uranium (mostly U-238); lesser contributors to environmental dose were
Th-232 and Th-230. Notably, the Th-232 was not monitored routinely, as it was believed to be a
minor contributor to dose. The TBD concludes that estimates of environmental dose can be
derived strictly from uranium air monitoring data, as it should account for resuspension of other
radionuclides in soil. Because of the lack of environmental monitoring for unmonitored workers
during the operational period, this TBD relies heavily on data obtained during the remedial
period, environmental parameter measurements, and the air concentration measurements during a
hopper cleaning event.

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

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

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



Ig
Effective Date: |Revision No. {Document No. age No.
February 10, 2009 9 SCA-TR-TASK1-0028 24 of 61

3.0 VERTICAL ISSUES

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

3.1. COMMON ISSUES

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

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

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

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


T3r

Effective Date: (Revision No. ‘Document No. [Page No.
February 10, 2009 0 SCA-TR-TASK 1-0028 45 of 61

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

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

Late in 1964 the Fernald site provided the first production of 1.95% 23517
billets for the Hanford Site. During the following production years uranium
was processed in a variety of enrichments ranging from depleted to as high as
20%. The quantities of enriched material above 2% was not documented, but
was qualitatively reported to be small and/or insignificant in total mass. The
reported highest enrichment level processed in quantity was 2%.

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

TBD-5 (ORAUT 2005e, page 35) recommends that the dose constructor use 1% EU for the
period 1963-1967. However, as outlined above, assuming a maximum enrichment of 1% is not
supported by the documentation presented,

3.2.4 External Dose ORAUT-TKBS-0028-6
Background and Introduction

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

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

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

As described in a previous finding, there appears that there was no personal contamination or
egress monitoring at WS during the operations period 1957~1966 to detect contamination on the

Ye workers after they changed clothes and left the operation areas. Additionally, there is no

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

Aq



TI3

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

1.1. SUMMARY OF PRIMARY FINDINGS
1.1.1 Findings Common to Several TBDs

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

Lack of Personnel Contamination and Egress Monitoring

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

Inadequate Information Concerning Workers Status/Exposures for 1967-1984

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

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

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


4/26/2009 IEER Science for Democratic Action Vol....

IEER
ee

SDA Vol. 6.No. 2
Worker Radiation Dose Records Deeply Flawed

By: Arjun Makhijani and Bernd Franke

As part of its responsibility for the production and testing of nuclear weapons, the
Department of Energy (DOE) and its predecessor agencies (the Atomic Energy
Commission, 1947 -1974; and the Energy Research and Development
Administration, 1974-1977) have been responsible for ensuring that workers were
not exposed to more than the allowable amounts of radiation. The DOE has also
been responsible to adhere to what is called the "ALARA" principle -- the idea
that radiation exposures should be kept "As Low As Reasonably Achievable" with
available technology.

The goal of setting radiation dose limits and following the ALARA guideline is to
protect worker health by limiting exposure. But if exposure is not properly
measured, radiation exposure regulations cannot be enforced, nor can guidelines
be followed. Health monitoring personnel may not be aware of instances when
workers are overexposed. Diseases that workers may be at greater risk of
contracting may go undetected, harming them and their families. Health studies
based on worker dose data would produce misleading results because dose
records would be incomplete and knowledge of doses would be inaccurate.

From the beginning of the nuclear era until 1989, radiation doses from
radioactive materials inhaled or ingested by workers were not calculated or
included in worker dose records. This was revealed by DOE in a background
paper sent to IEER on April 7, 1997.! DOE and its predecessor agencies did
a make measurements of internal exposure to radioactive materials, though often
sporadic (see below), mainly by taking urine samples. After the mid-to-late
1960s, there was also selective use of more sophisticated counters that directly
measure radionuclides in workers' bodies. The DOE was not required by
regulations to calculate worker doses, but only to keep records of whether
workers were internally exposed to more than certain amounts of radionuclides.

The lack of historical internal dose data in worker dose records has important
consequences for public policy on health issues, for scientific investigations of
radiation risk, and most of all for the more than half-a-million workers (and their
families) who have been involved since the Manhattan Project in making and
testing US nuclear warheads. In 1989, DOE began to correct this historical
roblem by initiating a program of integrating internal and external worker doses.

Ti


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

under the Energy Employees Occupational Centers for Disease Control] and Prevention
{iiness Compensation Act Nationat institute for Occupational Safety and Health

| OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

F\ (cont
@A dust shod OF specific areas And, jobs ta Bldg 30)
Was Conducked Yn (Fol Data was Onmaney umd 9s “O.
basis fpr recommending achons +o redua oncentranes.
There iS no _Inclicahen Mat aust lontentraben dara were
Used Fy assess intake tn Calculabg Abses bo ndivctoal
works 7S, QuSt @pesure_ClCUbhen worksheet S were vSct
AE Mt SFLoUS, bok worksheet Colomns old not VSt
vads. There TS no etclence ty show We Same forms
were Usecl Pr WSP employees. TMe Ammwal Personnet
cDytémal- paernat Raciaken Exposure Report fom ,
Anparent Wr fn VSk _b4 (G59 for WSP cluded aA Sechen ta
Average. dust Concent anon S pir Minott per Cubre Meter by
Caendar guactée Wine of the a&pesure repects
reitwead Naa ong data tn that Sechon. his Tnchicates that
WhectuSt Concembrahen was net poubnely recorded. Nb
pechhe o-pland Arc nnonitoring ANAlYSTS Sheets were
found .(T-2A-)
@? Biasorsé dose. eshmares Were Unlikely possible. Mont
Mason himself Said Phat raclby close ZaiQ are net
Suf¥ciert exgept for minimym Ancol maximum eshmars.
Radlon eyposireS were. po marily put Scposures_, and
Where TS"ne data for Hose bulf eposures “for individual
wxonucds, CT35 >
Go) thee. 1S ho data. Rr radionuclides Thon un=Z20,
Tadiem -22b, actinian-227, ANA pretdchy ium ~23 1.7 Bio)
Cb) Thonum- 228 And” Phonun- 232 may not have ben fa
yr tibpum Plowing Chemical punhesber of nxtura t
Miirnium feed Mmaienale DM vivo Méasvrements were,
erhormed On Sd\WL WS workers for Vhonum fn [4bée.
OveraQU PeSUHS Showed Workers inaras {ot /03,
2D), 402 mMainiendnce And heath And Sateh y, which
Were OrnlipH Seposure._posihous , had a more freavert
oceucrénce of thace'nlelechon. The Quwdarhrancn of
Thon plepesifiens from Heese in vive Palliym-208
fwasurements 1S Yheretore  yncertain without the
Knowledge. oft Begree OF @uilibrivan Of He Thallion wit

Name or Social Security Number of First Petitioner: __|]



A A AR Re BE see S

Weldon Springs
SHailinckrodt -
Exposures and Location
Bldg. Exposure
108 Hexane
105 Nitrous Oxide
202 Bydrofluorene Acid
301 Metal Reduction

Exposures more than realized at the Weldon Springs Plant ~'
Thoriue in Bldgs. 108, S01 and 106
* ghorium daughters - gamma radiation
Thorium - metal :
e@ - also Tribute) phosphate - thousands of gallons
Hexane in thousands of, gallons
(wateh for Ifver damage)



*€

[Effective Date: 10/24/2003 [Revision No.00__[ Document No. ORAUT-TKBS-0005 | Page 26 of 124 |

factor of 0.93. MCW gave as the “tolerance cumulative dose” limits in use in 1955 as beta, 500 mrep
per week, whole or part body; gamma, 300 mR per week, whole or part body; sum of beta and
gamma, 500 mrep per week whole or part body; and 1500 mrep per week, extremity (MCW 1955).

