NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution.

MEMORANDUM

TO: INL Work Group 

FROM: SC&A, Inc.

DATE: July 14, 2016 

SUBJECT: SC&A’s July 2016 Progress Report: ANL-W Area Monitoring Data Review 

As part of the “SC&A Work Plan for Review of the NIOSH Petition Evaluation Report for SEC-00224 

(ER SEC-0024), ANL-W,” SC&A attempted to determine the change in the completeness and adequacy 

of the area monitoring data during the period 1951–1957 compared to 1958 going forward, since this is 

the National Institute for Occupational Safety and Health’s (NIOSH’s) proposed break point between 

granting and denying the Special Exposure Cohort (SEC). 

The Argonne National Laboratory-West (ANL-W) facilities primarily occupy two main areas on the 

Idaho National Laboratory (INL) site: the Experimental Breeder Reactor No. I (EBR-I) and the EBR-II 

complexes. Facilities in the EBR-II complex operated after 1961. EBR-I facilities of concern operated 

from 1951 to 1970. Based on the proposed 1957–1958 break point, SC&A’s review focused on the 

EBR-I facilities that operated during that time period:

• Experimental Breeder Reactor No. I (EBR-I), August 24, 1951, to December 30, 1963 

• Boiling Water Reactor Experiment No. 1 (BORAX-I), May 1953 to July 22, 1954 

• Boiling Water Reactor Experiment No. 2 (BORAX-II), October 19, 1954, to March 1955 

• Boiling Water Reactor Experiment No. 3 (BORAX-III), June 9, 1955, to December 1956 

• Boiling Water Reactor Experiment No. 4 (BORAX-IV), December 3, 1956, to June 1958 

• Zero Power Reactor No. 3 (ZPBR-III), October 1955 to November 1970 

SC&A began by examining NIOSH’s evaluation report (ER) for SEC-00224 (NIOSH 2016; hereafter 

referred to as “ER SEC-00224”) for relevant statements, comments, and citations regarding the 

availability of area monitoring data. Section 6.3.1 of the ER SEC-00224 provides an overview of the 

available ANL-W radiological monitoring data for the EBR-I complex. 

EBR-I Radiological Data

Relevant statements regarding the radiological monitoring data for EBR-1 are found in Section 6.3.1.1 

of ER SEC-00224 and are shown below: 

Radiological monitoring in the form of routine survey, smear, and air monitoring was 

performed at EBR-I from the inception of operations. However, NIOSH found limited 

quantities and types of monitoring performed during the evaluation period. Many of the 

records found were located in the personal files of the EBR-I Complex Radiation 

Protection Manager; although the records were incomplete, they included data from 

important radiological events. Air monitoring data prior to 1955 were not found. The 

amount of air monitoring data from 1955 into the early 1960s is limited, after which it 

was determined to be much more complete and comprehensive. Air samples were counted 

for beta/gamma and alpha contamination. Contamination and radiation surveys prior to 
Memo – ANL-W Area Monitoring Data Review 2 SC&A – July 14, 2016

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution.

1959 were limited, but surveys after 1960 are available. NIOSH collected a sampling of 

survey, smear, and air monitoring data for EBR-I with an emphasis on collecting as 

much alpha monitoring data as possible. 

ER SEC-00224 presents examples of air sample and smear sample data sheets for 1955 and 1961. 

However, other than the two data sheet examples, NIOSH does not provide any Site Research Database 

(SRDB) references to verify the completeness and adequacy of the EBR-1 area monitoring data in 

general or, specifically, to differentiate the periods 1951–1957 and 1958 forward. 

ZPBR-III Radiological Data

Relevant statements regarding the radiological monitoring data for ZPBR-III are found in 

Section 6.3.1.2 of ER SEC-00224 and are shown below: 

Since the beginning of operations in 1955, radiological monitoring has been performed 

at ZPR-III. NIOSH was able to find examples of air monitoring from its initial years of 

operations (Air Sample Data Sheets, 1956; Air Sample Data Sheets, 1958). More 

comprehensive air monitoring records were found for later years. Radiation and 

contamination survey programs were employed from inception due to the handling of 

uranium fuel plates. This program became more rigorous with the introduction of 

plutonium fuel plates and the recognized potential for widespread uncontrolled 

contamination if a fuel plate rupture were to occur. The completion of a radiological 

monitoring “check sheet” was required each time plutonium fuel plates were handled. 

Figure 6-8 shows an example check sheet. One of the additional monitoring prerequisites 

was direct determination of surface alpha activity on all plutonium plates at routine 

intervals as well as before and after the handling of each plate. This procedure was 

called “piece counting.” Figure 6-9 shows an example piece-counting sheet. NIOSH was 

able to collect many examples of “check sheets” and the data associated with the 

checklists.

ER SEC-00224 presents examples of a plutonium loading check sheet from 1963 and a piece-counting 

sheet from 1965, and also smear sample data sheets for 1956 and 1959. However, other than the two 

example sheets and air sampling sheets from 1956 and 1958, NIOSH does not provide any SRDB 

references to verify the completeness and adequacy of the ZPBR-III area monitoring data in general or, 

specifically, to differentiate the periods 1955–1957 and 1958 forward. 