In 1947, the basic dose limit was 0.1 rep/day and the relative biological effectiveness (RBE) for alphas
was 10 (Hursh 1975); probably this was true earlier as weil.

In anticipation of the lowering of the radiological dose standards (recommended limits) by the national
expert committees such as the National Council on Radiation Protection and Measurements (NCRP),
AEC began making changes in the plants in about 1948 to meet new "maximum permissible fevels” of
300 mRiweek for whole body irradiation and 1500 mrep/week for beta radiation to the hands (AEC
1949). In August 1949, AEC established and circulated to its contractor personnel a tolerance level of
300 mrep per week, which was to be taken as the total gamma plus beta dose to the whole body.
However, Mallinckrodt misunderstood that the 300 mrep limit was to be applied to the total of beta and
garnma and interpreted it as the limit for either beta or gamma (AEC 1950b). Finally, in January 1950
AEC made it clear to Mallinckrodt that the limit applied to the total beta plus gamma (AEC 1960b)

In mid-1950 AEC agreed to allow Mallinckrodt to interpret the 300 mrep total gamma plus beta whole-
body limit as being taken as the average weekly dose over a three-month period, thus allowing the
300 mrep to be exceeded in some weeks (AEC 1950d); this was apparently based on the fact that
Mallinckrodt was already using a system of personne! rotation to reduce doses (AEC 1950b).
However, AEC at the same time suggested that 150 mrep per week be taken as a recommended limit
for most purposes and that a weekly dose of 600 mrep be exceeded only in exceptional cases. It
should be noted that in 1953, a design contractor was stating that the design criteria for ventilation
and dust contro! equipment his company had put in at Mallinckrodt and Harshaw included a maximum
weekly exposure of 300 mR of gamma radiation, with actual design predicated on half that to allow for
a safety factor in unusual circumstances (Miller 1953).

During the early days of wartime uranium processing, AEC/MED's acceptable levels of exposure for
the uranium processing plants for dust in air were 500 yg/mé for insoluble uranium salts and 150
pgim® for soluble salts (AEC 1949). In 1944 MED determined that a standard was needed for
uranium dusts and adopted the air maximum permissible concentration (MPC) level for lead, 150
tig/m®, as the interim standard (Hursh 1975). in 1949, a University of Rochester scientific group
suggested an air MPC of 50 j1g/m? for soluble uranium forms based on (chemical) injury to the kidney
and an air MPC for insoluble forms based on radiation injury to the lung (Hursh 1975). In 1953 the
NCRP recommended in National Bureau of Standards Handbook 52 (quoted in Hursh 1975) a limit of
73 g/m? for both soluble and insoluble forms; it was adopted. These were occupational standards
that correspond te a 40-hour week (the number of hours that Hursh (1975) uses in conversions in his
discussion of the history of standards).

By 1949, AEC had set a "preferred level” of 50 pg/m? for uranium dust, assuming a routine exposure
of 8 hours a day, 6 days a week (AEC 1949). This was taken to be equivalent to 70 dpmim’ for alpha
and is based on animal studies (Hursh 1975). For dosimetry reference, Appendix A gives the basis
for this figure. This was later referred to as the Maximum Allowable Concentration (MAC) and was
still in use as of 1953 (Miller 1953). In early 1955, AEC appears to have adopted a MAC of 100
dpm/m? for alpha, as AEC (1955c) stated in an air dust study report. In a 1958 report, AEC gave the
limit for natural uranium, either soluble or insoluble, in air as 5 x 10° uCi/m! for 40 hours/wk (i.e.,
occupational) and 1.7 * 10°? uCi/m! for continuous occupancy (AEC 1958, Table |). In 1959 the AEC
also recommended against respirator use except in emergency situations (AEC 1949), suggesting
that before the relevant period of Mallinckrodt work, extensive use of respirators was still tolerated as
ameans of minimizing exposure.



Effective Date: Revision No. Document No. Page Nu.
January 31, 2005 0 SCA-TR-TASK1-0002 94 of 102

others indicated that people went offsite for lunch or home in their work clothes. The
plant did have a laundry service and workers were provided with new clothes the next
day. The laundry was found to have radioactive material on it. Workers report that dust
would get into their hair.

Use of respiratory protection was intermittent. The primary respiratory protection used
included dust masks or half-face masks with removable filters. The type used depended
on the area. In pictures from the MCW magazine there appear to be similar to painters
masks, Some workers in the green salt processing area remember getting green salt on
their face around their mask. Respiratory protection used seemed to be variable for the
different operations. The policy was to use respirators for the day and discard them for
washing. The lab was responsible for cleaning the respirators and replacing filters. Ifa
worker knew he/she might need it, he/she would carry it with them on their person, One
worker indicated he used his until it was worn out. In between, uses he stored it in his
locker.

In the 1960’s during an OSHA visit, one worker indicated that OSHA directed the plant
to dispose of all current respirators as they were not appropriate for the hazard.

Workers report that the uranium compounds at MCW included brown oxide, orange
oxide and green salt. Urine samples were collected every six to twelve months starting in
the late 1940’s. Denise indicated that they recorded a lot of zeros recorded,

Documentation from the production areas was provided to administrative workers for
processing. In some cases, the paperwork was returned to the initial organization. In
other cases the paperwork was put into a library. The administrative offices were dusted
once or twice a day. Some workers recollect that documents were burned.

There were lots of pipes and tanks at the facility, At times maintenance personnel (e.g.,
pipefitters, welders) had to enter tanks or pipes to work.

Some Radon Breath Analysis was performed for individuals working around Radium.
Most of the results were recorded as zero.

Dust control measures at MCW included exhaust systems, used of vacuum, dust
collectors, and water. Dust collectors contained dust bags which were monitored by a
sensor. When the dust bag became plugged, the dust collector had to be turned off
(originally manually) and a ring blower used to loosen the dust. The ring blower was
then turned off and the dust collector returned to service. Although the dust collectors
reduced dust levels, the dust bags would periodically rupture creating a mess. The plant
had some gloveboxes. The level of dust control measures was fess in Plant 4, the original
production plant. There were wooden floors in Plant 4 and concrete floors in other areas.
Plant 5 had a floating foundation. There was also outside storage.

ole


T2I

Effective Date: [Revision No. |Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 Ll 27 of 61

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

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

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

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

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

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

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

34



(Effective Date: (Revision No. {Document No. Page No,
February 10, 2009 iY SCA-TR-TASK1-0028 49 of 61

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

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

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



) v

[Document No. ORAUTTKBS-0028-5 [Revision No. 00__| Effective Date: 04/28/2005 | Page 28 of 43 |

§.3.2 Environmental Monitoring Period (1975 to 1984)

No personnel bioassay monitoring appears to have been conducted during this period.
5.3.3 Remediation Period (1985 to 2001

An extensive, state-of-the-art bioassay monitoring program was conducted during the 1991 to 2001
period to detect intakes greater than 100 mrem committed effective dose equivalent (CEDE). This
program is well defined in the WSSRAP Technical Basis Manual revisions (| DOE 1991, 1994, 1997,
1998a,b,c, 2000a, 2001), The focus of the program was to conduct bioassay based on workplace
action levels for air sampling, nasal wipe analysis, and wipe analysis of the inside of respirators at the
end of each day they were used. These action levels triggered fecal sampling, urine sampling, and in
vivo measurements, as appropriate.

There are no Technical Basis Manuals available to document the bioassay monitoring program during
the early part of the remediation period (1985 to 1990). If no individual bioassay data and no
applicable co-worker bioassay data are available for a claimant for the 1985 to 1980 time period, the
environmental data for 1985 to 1990, described in the Technical Basis Document for the Weldon
Spring Plant ~ Occupational Environmental Dose (ORAU, 2005c) can be used to estimate intake.
Alternatively, individual or co-worker bioassay data for the subsequent year (1991) may be used to
estimate worker intakes.

Routine uranium urine sampling also accurred monthly for at-risk workers. Uranium MDAs were
reported as 4 pg/L in 1991 (DOE 1991) using laser fluorimetry and as 0.1 pg/L in 1994 to 1998 (DOE
1994, 1997, 1998a) and 0.0524 pg/L in September 1998 to 2001 (DOE 1998b,c, 2000a, 2001) using
kinetic phosphorescence analysis. Uranium results of 0.2 yig/L or greater were considered positive for
occupational uranium intakes in 1997 (DOE 1997), and results of 0.3 g/L or greater (DOE 1998c,
2000a, 2001) were considered positive for occupational uranium intakes from 1998 through 2001.

54 IN VIVO MEASUREMENTS
541 Operational Period (1957 to 1967)

There is no indication that WSP had an in vivo measurement program or performed any in vivo
measurements for uranium, but there is an indication that in vivo measurements were performed on

some WSP workers for thorium in 1966:

From July 11 through July 27, 1966, ¥-12 personnel visited the Weldon Spring plant
and set up the portable Whole Body Counter for in vivo thorium counting to quantity
body burden deposition and the risk inherent with using the current Atomic Energy
occupational air concentration limits (3.7E-11 yCi/ml). During this period of testing,

200 measurements were made in the monitoring of 148 persons. The determination of

workers to be monitored was done on a strictly voluntary basis. A good cross
representation of workers volunteered. The interpretation of the result is as follows:

1. Workers who showed net counts less than 60 counts per 20 minutes had less
than detectable amounts of thorium in their jungs and were therefore given a
‘negative’ result.

2. Workers showing net counts in excess of 60 counts per 20 minutes but less
than 204 were interpreted as a ‘trace’ of thorium.

LS


T-10

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

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

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

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

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

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

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

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

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

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

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


[Document No. ORAUT-TKBS-0028-4 [Revision No. 00 | Effective Date: 06/28/2605 | “Page 16 of 35 |

background value of 7.4E-04 Ba/m* (0.02 pCi/m®, Meshkov et al. 1986) was subtracted from the
values. For 1957 and 1958 at the WSCP, for which measurements are not available, the analysis
assumed that perimeter air concentrations were the same as those measured in 41959, the operational
year with the highest measured perimeter concentrations. This is probably an overestimate for the
first 2 years, when uranium receipts were lower than those during the main production years (1960-
1964; Table 2-4 in Part 2 of this Site Profile). Measured concentrations are not available for the WSQ
until 1964; until then, only drummed thorium wastes were reportedly stored at the quarry (Section
2.2.3.2 in Part 2 of this Site Profile). Most of the material was dumped at an elevation below the
present natural water table of the quarry (Weldon Spring Raffinate Pits and Quarry Task Force Report
1967). In 1963 and 1964, an estimated 38,000 m* of contaminated rubble, equipment, and soil were
placed in the WSQ, and much of this waste was not submerged. Thus, airborne concentrations of
uranium and thorium resulting from use of the WSQ were probably negligible before 1963; this
observation is supported by the measured concentrations of uranium in air in 1961 and 1962.

The uranium concentrations (Ba/m*) in Table 4-5 were converted to isotope-specific intakes, in Ba/yr,
by assuming the ratio of 1:1:0.05 for “°U:?"U:?°Th activities and multiplying by an appropriate
inhalation rate. For perimeter concentrations, intakes were calculated by multiplying by an inhalation
rate of 2400 m*/yr, representing an assumption of continuous exposure over the work year. To
address intakes associated with the localized contaminated dust arising from the reported hopper
decontamination operation outside Building 103 (noted above), the analysis assumed that the
operation took place for 1 hour per workday (12.5% of the work year) every year during the
operational period, and that unmonitored individuals were at a location in which an average
concentration of 4.4 Ba/m* occurred for 5% of their work year (approximately 24 minutes per day).
This corresponds to a yearly inhalation rate of 120 méyyr. The resulting average intakes are presented
in Table 4-6.

In Table 4-6, the °U and ““U" columns for the operational period represent the sum of “°U and **U
intakes. Since natural uranium accounted for more than 97% of the nuclear materials throughput
(Sect. 2.2.2.2 of this SPD), it is reasonable to assume that the activities of these two isotopes are
equal in the measured concentrations, as they are approximately equal in natural uranium ore
concentrates. Thorium-230 intake is assumed to be 5% of uranium isotope (in this case, either 280) oF
2°4.)) intake, consistent with the assumptions by Meshkov et al. (1986), which are based on estimates
for yellowcake composition. During the 10-year operational period, the amount of 2°Th fikely to be
present on contaminated surfaces and in air is more reflective of the amount present in the original
material being pracessed than of the daughter ingrowth due to decay of 2341) This assumption is
applicable to post-1962 intakes for the WSQ, although the ratio is less certain for waste deposited in
the quarry, which has not been well-characterized radiologically.