BORAX I–IV Radiological Data 

Relevant statements regarding the radiological monitoring data for ZPBR-III are found in 

Section 6.3.1.3 of ER SEC-00224 and are shown below: 

From the onset of radiological operations through the end of the period under 

evaluation, health physics groups affiliated with ANL-W conducted air sampling and 

surveys for dose rate and contamination at the BORAX reactors. However, the degree 

and amount of radiological monitoring data available to NIOSH is very limited for 

BORAX-I through Borax-IV. NIOSH has collected a sampling of routine survey, smear, 

and air monitoring data for BORAX-V through the end of reactor operation and 
Memo – ANL-W Area Monitoring Data Review 3 SC&A – July 14, 2016

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution.

dismantling. Radiation surveys included measurements of beta/gamma and neutron dose 

rates. Smears were collected for beta/gamma and alpha contamination while air 

monitoring filters were counted for fission products and alpha releases. Figure 6-10 

shows an example of a radiation survey (Survey Reports, Jun-Aug1963) from the 

hundreds of pages of radiation surveys available to NIOSH for BORAX-V.

ER SEC-00224 presents examples of data sheets from BORAX V for 1963. However, BORAX V 

operated from February 1962 to September 1964 and is not relevant to SC&A’s inquiry. BORAX I–IV 

operated from May 1953 through June 1958. NIOSH states, “the degree and amount of radiological 

monitoring data available to NIOSH is very limited for BORAX-I through BORAX-IV,” and does not 

provide any SRDB references to verify the completeness and adequacy of the BORAX I–IV area 

monitoring data in general or, specifically, to differentiate the periods 1953–1957 and 1958 forward. 

Document Review

SC&A conducted a search of the SRDB for air sampling and contamination survey documents. The 

document search found 1,090 documents concerning ANL-W air sampling and 387 documents 

concerning contamination surveys. Table 1 shows the 26 documents relevant to the EBF-I, ZPBR-III, 

and BORAX I–IV facilities from 1956 to 1960. 
Memo – ANL-W Area Monitoring Data Review 4 SC&A – July 14, 2016

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution.

Table 1. Air Sample/Survey Documents 1956–1960 

SRDB

ID

Total 

Pages Document Title

60249 15 Air Sample Data Sheets EBR and ZPR 1959

60251 19 Air Sample Data Sheets BORAX IV 1957

138264 20 Air Sample Data Sheets Borax Reactor September 1957

138340 23 Air Sample Data EBR-I July–August 1960

138689 243 Alpha Beta Air Monitoring EBR-1 1955–1958

138685 60 Alpha Beta Gamma Survey May 1958

140394 5 Health Physics Logbook Surveys and Monitors MTR June 1, 

1958

140395 7 Health Physics Logbook Surveys and Monitors MTR May 14, 

1958

140398 12 Health Physics Logbook Surveys and Monitors MTR April 22, 

1958

140400 6 Health Physics Logbook Surveys, Smears and CAM Calibrations 

MTR April 1, 1958

140439 13 Health Physics Logbook Surveys and CAM Calibrations MTR 

January 24, 1958

143756 385 Air Sample Data Sheets and Reactor Survey Sheets for EBR-I, 

ZPR-III, and AFSR April 1959–August 1960

143774 279 

Air Sample Data Sheets, Smear Sample Data Sheets, and 

Radiation Survey Reports ZPR-III, EBR-I, BORAX and AFSR 

December 1959–December 1960

145085 17 HP Record Logbook Air Samples EBR-I January 17, 1957–

October 12, 1960

145089 77 Non-Routine Processing and Routine Survey Log Sheet ALPR 

October–December 1958

145090 240 Air Sample Data Sheets February 1955–May 1959

145094 5 Air Sample Data Sheet BORAX and ZPR May 1957

145098 4 Radiation Survey Log Sheets BORAX March 1958

145099 3 Survey Sheets BORAX July 23, 1958

145102 9 Survey Sheets BORAX May–August 1957

145104 3 Survey Sheets BORAX January 23, 1956

146418 206 Air Sample Data EBR-I 1960

146428 93 Air Sample Data, Smear Sample Data AFSR January 25, 1960–

November 6, 1961

146429 236 Air Sample Data, Building Survey Sheets EBR-I 1960

146438 88 Air Sample Data, Smear Sample Data, AFSR January 16, 1960–

November 6, 1961

150017 350 Radiation Survey Log Sheets Nos. 1 - 310 August 7, 1957–

December 21, 1957
Memo – ANL-W Area Monitoring Data Review 5 SC&A – July 14, 2016

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 USC §552a and has been cleared for distribution.

SC&A conducted a review of each of these documents. The depth of the review depended on the type of 

document and its contents. For example, less time was spent reviewing five months of survey data in 

“Radiation Survey Log Sheets Nos. 1-310 August 7, 1957–December 21, 1957” (SRDB Ref. 

ID 150017), than was spent reviewing three years of air monitoring data in “Alpha Beta Air Monitoring 

EBR-1 1955–1958” (SRDB Ref. ID 138689). 

Summary

SC&A conducted a review of the area monitoring data presented in ER SEC-00224 and documents 

found on the SRDB for EBR-1 facilities operating during the 1957–1958 timeframe. The purpose was to 

determine the completeness and adequacy of the area monitoring data for the period 1951–1957, 

compared to that from 1958 and forward. SC&A concludes that while the air monitoring and survey data 

may not be complete for each year and facility, SC&A did not find a clear distinction between the 

completeness and adequacy of the data for any particular year or facility that would validate NIOSH’s 

proposed SEC cutoff date of 1957. 

In Section 7.2 of ER SEC-000224, NIOSH discusses the potential use of the area monitoring data as an 

alternate method to bound internal doses. However, NIOSH further states that it does not have plans to 

use this method. Therefore, at this time, SC&A believes it is best to concentrate resources on reviewing 

actual personnel monitoring results. 

Reference

NIOSH 2016. SEC Petition Evaluation Report, Petition SEC-00224, National Institute for Occupational 

Safety and Health. February 18, 2016.