Although the intake values in Table 4-6 for the operational period can be attributed largely to the one
measured value of uranium downwind of the hopper cleanout operation in 1966, it is notable that the
average value of 555 Bo/yr for total uranium intake (corresponding to 277 Ba/yr for 2341) intake)
compares closely with the average estimated intake of 366 Ba/yr for 41) at the Feed Materials Plant
in Fernald, Ohio (ORAU 2004), for the same years of operation. The Fernald plant received
yellowcake in similar quantities to those received by the WSP between 1957 and 1966, and used
similar operations in processing the receipts for ultimate shipment. Table 4-7 lists site-wide maximum
intakes, representing the maximum intake each year for the areas listed in Table 4-6.

Radon

Measured air concentrations of radon during the operational period are not reported in the literature
available for this TBD. Therefore, the analysis used a very simplistic screening-level mode! for
estimating air concentrations at the WSCP, the location of the acid recovery plant, to estimate air



[Document No. ORAUT-TKBS-0028-6 [ Revision No. 00__| Effective Date: 06/24/2005 ;_.

likely the most important contributor to skin dose, because of its frequent high-energy beta emission.
Pa-234m also emits higher energy gamma rays, albeit less frequently, than other nuclides of concern
at WSP.

Table 6-1. Beta and gamma emissions of
rimary interest®

Beta energy Gamma
Radionuclide (MeV, max.) | energy (MeV)
U-238 None None
’ 0.10 (19%) [0.063 (3.5%)
Th2a4 0.193 (79%) _| 0.003 (4%)
0.766 (0.2%)
Pa-234m 2.28 (99%) br t9 6%)
0.144 (11%)
7 9.163 (5%)
U-235 None 0-186 (54%)
0.205 (5%)
0.205 (15%)
Th-234 0.287 (49%) | 0.026 (15%)
0.304 (35%) | 0.084 (6.5%)
U-234 None 0.053 (0.1%)
a. Source: Shieien, Slaback, and Birky (7998).

Radiation protection practices and exposures at WSP varied over time. There is no comprehensive
description of the practices and processes available at this time. Partial descriptions have been
discerned from several documents as discussed in the following sections. Though contemporary
references at WSP are limited there is dose information for all years discussed.

6.1.3.1 Plant Operations Period (1957 to 1966)

A film badge notification memorandum by the Health and Safety Department (MCW 1958) indicates
that the WSP film badge program began on March 1, 1958. Before that time, dosimetry performed at
WSP was more than likely provided by the MCW St. Louis plant. A memo from Brandner to Mason
(Brandner 1956a) states that some St. Louis employees transferred to the Weldon Spring plant
“where they are no longer being monitored for radiation exposure with film badges.” This agrees with
a footnote from individual film badge data summary sheets in 1966 that states “during start-up at
Weldon Spring in 1958 and later, some persons were not badged because {they were] not involved in
radiation work” (an example is shown in fig. 6A-7.)

Each employee, with the exception of “office females," (Brandner 1956a) wore a combination film
badge and security badge. The film monitors were changed biweekly or more often as necessary.
Burr (1959a) indicates that for turret lathe operators, film badges were exchanged weekly on Monday
night. However, Burr (1959b) states that “monthly exchange of film badges for ail plant personnel is
scheduled for January 30, 1959.” An undated report entitled “Personnel External Radiation
Monitoring Program” (MCW undated) describes the MCW program. It states that “wage personnel
film badges are exchanged monthly and salaried personnel film badges quarterly.” A 1965 Summary
of Health Protection Practices states that “operations badges are exchanged and processed on a
calendar month schedule, all others on a three-month schedule.” if the exchange frequency cannot
be explicitly identified, the dose reconstructor should make the claimant-favorable assumption to use
the most frequent exchange frequency for the period.

6?


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

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

Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

ES Cont)

@As noled iavhe previovs SC Cohorts for Mattinckrodt;
Man Widen Sonng Plant workers have given kKAimobvials
ous accidedts that have Occurred While worl.
Whe Went to WS in 1957, conficmed “rte
Sng bombs We bombs would Often
oUt Vi adium And otter C@mtammnantks Which wold nate
Que _tnside of the eleline Rirnace. He Qvoled That
Chemical poerators, 2lectricians, and oes hacl Sve Aushj
And ratioachve job of repAicing Hyatirnace.” Sonehmes
QyolosiOns occurred everyday tora penod of hme. The
workers’ kim hytaes aid notmeasiré amounts OF raciahort
ath uit} The badge WAS just a Koddic pice +ha+
(neasured jevel Of racianon. oF didnt record Hoamont A
Nigh level of beige aoasure Alert He Sathy co prchnet
AY recanshuct+_ whatis pow Called worksite Hse ‘reconShuchbu
@ profile. The Sateh{ deparchnent world {Go ou4 fo Worker
worksites with a Seger counter ancl ac Sampling deuces
and try to pry eet he measure of rradliat Gn dosage’ clung &
ecihe? f hme . ower wach
Adu xd Phare Were produ ch en ES even prbcessing

_ He eo, Mmenhon eol an Sgol asiOn in He Biker Hovse .TY
yang Interview, he reported
hak ta Was TEDUTE. dertocm Cech cat

mankeranc. on Yoo. adrusion press in Bldg 301 ater r+
exploded. Ne reported What He oolosion pwaced “black,
Qust" and We Sid Brinn pF vanium was volved. Ne
Slated no prea hons were Faken duning the Macident and
he veceved no Metical treatment. Singe NSH Could not
focwe Such an mncdent , ifsasrf It didnt happen. NLOSH
Nas not been able to pestonshuct ene clases tor mneicents
Wor have Yaers heen Uhi2ing worker” YeshmOny . How FS
Yris Clam ant--favorablé ?~

Lack of Accident Aicurentaren atthe WS Sie -

rcidents And incidents Phat Could podlembaiy peeae

Maenal tothe epwabons AVA And $2_Unmoyittored were

Name or Social Security Number of First Petitioner: ht


4-30

Effective Date: Revision No. {Document No. age No.
February 10, 2009 0 SCA-TR-TASK1-0028 37 of 61

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

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

3.2.3. Internal Dose ORAUT-TKBS-0028-5

Background and Introduction

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

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

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

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

4)



aS

T-23

Effective Date: Revision No. Document No. Page No.
February 10, 2009. 0 SCA-TR-TASK }-0028 33 of 61

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

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

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

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

* Validating the results of this measurement by comparing it to the average estimated
value for Fernald (see ORAUT 20054, page 16) is not supported, because conditions/
operations at the two facilities would not be sufficiently identical on a daily basis; plus
the Fernald value was based on an estimated value, not a measured value.

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

Finding #12: Lack of Validation for Maximum Environmental Dose

The TBD (ORAUT 2005d) fails to validate the adequacy of estimating the maximum
environmental dose due to source terms at differing locations at the WS site. In the current TBD,
NIOSH has offered that existing air monitoring data do not distinguish the source of emissions;
therefore, to some measure, it only allows evaluation of cumulative emissions and dose. The
estimation of dose methodology currently being applied by NIOSH does not reasonably address
maximum dose to workers who are not routinely monitored across the site. At WSCP, as many
as 50% of the site workers were not routinely monitored.

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

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

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



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

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

Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

(Cont
individval film badge lata Summany Sheers Tp
1Flplo Yhat States 'dvring Stark ve af Weldon Senne,

1n_ 1958 anc lalér, Some WwersonsS were het mdaed
pecavse tney weehor fAvelved fn raciahen work, “(rl
(DM Some wirkors recollect Fh dicoments Uere
bUcrOo. (FAD

F2

Name or Social Security Number of First Petitioner:



[Document No. ORAUT-TKBS-0028-5 | Revision No. 00__| Effective Date: 06/28/2005 |__Page 10 of 43]

Table 5-1. History of dust-generating activities.°
Perlod Activity
1957-1966 Operation of the uranium teed materials plant
« Uranium concentrates converted to uranium trioxide, uranium tetrafluoride, and uranium metal
« Some thorium processing between 1965 and 1966
* — Raffinate from processing removed to saffinate pits
» 44,500 metric tons of uranium materials received for processing and sampling per year between 1958

and 1964

December Plant closed
1966 « Hopper and process lines emptied

+ _Dust collectors cleaned out
January ‘Site used as interim storage depot for yellowcake later shipped to other plants for refining and processing.
1967-7
4967, Buildings 103 and 105 transfesred from the AEC to the Army for herbicide production
March 1968 Army started decontamination and equipment removal
December Construction of herbicide facility began; project terminated in early 1969 before renovation was complete.
1968

March 1968- | Decontamination and equipment removal for Buildings 103 and 105 (see table 5.2 for building operations
dune 1969 description)

« About 1,000 metric tons rubble remaved to the quarry

*° About 2,000 metric tons scrap moved to Tennessee

* — About 200 metric tons steel parts moved to Ohio

* About 100 metric tons uranium oxide removed from the buildings

4969-1985 Site remamned essentially undisturbed

1985 Remediation initiated by DOE — Weldon Spring Site Remedial Action Project (WSSRAP)

‘October 1986 | MK-Ferguson and Jacobs Engineering assumed responsibility for the WSSRAP.
3. Adapted from Meshkov (1986) and Lesperance, Siegel, and McKinney (1992).

Table 5-2. Potential internal radionuclide exposure for production buildings.*
Bidg. | Building

no. description Building operations Potential radionuclide exposures
104 ‘Sampling Sampling of ore concentrates containing 60 | U-nat dust, Ra-226, Th-230, Po-210 and Pb-210
~ 70% yellowcake Rn-222 and its short-lived decay products

Some material repackaged in drums — some | Th-232 and decay products in 1966
sent to Bldg 103 for processing

103 Digestion Materiais digested with nitric acid. Uranium” | U-nat dust (as yellowcake and UO,), Ra-226, Th-230, Po-
bearing solution sent to Bidg 105 for 210 and Pb-210
purification. Materials returned for Rn-222 and its short-lived decay products
denitration after purification and sent to Bldg | Th-232 and decay products starting November 1963
201.
105 Purification ‘Materials were purified by solvent extraction | Wet process but some potential for uranium or thorium (in
and returned fo Bldg 103 for denitration. 1966) dust exposure. Uranium would have been the
major internal exposure component but Rn-222 and decay
Product exposure possible
4108 ‘Acid recovery | Recovering and re-concentrating nitric acid_ | Radon gas and its decay products
201 Green salt Feed from Bidg 103 (after denitration) Potential for uranium exposure as green salt dust or
(UFs) plant converted to UFs. natural thorium (1965-66). No significant Th-230, Ra-226

or decay product exposure.

301 Metals plant | Mg used to convert UF; to U metal. Rotary | Potential for uranium exposure as green salt dust and
kin used to convert U metal chips to UsOx. | UsOs or natural thorium (1965-66). No significant Th-230,

U fuel cores produced; acceptable cores Ra-226 or decay product exposure.
shipped to reactor sites. Th-232 and decay products starting November 1963
403 Chemical pilot 7 Smaii-scale chemical processes Cnat dust, Ra-226, Th-230, Po-210 and Pb-216
plant Rn-222 and its short-lived decay products
Th-232 and decay products starting November 1963
404 Metallurgical { Small-scale metallurgical processes Potentiat for uranium exposure as green sait dust and
pilot plant Us Oe or natural thorium (1965-86) No significant Th-230,

Ra-226 or decay product exposure.

407 | Analytical and | Small-scale research and analytical work on | U-nat dust, Ra-226, ‘Th-230, Po-210 and Pb-210
research labs | products and processes. Rn-222 and its short-lived decay products
Th-232 and decay products from 1965 to 1966.

a. Adapted from ORAU (2005p).



[Document No. ORAUT-TKBS-0028-1 [| Revision No. 00__| Effective Date: 06/28/2005 [ Page 8of 11 J

of5V in natural uranium ore concentrates represents less than 5% of the activity in natural uranium,
and because the WSP processed only a small amount of slightly enriched uranium.

Radionuclide concentrations in WSP outdoor areas are based on limited environmental
measurements at the site. The total amount of uranium emitted to the atmosphere has been
estimated from monitoring data (Meshkov et al. 1986) and from a nuclear materials balance study
(DOE 1986). Based on methods and data in these two reports, the estimated uranium activity emitted
from the Plant ranged between 1 and 5 Ci/yr. An estimate of radon release, based on the amount of
uranium processed during the operational period, ranges from 12 to 34 Ci/yr, assuming radium activity
was 1% of uranium activity, radon was in equilibrium with radium, and all radon was released.
Beginning in 1981, annual environmental monitoring reports provided estimates of air concentrations
of particulate radionuclides and of radon at the WSCP and WSQ. These estimates reflect emissions
during the later maintenance period, and throughout remediation activities. The TBD analysis used
these data to derive annual estimates of intake for 1957 to 2004.

Measured air concentrations of radon during the operational period are not reported in the literature.
Therefore, a simplistic screening-level model was used to estimate air concentrations at the WSCP.

Because no site-specific ambient gamma data were available for the WSCP during the operational
period, this analysis evaluated ambient dose rates for the Feed Materials Plant in Fernald, Ohio, as
reported in ORAU (2004). The reported net average dose rate for 1956 to 1970 was 0.18 mrem/hr, or
4,576 mremvyr for continuous exposure. When this dose rate estimate is applied to the WSP
operational period, the WSP site background rate of 99 mrem/yr (Bechtel 1986) is added to derive an
ambient dose rate of 1,675 mrem/yr for continuous exposure. This corresponds to a 2,000-hr
exposure of 382 mrem. Between 1982 and 2000, thermoluminescent dosimeters monitored ambient
exposure at many perimeter locations around the WSCP, the WSRP, and the WSQ. These data are
summarized in this TBD, which summarizes estimated ambient onsite dose for the WSRP, WSCP,
and WSGQ for periods between 1957 and 2004.

1.2.4 Occupational Internal Dosimetry

The WSP Occupational Internal Dosimetry TBD (ORAUT-TKBS-0028-5) discusses the internal
dosimetry program and develops estimates of potential intakes. Radionuclides of concern at the site
include naturally occurring isotopes of uranium (“U, “*U, and *°U) and their decay products
(primarily °Th and “*Ra). Due to the amount of material processed, the primary tadionuctides of
concern for internal radiation dose are the uranium isotopes. Because WSP processed some natural
thorium, dose reconstructors should consider “Th and its decay products, ”*Ra and Th.

The primary modes of intake were chronic and acute inhalation. The internal dosimetry program
required routine monitoring of environmental radon and thoron and their decay products when an
individual was likely to receive an annual intake of 10% or more of the annual limit of intake.
According to Revision 7 of the internal Dosimetry Program Technical Basis Manual (DOE 2001), that
threshold was never exceeded. Bioassay (urine) data estimate the activity of the radionuclide
excreted in the urine following an inhalation. This TBD discusses these data, including history,
sensitivity, and pertinent nuances of methods and data.

Urine bioassay data represent the primary information available to quantify uranium intake for the
worker who is the subject of a claim. However, data are not always available for individual workers.
These data can be supplemented by workgroup monitoring data, because essentially continuous
bioassay monitoring of a worker was simulated by sampling at least one worker in the group each
week, with Monday ~ Friday ~ Monday sampling for “exposed” workers.

o?


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

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

; OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

FA Chemical @cpcsures are oFeN Nixhrs OF SUbSiances
WAlIng A SK dSeesment based On Known fori ogvcat
orvb és of Huse maienials nearly Imyoossible, Sverat Dos

reports Suqgést Uhemical harards posed a Sign Scant ae

tart sk +o beth Current and Srmer Doe workeR.
“mese SKS may ckeeed Fhose_pvoSed oy radionuclides.
@® Fom Whe keg wnning Of the nucharer onb! 1987
Yadiahon doses “frona] radioach ve Wdtenals fnhalect’ or
Wmesied bg werkers vjexe nor Carcvlaleel oriacloded in
WtHay bse _pe port SiN AWE repect fom 4117),
One CAI be ~exoasedt Hh roveh_fngeshon intp-He Mouth
of bu Absoroken WWurmugh Wourds and outs. Ofen
wounds dard CoS Gh not be determined! -for_indiuichal
werkers or dung e\posure in aCcidetsS. Alsd) While

Phore WAS No wWaArement to achalty Micviate

worker d0SCS, We" Tack oF Tnternat_racliaket dose
shat Sin worker Close records Means thatthe
telords of wWierkers Who were at nse of infernal
Cypos VES Ae In lompl&e, miskacding ,Ancl maceveie.
corbrmaken-Aabouvl expsesures Undlerstates a chal

Cy POSLTES (7-48)

Name or Social Security Number of First Petitioner: ac i

1)


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

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

Special Exposure Cohort Petition — Form B Page 4 of 7
Proposed Definition of Employee Class Covered by Petition — Complete Section E.

E.1 Name of DOE or AWE Facility: Weldon Sonn 1g lant

E.2 Locations at the Facility relevant_to this petitio
PTR ae evant linge OF he Weldon Spring Plant

jotted on Fighway 4" In ShChartes Count 0.

E.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

Ai typarrnenk pe Ener 4CQ0E), OE Contractocs, or SubContractars}
Or mic Weapens Onigloye WE lass
Worked atthe Weldon Spnng Plant dunag Oper Shoal (onod Iney-A6e.

E.4 Employment Dates relevant to this petition:

Start 19 45d End 1 (AG)
Start End
Start End
E.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: Yes Q No

if yes, provide the date(s) of the incident(s) and a complete description (attach additional pages

as necessary):
Q 12, About accidental
(S tothe environ ment duin'ag

J

Release § of radi oachve. Maren
Cperaens of He weldon Sennc Prt. Dupree CIGNA CHES
hwo _acedenial e@qosures OM Workers which occured
Guring plant operahens Snel were described Bf Mason
Quand, AWSit to CRAU in Avgust 1974, Dfe thsance, a
Worker pverflod a Dot With molten Uanul nitrate Splufen
Which solwd opt the floor. While abemehng totturn off
the valve he Pel into dre Weatenal onthe f1o0r. An incident
pepe was made Gucw i9el).Dydhe. abhor Cax%., a worker
inhawd Sduble Uranium while trapped ina dist enclusre.
“the worker suffered from "Cus" effect whch Mason
peturted WAS dave te the chemical toxicthy Of uranium
Eqposuré.. There. are ho nets Aout longer-term elects of
etlwr emplofee SMB A> v

Name or Social Security Number of First Petitioner: hl


F20

Effective Date: Revision No. ‘Document No. (Page No.
February 10, 2009 o SCA-TR-TASK]-0028 26 of 61

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

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

Finding #3: Individual Exposures versus Average Exposures

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

Calculating the dose from the radioisotopes that produce 95% or 99% of the dose, as was done in
TBD-4 (ORAUT 2005d, pages 11-12), to arrive at the conclusion that natural uranium over-rode
all the other radionuclides is not claimant favorable to some workers monitored for only natural
uranium who may have received a significant fraction of their internal and/or external doses
(either chronic or acute) ftom other radionuclides. Additionally, non-bioassayed and unbadged

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

38



TW

[Document No. ORAUT-TKBS-0028-4 | __ Revision No. 00 [ Effective Date: 06/28/2005 [Page 19 of 36]

stack or building vent release rate (Ci/s)
wind frequency

wind speed (m/s)

height of effluent release (m)

constant (m)

zAze7y
mano

Values used for the independent factors f and K correspond to the defaults in NCRP (1996), such that
fis assumed equal to 0.25 (the maximum frequency for any compass point), and Kis 1m. The
average wind speed at the WSCP from 1951 to 1970 was 4.2 m/s from the south (Weidner and
Boback 1982). The height of effluent release from the acid recovery plant is not known, but is
assumed to be 10 m.

The estimate by Meshkov et al. (1986) of an average annual release of radon (”"Rn) between 12 and
34 Cifyr (1.4 * 10° to 4.0 x 10° Ba/s) is based on the following: (1) 5,000 to 14,500 MT of uranium
materials were processed per year; (2) 70% of this was uranium; (3) radium activity was 1% of the
uranium activity (believed to be an upper end estimate); (4) radon was in equilibrium with radium, and
(5) all radon escaped during processing. Using this value in Equation 4-1, the estimated average
radon concentration within 100 m of the source is between approximately 30 and 80 Ba/m' (0.7 and

2 pCi/L). Because the radon concentrations reported here include background radon contributions,
the average value of 11 Bq/m? (0.3 pCi/L) for the Weldon Spring area (MK-Ferguson 2001 a) is added
to the calculated estimates, such that the average concentration ranges from 41 to 91 Ba/m*. This
TBD uses the upper estimate, which is a claimant-favorable assumption.

A similar estimate for thoron release from the WSCP during the operational period was not made, in
part because the type of thorium material processed is not sufficiently described in accessible
documentation. DOE (1986) states that “natural thorium was typically received in either a nitrate or
oxide form,” with no mention of it as a concentrated feed material. In addition, DOE (1986) indicates
that the amount of thorium material processed ranged from a low of 0.05% of the natural uranium
material processed in 1964 to a high of 7% in 1965. According to Wallo (1981), the ThO, mass
content, and thus the “?Th content, of natural thorium materials (like monazite sand) is approximately
5%. Assuming this and a secular equilibrium between “Th and °”“Ra and ”°Rn, it follows that the
estimated release of thoron according to the procedure above for radon is between 0.04% and 5% of
the radon release. If, however, the thorium material is assumed to be concentrated similarly to
uranium (ie., 70% *Th), the thoron release could range from 0.5% and 70% of the radon release.
Either way, the estimated dose attributable to thoron and its progeny is insignificant under these
assumptions with respect to radon and its progeny because radon progeny have a higher estimated
equilibrium factor and higher associated dose factors than thoron progeny (MK-Ferguson 2001b).

This TBD analysis estimated radon concentrations for the WSQ during the operational period from
measurements made in the vicinity from 1979 through 1982 (Meshkov et al. 1986; MK-Ferguson
1989a). Because the activities of °*Ra and “Ra are not significantly depleted in the quarry over
time, due to limited leaching and continuous production of these isotopes from precursors present in
the waste (Section 4.2.3.1), these years reasonably represent radon emanations for the WSQ during
the years of operation of the plant. These measurements are applied to the 1963-1967 period only.
Prior to that, drummed thorium waste was probably submerged and no significant source of radon
probably existed. Table 4-5 lists the average measured concentrations for this area.

Measurements of radon in 1979 through 1982 did not distinguish between ?”*Rn and *”Rn.
Therefore, the analysis made a dose-maximizing assumption that all the radon measured was “’Rn.
Because most of the dose from inhaled radon is due to alpha-emitting, short-lived daughters, the
working level month (WLM) unit is often a preferred method of reporting inhalation intake exposure to

(27


Special Exposure Cohort Petition

under the Energy Employees Occupationat
illness Compensation Act

Special Exposure Cohort Pet

B.2
B.3

B.4
B.5
B.6

C1

C.2

C3
C4

C5
C6

C7
C.7a

C.7b
C.7¢
C.7d

C.7e

Survivor Informatio:

Mr./Mrs./Ms. First Name
Social Security Number of Survivor:

Complete Section B if you are a Survivor or representing a Survivor.

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
Page 2 of 7

City State
Telephone Number of Survivor:
Email Address of Survivor:

Relationship to Employee:

Name of Employee:

Mr./Mrs./Ms. First Narvfe

Middle Initial Last Name
Former Name of Employee (e.g., maiden name/legal name change/other):

P.O. Box

Zip Code

Mr./Mrs./Ms. First Name
Social Security Number of Employee:
Address of Employee (f living):

Middle Initial Last Name

i

Street

Apt # P.O. Box

City State
Telephone Number of Employee: (

Zip Code

Email Address of Employee:

Employment Information Related to Petition:

Employee Number (if known):

Dates of Employment: star 1954 End
aF Chemical Works

Employer Name: Mailinckre

19

Work Site Location: _ Weldon Sevag Plant

supervisor's Nome: A

Name or Social Security Number of First Petitioner:



733

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

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

¢ No egress monitoring — Unmonitored external and internal doses from tack of personal

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

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

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

Total shallow dose — According to page 16 of TBD-6 (ORAUT 2005f), the dosimeters at
the WS site were calibrated using radium photon and uranium beta sources. This is
standard practice for uranium processing facilities. However, the WS site also handled
other radionuclides, as described in TBD-6 and other WS site documents; these included
Th-232 and RU with their associated decay products. Some of these radionuclides have
different beta energies than uranium. Additionally, TBD-6 does not address shallow dose
from low-energy photons, which may have been more predominate from these
radionuclides as compared to uranium. TBD-6 briefly discusses mixed beta-gamma
exposures on page 11 and states that they were determined by subtraction; it is assumed
that this means that the reading from the portion of the film behind the cadmium shield
(called SW) was subtracted from the reading of the film without cadmium shielding
(called OW), as indicated in Table 6-2 on page 12. This is not a valid procedure, unless
the beta-to-gamma ratio is known and remains constant, because beta and gamma
radiation have different darkening effects per unit dose. The response of film to gamma
radiation is very energy-dependent because of the photoelectric effect, whereas beta
interactions are not subject to this dependence. Shallow doses from both beta and low-
energy photons concerning calibration versus workplace radiation fields as a function of
location and time needs further investigation and more adequately addressed in this TBD.

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

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


Tlie

Effective Date: [Revision No, [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 12 of 61

Lack of Validation for Maximum Environmental Dose

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

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

1.1,2.2 Internal Dose ORAUT-TKBS-0028-5
Incomplete Assessment of Uranium Decay Products

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

Incomplete Assessment of Radon Exposure

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

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

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



F2ZS

Effective Date: Revision No. [Document No. Page No.
February 10, 2009 0 SCA-TR-TASK 1-0028 30 of 61

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

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

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

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

Finding #7: Photofluorography Exams Not Adequately Addressed

TBD-3 (ORAUT 2005c) mentions photofluorography (PFG) exams on page 7. However, no
recommendations to the dose reconstructor are made concerning this type of exam, other than
that there had not been any indications that PFG exams were conducted at the WSCP. ORAUT-
OTIB-0006 (ORAUT 2005g, page 21) states, “It is reasonable to presume that at least some of
the occupational medical diagnostic chest x-rays with the DOE and its predecessor organizations
were accomplished by PFG and, in the absence of data to the contrary, the use of PFG should be
assumed to ensure claimant-favorable dose reconstructions.” Table 7-6 of ORAUT-OTIB-0006
(page 24) also indicates that DOE/AEC facilities used PFG equipment from 1953-1968, which
would encompass the 1957-1966 operating period at WSCP. If PGF equipment was not located
at the WSCP site, workers may have had occupational PFG exams performed at offsite locations,
such as Barnes Hospital Labs, which serviced MCW workers in the earlier years, TBD-3
(ORAUT 2005c) does not show evidence of investigating this subject sufficiently (such as
checking Missouri state records, etc.) to justify discounting the possibility that some WS site
workers received PGF exams.

Finding #8: Lumbar Spine Exams Not Addressed

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

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



Fil

Effective Date: Revision No. {Document No. [Page No.
February 10, 2009 0 SCA-TR-TASK1-0028 29 of 61

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

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

3.2 SPECIFIC ISSUES

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

3.2.1 Occupational Medical Dose ORAUT-TKBS-0028-3

Background and Introduction

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

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

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

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

24


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

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

OMB Number: 0920-0639 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

£\ Coat
reliable dose assessment Who there Was a mixture

of Uranium 0 nds And Uranium isbrmpes (3h

Go Lack 0F NS Sie documentaten especial 4 ia Hae
“area pk neutron @xposuce_ dos imeree rospp nse avid
tatahen #eld Char adlenizaben 632)"

@_No indi@fen that mubhe exhemchy MoniPrag was
Pachoomal Ar ws duriag pevahOnal Period. 732 +5733)



[Document No. ORAUT-TKBS-0028-5 | Revision No. 00__[ Effective Date: 06/28/2005 [Page zuw =~

The sample result (in milligrams per liter) is reported under columns headed by SCHEDULED,
RESULTS, or no heading on the original data cards, and under the heading MGUPERL on the
computer printouts. On the original data cards, the sample result is frequently followed by two dashes.
and a number, which has been assumed to be the pH of the urine sample.

Following the sample result on the original data cards or in the column headed by SAMTYPE on the
computer printouts, an asterisk indicates a Friday afternoon sample. However, not all Friday samples
are flagged by the asterisk. If the sample day is important, the DR could wish to determine the actual
day using the Microsoft® Excel WEEKDAY function, which converts a date to a day-of-the-week code
where 1 is Sunday, 2 is Monday, and so forth. Written on the original data cards after the result or
under SAMTYPE on the computer printouts are notations that indicate pre-employment samples
(code P), termination samples (code 7), or special samples (code S).

5.3.1.1.6 Work Group Data

Urine bioassays were performed routinely as described in Section 5.3.1.1.1. Urine samples were
obtained weekly from representative individuals in areas of WSP where uranium was handled. The
data from the representative individuals were intended to be used to assess the intake by coworkers
so that the work group was continuously monitored. Individual urine bioassay results supplemented
by contemporaneous data from coworkers could provide the best measure of that person's uranium
intake because the sampling for an individual worker could have occurred during quiescent
operational periods.

Because most of the work group urine data summaries have not been discovered, the data have been
recreated. Approximately 28,000 urine bioassay results were recorded during the operational period
(1958 to 1966). Tables 5-8 to 5-17 provide median, 95th-percentile, and maximum concentrations for
routine urine bioassay samples by year.

The data were analyzed by major work location, cost center or job description, and sample day
(Monday or Friday). In some cases cost centers were combined to increase the number of individual
analyses. The data set for 1958 includes a mixture of WSP and Destrehan Street workers and was
coded in the original records by job description or work location rather than cost center. In cases
where there were five or fewer records, the tables contain only the maximum urine bioassay result.



1-34

[Document No. ORAUTTKBS-0028-5 |__Revision No. 00_| Effective Date: 06/28/2005 |_ Page 31 of 43]

Radiation Protection and Measurements (NCRP) discouraged its use, the special curie was
commonly employed for natural uranium. The special curie was defined in 1959 as follows (NCRP
1973):

Special curie = 3.7 * 10" d/s *°U + 3.7 x 10" d/s TMU +9 x 10° d/s *U
= 7.49% 10° dis

The definition was altered slightly in 1963 to use 1.7 x 10° d/s for 7*°U. It is important to understand
the use of the term special curie when the data are reviewed. In addition, MCW used the ratio
between the measured DWA and the guideline or standard as an index of exposure.

5.5.1.3 Dust Exposure Calculation

The total dust exposure worksheets used to record data for the MCW St. Louis site have a provision
for entering the dust concentration, but the applicable worksheet column does not listthe units. The
values are most likely the index (i.e., the DWA divided by the guideline), and there is no indication of
the source of the data. The intake calculated from urine bioassay and the intake calculated from
measured dust concentrations were averaged with equal weight given to each source. There is no
evidence to show when use of these forms was discontinued and no indication that they were used for
WSP employees.

The Annual Personnel Internal-External Radiation Exposure Report form, apparently in use by 1959
for WSP, includes a section for average dust concentration in disintegrations per minute per cubic
meter by calendar quarter. None of the exposure reports reviewed had any data in that section. This
indicates that the dust concentration was not routinely recorded. However, because the average dust
concentration, when recorded, is in units of disintegrations per minute per cubic meter, the average
daily intake can be calculated by assuming a breathing rate of 10 m*/d for typical light work for an
eight-hour work day or by using a job-specific value.

No specific in-plant air monitoring analysis sheets were found, but samples of the forms for reporting
perimeter air sample data were available. These formscould also have been used for in-plant
measurements. The forms include information on the sampling rate, time, and the gross alpha
activity. The samples were analyzed for alpha and beta activity.

5.5.1.4 Dust Studies

A study of specific areas and jobs in Building 301 was conducted in 1964 (MCW 1961). Time-
weighted average concentrations were calculated based on the number of work hours at various
positions. The measured concentrations were reported in microcuties per cubic centimeter using the
special curie unit and in micrograms per cubic meter. The data were used primarily as a basis for
recommending actions to reduce concentrations. There is no indication that the data were used to
assess intake.

An undated document titled Summaries of Dust Concentrations at Production Jobs (MCW c. 1966)
provides data on time-weighted average dust concentrations for various work areas for the period
from 1958 to 1966. The data were summarized for historic use in evaluating worker dust exposures.
The dust samples were collected on open-face Whatman No, 41 or membrane filters with areas
ranging from 3 to 5 cm*. The membrane filters had a pore size of 0.8 pm. The flow rate ranged from
10 to 20 Limin. The report notes that the samples were taken either as fixed general air samples or
as “hand held breathing zone type.”

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NY YN NY NY NY |e | Be SF KF Fe Ke Ke KS
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Bist Methng fetwH Day neo LBS

Jv a 2005

19

residues were being opened and so on. And
because they were puff exposures and we don’t
have -- we don't have the data from those puff
exposures for the individual workers, you --
you can't make reasonable estimates and the
type that I was talking about, but you could
make bounding estimates by using distributions
and 95 percentiles and so on, but you do have
to collect all the data. We discuss that we
feel that radon in many areas might be high
enough to affect non-respiratory tract organs.
The other part that -- that's unclear is what
was the history of residue processing in Plant
6, and that's not very clear so it's not ~~
it'll not be possible, we think, with the
existing data to make an accurate assumption
about radionuclide ratios in the composition of
the air. So some kind of -- if you can't find
that history exactly and we -- we didn't see an
indication that you could, then you'd have to
make some kind of maximizing assumption about
that. So a reasonable estimate is not possible
-- no distribution, no -- no time period for
processing.

Similarly we didn't find Mallinckrodt-hased

52



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

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

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

F.3 Q We have attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation
guidelines.

(Attach report to the back of the petition form.)

F.4 3 1We have attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

(Attach report to the back of the petition form.)

All Petition i . Amaximum of three persons may sign the petition.
—_ 4104/04
Signi Date

Signature Date

Signature Date

Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of
fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true.

Send this form to: SEC Petition

Office of Compensation Analysis and Support
NIOSH

4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Social Security Number of First Petitioner: