1608 SPRING HILL ROAD, SUITE 400 • VIENNA, VIRGINIA • 22182 • 703.893.6600 • FAX 703.821.8236 

December 30, 2008 

Mr. David Staudt 

Center for Disease Control and Prevention 

Acquisition and Assistance Field Branch 

Post Office Box 18070 

626 Cochrans Mill Road – B-140 

Pittsburgh, PA 15236-0295 

Re: Contract No. 200-2004-03805, Task Order 1: Draft Report SCA-TR-TASK1-0005, 

Supplement 1, Idaho National Laboratory (INL) Site Profile Review Update

Dear Mr. Staudt: 

SC&A is pleased to submit its draft report, Idaho National Laboratory (INL) Site Profile Review 

Update, SCA-TR-TASK1-0005, Supplement 1. The original site profile review, dated January 

25, 2006, reviewed the 2004 versions of the six TBDs. Given the amount of time that has passed 

since that review and the subsequent issuing of revised TBDs in 2007, it was the judgment of the 

Advisory Board that a supplementary review of the site profile was appropriate before beginning 

the issues resolution process by the recently formed INL Work Group. 

This report has been cleared by DOE, and reviewed and cleared for Privacy Act information, and 

is now cleared for unrestricted distribution. 

Should you have any questions, please contact me at 732-530-0104. 

Sincerely, 

John Mauro, PhD, CHP 

Project Manager 

cc: P. Ziemer, Board Chairperson A. Makhijani, SC&A 

Advisory Board Members H. Behling, SC&A 

C. Branche, NIOSH S. Ostrow, SC&A 

L. Elliott, NIOSH J. Zlotnicki, SC&A 

J. Neton, NIOSH J. Fitzgerald, Saliant 

S. Hinnefeld, NIOSH J. Lipsztein, SC&A 

L. Homoki-Titus, NIOSH K. Robertson-DeMers, Saliant 

A. Brand, NIOSH S. Marschke, SC&A 

J. Broehm, NIOSH K. Behling, SC&A 

C. Ellison, NIOSH T. Bell, Saliant 

L. Shields, NIOSH Project File (ANIOS/001/05) 

D. Sundin, NIOSH 
 

Draft Report 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

Idaho National Laboratory (INL) 

Site Profile Review Update 

Contract No. 200-2004-03805 

SCA-TR-TASK1-0005, Supplement 1 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

December 2008 

Disclaimer

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
Effective Date: 

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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. 

SCA-TR-TASK-0005-S1 

Effective Date: 

 Draft – December 10, 2008 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of NIOSH 

Dose Reconstruction Program Revision No: 

 0 – Draft 

Idaho National Laboratory (INL) 

Site Profile Review Update Page 2 of 28

Task Manager: 

_____________________ Date: ____________ 

Stephen L. Ostrow, PhD 

Supersedes: 

N/A 

Project Manager: 

_____________________ Date: ____________ 

John Mauro, PhD, CHP 
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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.

TABLE OF CONTENTS 

1.0 Introduction..........................................................................................................................4 

2.0 Revisions to the Originally Reviewed Site Profile ..............................................................5 

2.1 Introduction..............................................................................................................5 

2.2 Site Description........................................................................................................5 

2.3 Occupational Medical Dose.....................................................................................6 

2.4 Occupational Environmental Dose ..........................................................................7 

2.5 Occupational Internal Dose......................................................................................7 

2.6 Occupational External Dosimetry............................................................................8 

3.0 SC&A Issues Assessment..................................................................................................10 

3.1 Issue 25: Discrepancies between PIC and Film Reading......................................10 

3.2 Issue 26: Minimum Detection Limit.....................................................................12 

3.3 Issue 29: Failure to Properly Address Neutron Exposures...................................12 

3.4 Issue 35: Multiplying Factors for Missed Neutron Dose......................................13 

3.5 Issue 36: Missed Low Energy Beta Dose .............................................................14 

3.6 Issue 37: Error in Reference .................................................................................15 

3.7 Issue 38: Shallow Dose.........................................................................................15 

3.8 Conclusion .............................................................................................................15 

4.0 References..........................................................................................................................16 

Attachment 1: Issues Resolution Matrix for Findings and Key Observations .............................18 
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1.0 INTRODUCTION 

At the request of the Advisory Board on Radiation and Worker Health, SC&A performed a brief, 

supplemental review of the latest revisions of the six Idaho National Laboratory (INL) Technical 

Basis Documents (TBDs), which were issued in 2007 (ORAUT 2007a-f); the TBDs, when taken 

together, are often referred to as the Site Profile. SC&A had reviewed earlier revisions of the 

TBDs (ORAUT 2004a-f), issued in 2004, and other documents and presented its findings in its 

Site Profile Review Report (SC&A 2006). It is not the intent of this update report to re-review 

the site profile in depth or to do a detailed comparison of the two site profiles. This update report 

will refer to the previously reviewed site profile as the “2004 Site Profile” and the latest site 

profile as the “2007 Site Profile.” SC&A 2006 is Rev. 1 of the originally-issued report of 

September 23, 2005 (SC&A 2005); the revision included the additions of Attachment 3, 

“Summaries of Site Expert Reviews,” and Attachment 5, “Issues Resolution Matrix for Findings 

and Key Observations,” but made only minor changes to the remainder of the report. 

It is intended that this update report will serve as a reference document for use by the recently 

formed Board Work Group on the Idaho National Laboratory. Since a significant amount of 

time has passed since the SC&A Site Profile Review Report, the approach to dose reconstruction 

has evolved, new information about the site may have come to light, and NIOSH may have 

incorporated material generated in response to SC&A’s comments to the 2004 Site Profile. The 

35 issues identified in the SC&A report are summarized in the Issue Resolution Matrix found in 

Attachment 5 to SC&A 2006. 

In performing its current review, SC&A read the 2007 Site Profile TBDs in light of the 

comments appearing in its Site Profile Review Report to assess whether the revised TBDs 

appeared to respond to the comments therein. SC&A also reviewed Technical Information 

Bulletins (TIBs) that were issued subsequent to the 2004 Site Profile to ascertain whether they 

would have a significant impact on the SC&A comments. Finally, SC&A conducted a search for 

any relevant material that might have been placed on the O-drive since the end of 2005; no such 

material was found, however. 

For convenience in considering SC&A’s comments (old and new), this report attaches a revised 

Issues Resolution Matrix that has two new columns: one noting if a particular comment was 

added, removed, expanded, reduced, upgraded, or unchanged from the original matrix, and the 

other providing any related comments. Section 2.0 of this report examines the publication 

records (i.e., revision logs) of the TBDs to note the changes that NIOSH thought important from 

one revision to the next, and Section 3.0 discusses the revisions made to the SC&A comments, 

which appear in the attached matrix. 
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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.

2.0 REVISIONS TO THE ORIGINALLY REVIEWED SITE PROFILE 

A starting point in assessing the status of the 2007 Site Profile is to compare it to the one 

originally reviewed in SC&A 2006, the 2004 Site Profile. Since it is not the purpose of this 

report to do a detailed assessment and comparison of the site profiles, the following sections will 

focus on what NIOSH has noted as the changes in each TBD from one revision to the next, as 

recorded in the Publication Records (“revision logs”). It should be noted that even seemingly 

minor revisions, such as in the description of a process or location, or in a table, might have an 

effect on assigned doses, but not necessarily also have an impact on the issues that SC&A 

identified in its review of the 2004 Site Profile. 

2.1 INTRODUCTION 

This section compares the originally reviewed ORAUT 2004a (Rev. 0) to the current ORAUT 

2007a (Rev. 2). Table 2-1 reproduces the Publication Record of ORAUT 2007a. 

Table 2-1. Publication Record 

Effective 

Date 

Revision 

Number Description 

5/7/2004 0 New document for the INEEL Introduction. Incorporates responses to OCAS 

comments. First approved issue. Initiated by Norman D. Rohrig. 

12/13/2006 1 Approved revision as a result of biennial review. Revised language in the Purpose 

section as required by NIOSH. Attribution and Annotation section added. 

Constitutes a total rewrite of document. Incorporates internal, NIOSH, and DOL 

formal review comments. This revision results in no change to the assigned dose 

and no PER is required. Training required: As determined by the Task Manager. 

Initiated by Norman D. Rohrig. 

4/26/2007 2 Approved Revision 02 revised to change document owner and to better identify 

references in the text. This revision results in no change to the assigned dose and 

no PER is required. Training required: As determined by the Task Manager. 

Initiated by Jo Ann M. Jenkins. 

Source: ORAUT 2007a 

2.2 SITE DESCRIPTION 

This section compares the originally reviewed ORAUT 2004b (Rev. 1) to the current ORAUT 

2007b (Rev. 3). Table 2-2 reproduces the Publication Record of ORAUT 2007b. 

Table 2-2. Publication Record 

Effective 

Date 

Revision 

Number Description 

11/7/2003 0 New technical basis document for the Idaho National Engineering and 

Environmental Laboratory — Site Description. First approved issue. Initiated by 

Norman D. Rohrig. 

7/28/2004 1 Corrects date of operation in Section 2.4.11 and adds OGC required paragraphs. 

Approved issue of Revision 01. Initiated by Norman D. Rohrig. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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Table 2-2. Publication Record 

Effective 

Date 

Revision 

Number Description 

7/29/2005 2 Adds additional descriptive material on ICPP in response to union outreach 

comments. Incorporates formal internal and NIOSH review comments. Approved 

issue of Revision 02. Retraining is not required. Initiated by Norman D. Rohrig. 

8/17/2007 3 Approved Revision 03 initiated to add Attributes and Annotations section. Added 

references. Incorporates formal internal and NIOSH review comments. Training 

required: As determined by the Task Manager. Initiated by Jo Ann M. Jenkins. 

Source: ORAUT 2007b 

2.3 OCCUPATIONAL MEDICAL DOSE 

This section compares the originally reviewed ORAUT 2004c (Rev. 0) to the current ORAUT 

2007c (Rev. 1). Table 2-3 reproduces the Publication Record of ORAUT 2007c (including the 

signature block for Rev. 0, PC-1, which appears in the original document). 

Table 2-3. Publication Record 

Effective 

Date 

Revision 

Number Description 

 1/15/2004 0 New Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory — Occupational Medical Dose. First approved issue. 

Initiated by Norman D. Rohrig. 

 5/28/2004 0 PC-1 Adds spleen to organ table on page 10. Eliminates date overlap in table on page 11. 

Initiated by Norman Rohrig. 

Approval: 

Signature on File 5/27/2004

Norman D. Rohrig, Document Owner 

Signature on File 5/27/2004

Task 3 Manager, Judson Kenoyer, Task 3 Manager 

Signature on File 5/27/2004

Richard E. Toohey, Project Director 

Signature on File 5/27/2004

James W. Neton, OCAS Health Science Administrator 

1/31/2007 1 Approved Revision 01 as a result of biennial review. Revised language in the 

Purpose section as required by NIOSH. Attributions and Annotations section 

added. Changed treatment of eye and brain dose. As a result of internal formal 

review, add Table 3-3. Incorporates NIOSH formal review comments. This 

revision results in an increase in assigned dose and a PER is required. Constitutes a 

total rewrite of document. Initiated by Norman D. Rohrig. 

Source: ORAUT 2007c 
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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.

2.4 OCCUPATIONAL ENVIRONMENTAL DOSE 

This section compares the originally reviewed ORAUT 2004d (Rev. 0) to the current ORAUT 

2007d (Rev. 1). Table 2-4 reproduces the Publication Record of ORAUT 2007d. 

Table 2-4. Publication Record 

Effective 

Date 

Revision 

Number Description 

3/30/04 0 New Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory — Occupational Environmental Dose. First approved 

issue. Initiated by Norman D. Rohrig. 

8/17/07 1 Approved Revision 01 initiated to add additional information on how TLD results 

were chosen. Added Purpose, Scope, and Acronyms sections. Added references 

and SRDB numbers. Changed Idaho National Engineering and Environmental 

Laboratory to Idaho National Laboratory. Incorporates formal internal and NIOSH 

review comments. Adds Attributions and Annotations section. Incorporates formal 

internal and NIOSH review of the Attributions and Annotations section. 

Constitutes a total rewrite of the document. Training Required: As determined by 

the Task Manager. Initiated by Jo Ann M. Jenkins. 

Source: ORAUT 2007d 

2.5 OCCUPATIONAL INTERNAL DOSE 

This section compares the originally reviewed ORAUT 2004e (Rev. 0, PC-1) to the current 

ORAUT 2007e (Rev. 2). Table 2-5 reproduces the Publication Record of ORAUT 2007e. 

Table 2-5. Publication Record 

Effective 

Date 

Revision 

Number Description 

8/11/2004 0 New Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory — Occupational Internal Dose. First approved issue. 

Initiated by Norman D. Rohrig. 

10/12/2004 0, PC-1 Approved page change revision. Deletes references to rigorous radiation program 

on page 39. Initiated by Norman Rohrig. 

Approval: 

Signature on File 9/30/2004

Norman D. Rohrig, Document Owner 

Signature on File 10/1/2004

Judson Kenoyer, Task 3 Manager 

Signature on File 10/1/2004

Richard E. Toohey, Project Director 

Signature on File 10/12/2004

James W. Neton, Associate Director for Science 
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Table 2-5. Publication Record 

Effective 

Date 

Revision 

Number Description 

1/13/2006 1 Approved issue of Revision 01. Revised to change table number format, responds 

to new information from Workers Outreach Effort and revises MDA tables. 

Incorporates 1-year decay time for Al fuel in Tables 5-18 and 5-24. Combined 

“INTEC & Unknown” and “Other Area” categories in Table 5-24 for 1971-80 into 

“All but ANL-W.” Training required: As determined by the Task Manager. 

Initiated by Norman D. Rohrig. 

6/5/2006 1, PC-1 Page change revision to correct error on page 24 in Table 5-12 in Section 5.5 on 

sample volume in 1980s. Approved issue of Rev. 01 PC-1. No sections were 

deleted. Incorporates NIOSH formal review comments. This revision results in a 

reduction in assigned dose and no PER is required. Training required: As 

determined by the Task Manager. Initiated by Norman D. Rohrig. 

Approval: 

Signature on File 5/23/2006

John M. Byrne, Document Owner 

Signature on File 5/23/2006

John M. Byrne, Task 3 Manager 

Signature on File 5/22/2006

Edward F. Maher, Task 5 Manager 

Signature on File 5/24/2006

Kate Kimpan, Project Director 

Signature on File 6/5/2006

James W. Neton, Associate Director for Science 

7/30/2007 2 Revision initiated to add Purpose, Scope, and Attributions and Annotations 

sections. Added references. Updated the formatting and made editorial changes. 

Corrected error in Fecal MDA for Th-230 and Np-237 in Table 5-13. Constitutes a 

total rewrite of the document. Incorporates formal internal and NIOSH review 

comments. Training required: As determined by the Task Manager. Initiated by Jo 

Ann M. Jenkins. 

Source: ORAUT 2007e 

2.6 OCCUPATIONAL EXTERNAL DOSIMETRY 

This section compares the originally reviewed ORAUT 2004f (Rev. 0) to the current ORAUT 

2007f (Rev. 2). Table 2-1 reproduces the Publication Record of ORAUT 2007f. 

Table 2-6. Publication Record 

Effective 

Date 

Revision 

Number Description 

4/6/2004 0 New technical basis document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) — Occupational External Dosimetry. First 

approved issue. Initiated by Norman D. Rohrig. 

11/7/2006 1 Document revised as a result of biennial review. Approved Revision 01. 

Incorporates formal internal review comments. Revision constitutes a total rewrite 

of document. Adds Section 6.5.1 to incorporate comments from the Worker 

Outreach meeting with the PACE Local 8-0652 on April 28, 2004. Incorporates 
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Table 2-6. Publication Record 

Effective 

Date 

Revision 

Number Description 

formal NIOSH review comments. This revision results in no change to the 

assigned dose and no PER is required. Training required: As determined by the 

Task Manager. Initiated by Norman D. Rohrig. 

6/18/2007 2 Approved Revision 2 initiated to incorporate Attribution and Annotation section. A 

minor change was made to Sections 6.3.4.5 and 6.5.4.2, which will reduce the dose 

for a very few individuals. Incorporates formal internal and NIOSH review 

comments. Constitutes a total rewrite of the document. This revision results in no 

change to the assigned dose and no PER is required. Training required: As 

determined by the Task Manager. Initiated by Jo Ann M. Jenkins. 

Source: ORAUT 2007f
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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.

3.0 SC&A ISSUES ASSESSMENT 

SC&A examined the 2007 Site Profile TBDs and compared them to the corresponding 2004 

TBDs, which were the subject of the original SC&A assessment report, SC&A 2006. Issues1

identified by SC&A (divided into findings and observations, as illustrated in Figure 3-1) are 

summarized in Attachment 1 to this report: “Issue Resolution Matrix for Findings and Key 

Observations.” The matrix was derived from the Attachment 5, Table A-5 matrix in SC&A 2006 

by adding a column indicating SC&A’s new assessment of each issue and a column containing 

comments for some issues. The original matrix contained 35 issues, divided into 18 observations 

and 11 distinct findings (several of the 17 issues categorized as findings were combined to 

produce 11 distinct findings). The new matrix corrected one issue (No. 2), expanded four issues 

(Nos. 25, 26, 29, 35), and added three new issues (Nos. 36, 37, 38) for a total of 38 issues. In 

addition, one of the original observations (No. 26) was upgraded to a finding (No. 12). 

Issues 

Findings Observations 

Figure 3-1. Issues Divided into Findings and Observations 

Table 3-1 summarizes the number and division of issues in the matrices in SC&A 2006 and this 

report. 

Table 3-1. Issue Resolution Matrix Summary 

SCA 2006 This Report 

Issues 35 38 

 Distinct Findings 11 13 

 Observations 18 19 

Revisions to the original matrix of SC&A 2006 will be discussed in turn. 

 

3.1 ISSUE 25: DISCREPANCIES BETWEEN PIC AND FILM READING 

This issue was expanded from SC&A 2006 by adding the following to the matrix description: 

“Many difficulties in comparing PIC readings and film results make agreement within a factor of 

two the best that can be expected.” 

Attempting to compare PIC and film readings is fraught with difficulties. SC&A 2006 focuses 

on the beta-to-photon ratio issue. This is a concern, but only one of several. Perhaps of greater 

importance in many situations are the large energy-dependent response differences between the 

two classes of dosimeter. Unfortunately, we do not have detailed information regarding the 

 1

 Note that the matrices use the terms “issue” and “comment” interchangeably. 
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types of PIC used and their wall characteristics; the PICs are described in very general terms in 

several contemporaneous documents available on the NIOSH O-drive document collection. 

Generally, early PICs had a wall that was opaque to x-rays below about 40–80 keV, where there 

is also a large over-response for uncorrected film emulsions. Thus, depending on the situation, 

the film-to-PIC reading ratio varies greatly with photon energy over the range of just a few tens 

of keV. 

It should be noted that, even under current conditions, a film dosimetry system and older style 

PIC device could both be working within DOELAP (Department of Energy Laboratory 

Accreditation Program) or NVLAP (National Voluntary Laboratory Accreditation Program) 

requirements, while readings from the two could still differ by a factor of two even at energies 

where the PIC is responsive. When energy cutoff and human error factors are considered as 

well, large variations in comparing the readings from the two different measurement methods are 

to be expected. Somewhat mitigating the difference in readings, however, is that since many of 

the sources of error and disparity are independent, they will sum in quadrature, reducing their 

overall impact. Thus, the value of comparing the two dosimetry methods is limited, even if 

variations of a factor of two are accepted and even if averaged over an entire year. Some of the 

factors that would lead to disagreement between the two dosimeter readings are summarized in 

the following: 

Technical Factors

• Cut off for low x-ray energies due to PIC construction. 

• Widely differing energy response of film and PICs to x-rays and low energy gammas. 

• Widely differing responses as a function of beta energy. 

• Added variable of the film algorithm. This has a number of impacts including 

mischaracterization of beta radiation as x-ray radiation in early film badge systems, 

under-reporting deep dose for some photon energies, and, overall wide swings in energy 

response. These disparities are due to an only partially successful effort to smooth out 

the factor of 30 over response of film emulsion to x-ray energies compared with high 

energy gammas. 

• Calibration systems may be different. 

• Zeroing, reading, and rounding errors. (PICs have no control or background subtraction, 

are usually read after being worn for short periods, and are difficult to read precisely). 

• Mechanical errors (PICs). 

• Temperature and humidity effects (Film). 

• Processing variables (Film). 

• Angular response differences between the two devices. This can be a large problem with 

x-ray energies when exposure from the side of the film holder can bypass the filters and 

cause a large over response. 
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Human Factors

• Were both dosimeters worn in close proximity to each other?; i.e., were they in an 

identical radiation field to begin with? 

• Were both dosimeters worn for the entire period in question? 

• Was there a bias introduced in reading one’s own PIC? 

• Were errors made in reading, transcribing, and matching PIC doses with the relevant film 

dosimeter? 

3.2 ISSUE 26: MINIMUM DETECTION LIMIT 

This issue was expanded from SC&A 2006 and upgraded from an observation to a finding by 

adding the following to the matrix description: 

The selection of 10 mrem as the MDL [minimum detection limit] for high energy 

gamma is questionable. Even for modern densitometers and film, it is a challenge 

to achieve this level, as a single density “click” can correspond to greater than 10 

mrem for high-energy gamma radiation; this is not a problem, however, for 

intermediate and low-energy x-rays. Rather, one click of the densitometry system 

may correspond to 15 or 20 mrem for 660 keV or 1.2 MeV gammas, for example. 

If the claim is made that 10 mrem is a valid choice for the MDL, then supporting 

materials should be provided, such as film dose-to-density curves and 

densitometer calibration data. Other sites (e.g., Savannah River Site - SRS) have 

adopted 40 mrem as the high-energy gamma MDL for early film. 

3.3 ISSUE 29: FAILURE TO PROPERLY ADDRESS NEUTRON EXPOSURES 

This issue was expanded from SC&A 2006 by adding the following to the matrix description: 

The method presented in the TBD of determining who needs to be assigned a 

missed neutron dose is circular: Section 6.5.4 states: “If no neutron dose was 

assigned to the worker or coworkers for several months, the dose reconstructor 

should assume that the person was not exposed to neutrons.” Clearly this does 

not allow for individual workers having temporary or varying assignments. Also, 

if the program failed to correctly identify that they should have been monitored, 

the record will show no assigned neutron dose. 

In addition, the TBD makes the assumption that high Z materials, such as iron and 

lead, were never used (e.g., for shield penetrations) in place of hydrogenous 

materials, such as water and concrete. However, no attempt is made to validate or 

qualify this assumption. 

ORAUT-OTIB-0051, Effect of Threshold Energy and Angular Response of NTA 

Film on Missed Neutron Dose at the Oak Ridge Y-12 Facility, was issued after the 

2004 Site Profile and has a bearing on neutron dosimetry issues; hence, it should 

be considered in this TBD. 
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ORAUT-OTIB-0051 (ORAUT 2006, May 15, 2006) was issued subsequent to the SC&A review 

(SC&A 2006), but is not referred to in the latest version of the INL external dose TBD (ORAUT 

2007f), which has an effective date of June 18, 2007. This TIB specifically investigates the NTA 

film neutron energy threshold issue. Based on this TIB, dependant on energy and angle, a factor 

of up to 2.9 is recommended to adjust for underreported intermediate energy neutron dose at 

Y12. This is significantly higher than the factors of 1.25 and 2 contained in the current INL 

TBD. NIOSH should consider which, if any, of the issues considered for Y12 are applicable to 

the INL facilities; perhaps an even larger multiplication factor is warranted in some areas. Any 

review will need to consider the site-specific ORAUT-OTIB-0009 (ORAUT 2004g) that 

reanalyzed the Bonner sphere work conducted by Hankins at INL. 

Despite the fact that application of ORAUT-OTIB-0051 would increase the correction factors for 

NTA under response, it may still underestimate the true problem; NTA counting for tracks at the 

lower energy cutoff is difficult and subject to error. The TIB discusses these issues, but may not 

give sufficient consideration to real-world counting conditions; it is not clear how data gathered 

during careful tests under ideal conditions should be applied to day-to-day dosimetry operations 

that took place 50 years ago. Significant human factors are involved in counting NTA film, 

especially when near the limits of energy and dose detection. A review of this issue is 

recommended. 

In Table 6.12 of the TBD (ORAUT 2007f), a 500 keV threshold is mentioned for NTA film 

neutron detection. Elsewhere in the document, a 500-800 keV value is used. Other sources use 

an 800–1,000 keV value. Original site reference material (Sommers undated) notes that the 

minimum detectable energy is 800 keV. The value chosen is important, as a significant 

component of the neutron spectrum can be below the detection threshold, depending on the 

location, method of neutron generation, and the degree of thermalization that has occurred in 

intervening materials. Clear guidance is needed to enable dose reconstructors to correctly 

interpret and assess missed dose. ORAUT-OTIB-0051, and a possible supplement specifically 

for INL, could be used to clear up the confusion with regard to energy threshold. 

Whatever multiplying factors are adopted, correction for NTA under response should not be 

spread uniformly among the various IREP neutron energy groups, as shown in Table 6-14 of the 

TBD (ORAUT 2007f). Instead, all under reported dose should be assigned to the IREP groups 

corresponding to energies lower than 800 keV. Current procedure calls for multiplying the 

reported dose by the modifying factor and then assigning the results to all energy groups. This 

will assign too much of the dose to higher energies and too little to lower energies. 

3.4 ISSUE 35: MULTIPLYING FACTORS FOR MISSED NEUTRON DOSE 

This issue was expanded from SC&A 2006 by adding the following to the matrix description: 

“See ORAUT-OTIB-0051 and Issue No. 29.” 

Section 3.3 contains a discussion relevant to this issue. 
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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.

3.5 ISSUE 36: MISSED LOW ENERGY BETA DOSE 

This is a new issue, and is characterized as finding No. 13. The matrix entry states the 

following: 

Section 6.3.2.2 of the TBD [ORAUT 2007f] discusses the 100mg/cm2

 plastic 

dosimeter holder and the fact that betas of less than 360 keV will not penetrate 

the holder. (It is unclear if this density includes the film wrapper.) However, the 

TBD does not discuss allowance for or consideration of the possibility of the 

complete failure to detect these betas. 

The general, averaging approach to missed beta is questionable. The concern is 

that beta exposure is always assumed to be due to a mix of energies and thus the 

dose component from low energies is known and can be corrected. Clearly this is 

not the case, as is stated in the attribution. 

A specific concern is the Rare Gas Processing Facility (CPP-604), which 

harvested Kr-85. This nuclide is a pure beta emitter, with an endpoint energy of 

670 keV. The film badges in use at the time were far from ideal for betas and 

failed to see any below 360 keV. NIOSH should determine if the maximum 

modifier recommended for betas of 2.8 is sufficient for this environment.

Table 6.10 (ORAUT 2007f) provides a beta correction factor of 2.8 for multifilter film. 

However, in the case of exposure to low-energy betas, the factor is inappropriate and an alternate 

means of deriving low energy beta dose is required. Furthermore, the whole approach to missed 

beta is questionable. For example, Attribution [13] in the TBD states: “Rohrig, Norman D. 

ORAU Team. Health Physicist. June-October 2003. Retrospectively, there is no simple way of 

knowing the beta emitters that caused employee X’s exposure in week Y, so this is a generic 

approach to the issue.” This was by way of explanation for the following: “Beta-emitting 

nuclides varied from location to location and time to time at INL, so a correction factor common 

for all facilities was estimated” (ORAUT 2007f, 30). The concern with this averaging approach 

is that beta exposure is always assumed to be due to a mix of energies, and thus the dose 

component from low energies is known and can be corrected. Clearly this is not the case, as is 

stated in the attribution. 

A specific concern is the Rare Gas Processing Facility (CPP-604), discussed on p. 30 of the 

TBD, which harvested Kr-85. This nuclide is a pure beta emitter with an endpoint energy of 670 

keV. There would be opportunity for worker exposure to Kr-85 betas during processing, any 

accidental releases, or deliberate venting. As this work was performed in the 1950s, we know 

that the film badges in use at the time were far from ideal for betas and failed to see any below 

360 keV. NIOSH should determine if the maximum modifier recommended for betas of 2.8 is 

sufficient for this environment. 
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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.

3.6 ISSUE 37: ERROR IN REFERENCE 

Issue 37, which is characterized as an observation, is quite minor and states: “The second 

paragraph of page 41 of the External Dose TBD (ORAUT 2007f) references Table 6-16 for IREP 

groups; it should refer to Table 6-14 instead.” 

3.7 ISSUE 38: SHALLOW DOSE 

Issue 38, which is characterized as an observation, states: “NIOSH should consider making use 

of ORAUT-OTIB-0017, Technical Information Bulletin: Interpretation of Dosimetry Data for 

Assignment of Shallow Dose (ORAUT 2005), where appropriate. Additionally, contrary to the 

OTIB’s claim (p. 15) that the assumption of undergarment and pants thicknesses of 2 mm each is 

claimant favorable, SC&A believes that measured thicknesses are about half that and, hence, the 

OTIB assumptions are not claimant favorable.” 

In the course of reviewing the 2007 NIOSH Site Profile, SC&A examined ORAUT-OTIB-0017 

(ORAUT 2005) as well. This OTIB, which SC&A reviewed in SC&A 2007, is not referenced 

by the External Dose TBD (ORAUT 2007f), but may be germane nonetheless. OTIB-0017 

states the following: 

For modeling purposes it is assumed that male workers wore pants or shorts and 

one layer of undergarments. Pants were assumed to have a thickness of 2 mm 

and a density of 0.7 g/cm3 while the layer of undergarment was also assumed to 

have a thickness of 2 mm and a density of 0.7 g/cm3. These estimates are 

considered to be claimant favorable. 

SC&A conducted some experimental research and determined that the thickness of men’s 

undergarments are less than 1 mm thick and jeans about 1 mm thick. Women’s clothing is 

expected to be even thinner. Hence, the OTIB assumptions do not appear to be claimant 

favorable for assignment of shallow beta doses. 

3.8 CONCLUSION 

Overall, the original SC&A review of the 2004 Site Profile is still current and valid, as none of 

the findings of SC&A 2006 appear to have been addressed in the revised TBDs of the 2007 Site 

Profile. In addition, following its current review of the two Site Profiles and other documents, 

SC&A modified or added a number of findings and observations, as summarized in the Issue 

Resolution Matrix. Other documents surveyed included the ORAUT-OTIBs (about 25) that have 

been issued or revised subsequent to the 2004 Site Profile; SC&A did not note any relevance to 

the site profile, with the possible exception of ORAUT-OTIB-0017 (see Issue 38). SC&A also 

looked at the one INL Program Evaluation Report, OCAS-PER-017 (OCAS 2007), pertaining to 

the INL site, and found that it did not impact the site profile. 
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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.

4.0 REFERENCES 

OCAS 2007. Evaluation of Incomplete Internal Dosimetry Records from Idaho, Argonne East 

and Argonne-West National Laboratories, OCAS-PER-017, Rev. 0, September 11, 2007. 

ORAUT 2004a. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Introduction, ORAUT-TKBS-0007-1, Rev. 0, Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. May 7, 2004. 

ORAUT 2004b. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Site Description, ORAUT-TKBS-0007-2, Rev. 1, Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. July 28, 2004. 

ORAUT 2004c. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational Medical Dose, ORAUT-TKBS-0007-3, 

Rev. 0, PC-1, Oak Ridge Associated Universities Team, Cincinnati, Ohio. May 28, 2004. 

ORAUT 2004d. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational Environmental Dose, ORAUT-TKBS-0007-

4, Rev. 0, Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 30, 2004. 

ORAUT 2004e. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational Internal Dose, ORAUT-TKBS-0007-5, 

Rev. 00, PC-1, Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 12, 2004. 

ORAUT 2004f. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational External Dosimetry, ORAUT-TKBS-0007-

6, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 6, 2004. 

ORAUT 2004g. Technical Information Bulletin in Support of INEEL Technical Basis Document 

Section 6: Reanalysis of Hankins MTR Bonner Sphere Surveys, ORAUT-OTIB-0009, Rev. 0, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 17, 2004. 

ORAUT 2005. Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment 

of Shallow Dose, ORAUT-OTIB-0017, Rev. 01, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. October 11, 2005.

ORAUT 2006. Effect of Threshold Energy and Angular Response of NTA Film on Missed 

Neutron Dose at the Oak Ridge Y-12 Facility, ORAUT-OTIB-0051, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. May 15, 2006. 

ORAUT 2007a. Idaho National Laboratory - Introduction, ORAUT-TKBS-0007-1, Rev. 2, Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. April 26, 2007. 

ORAUT 2007b. Idaho National Laboratory - Site Description, ORAUT-TKBS-0007-2, Rev. 3, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 17, 2007. 
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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.

NOTICE:

ORAUT 2007c. Idaho National Laboratory - Occupational Medical Dose, ORAUT-TKBS0007-3, Rev. 1, Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 31, 2007. 

ORAUT 2007d. Idaho National Laboratory - Occupational Environmental Dose, ORAUTTKBS-0007-4, Rev. 1, Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 17, 

2007. 

ORAUT 2007e. Idaho National Laboratory - Occupational Internal Dose, ORAUT-TKBS0007-5, Rev. 2, Oak Ridge Associated Universities Team, Cincinnati, Ohio. July 30, 2007. 

ORAUT 2007f. Idaho National Laboratory - Occupational External Dosimetry, ORAUTTKBS-0007-6, Rev. 2, Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 18, 

2007. 

SC&A 2005. Review of the NIOSH Site Profile for the Idaho National Laboratory, Idaho, SCATR-TASK1-0005, Draft, Rev. 0, S. Cohen and Associates, McLean, Virginia, and Saliant, Inc., 

Jefferson, Maryland. September 25, 2005. 

SC&A 2006. Review of the NIOSH Site Profile for the Idaho National Laboratory, Idaho, SCATR-TASK1-0005, Draft, Rev. 1, S. Cohen and Associates, Vienna, Virginia, and Saliant, Inc., 

Jefferson, Maryland. January 25, 2006. 

SC&A 2007. Review of NIOSH/ORAUT Procedures and Methods Used for Dose Reconstruction 

(Supplement 1), SCA-TR-TASK3-0001, Rev. 1, S. Cohen and Associates, Vienna, Virginia, and 

Saliant, Inc., Jefferson, Maryland. August 3, 2007. 

Sommers, J.F., undated. Interoffice Correspondence to All Reactor HPs, Neutron Dosimetry, 

Headed: Som-30-69. (SRD ref. I.D. 8144) 
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ATTACHMENT 1: ISSUES RESOLUTION MATRIX FOR FINDINGS AND KEY OB

Issue Resolution Matrix for INL Findings and Key Observations (11/26/08) 

(Revised Attachment 5, Table A-5 of SC&A 2006) 

Added, Rem

Expanded, Re

Upgraded 

Unchanged

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No.1 

1 ORAUT- TKBS-0007-4 5 

Issue 1: (5.1.1.1) Routine Airborne Releases - Source terms provided 

require improvement for use in determining the worker intake from airborne releases at different INL facilities. The data NIOSH uses do not take into account the deficiencies in the environmental monitoring equipment and their locations, and, in addition, NIOSH does not assess the uncertainties associated with the meteorological dispersion model used for the INL site. Most importantly, the source terms do not account for worker inhalation of resuspended contaminated soils and materials around the INL facilities. 

45 Unchange

2 ORAUT- TKBS-0007-4 6 

Issue 2: (5.1.1.2) Episodic Airborne Release - The airborne releases 

associated with several of the Initial Engine Tests of the Aircraft Nuclear Propulsion (ANP) Program were likely to have been underestimated by factors ranging from 2 to 16. Also, NIOSH did not 

evaluate the uncertainties associated with the deficiencies in air monitoring equipment. 

55 Upgraded 

3 ORAUT- TKBS-0007-4 7 

Issue 3: (5.1.1.3) Direct Gamma Exposures – The fence-line TLD 

measurements are not adequate for reconstructing direct gamma doses to personnel working outdoors at and around a specific INL facility inside the fence-line boundary, because they do not take into account the most bounding scenarios. 

57 Unchange

1 Page numbers refer to SC&A 2006. 2 Compared to SC&A 2006, Attachment 5, Table A-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 Work

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

Number TBD Number Finding Number Issue Number and Description SC&A Page No.1 

4 ORAUT- TKBS-0007-5 8 

Issue 4: (5.1.2.1) Completeness and Quality of INL Internal 

Dosimetry Programs - The identification and determination of missed internal dose for workers are heavily influenced by the assumption of 

confidence, but SC&A found this premise to be unsupported after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, many site experts interviewed by SC&A indicated that there were significant deficiencies and inconsistencies in radiation work practices throughout the operating history of the INL facilities. These observations jeopardize the validity of the TBD approaches in reconstructing missed worker internal doses. 

73 Unchange

5 ORAUT- TKBS-0007-5 9 

Issue 5: (5.1.2.2) High-Risk Jobs (Internal Exposure) - NIOSH did 

not evaluate comprehensively the facility and field data to identify and separate out the high-risk or high-dose jobs for worker internal exposures. This information is essential for dose reconstructors to fill in the data gap when dose records in a claimant’s file are not complete. 

77 Unchange

6 ORAUT- TKBS-0007-5 O 3

Issue 6: (5.1.2.3) Calibration of Internal Dosimetry Analytical and 

Monitoring Equipment - The TBD does not provide any information on the calibration procedures, sensitivities, and standards of the internal dosimetry analytical equipment and monitoring instrumentation. The 1991 DOE Tiger Team findings show the deficiencies in these areas. NIOSH should evaluate the uncertainties and impacts on the internal dose assessment results associated with the deficient calibration programs at INL. 

78 Unchange

3 “O” denotes an observation (rather than a finding). 

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82.
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7 ORAUT- TKBS-0007-5 O 

Issue 7: (5.1.2.4) Changes of Internal Dose Limits - Inconsistent work 

practices were prevalent in the early years of the INL operation and may have led to significant missed dose to workers. NIOSH should evaluate the impacts of these dose limit changes over the operating history of INL to see whether there were missed doses in the early years when the radiation protection policy was less protective and inconsistently implemented. 

78 Unchange

8 ORAUT- TKBS-0007-5 10 

Issue 8: (5.1.2.5) High-Fired Plutonium and Uranium Intakes - The 

TBD did not evaluate the hazard associated with high-fired plutonium and uranium at the INTEC (ICPP) and RWMC facilities. High-fired Pu-238, Pu-239, and uranium are not easily dissolvable, nor do they readily break into very small particles. They also emit some gamma rays and neutrons. Similar to the treatment of recycled uranium, NIOSH should evaluate the lung dose for intake of high-fired uranium and plutonium oxide particulates (alveolar deposition). 

78 Unchange

9 ORAUT- TKBS-0007-5 O 

Issue 9: (5.1.2.6) Skin and Facial Contamination - This TBD does not 

consider incidents with workers having skin contamination, facial contamination, and positive nasal swipes in the INL facilities. These kinds of problems would be compounded by the deficiencies in air sampling systems and ineffective respiratory protection programs. Guidance should be provided to a dose reconstructor to account for the missed dose due to the unaccounted uptake. 

79 Unchange

10 ORAUT- TKBS-0007-5 O Issue 10: (5.1.2.7) Breathing Rates - The TBD assumption appears less claimant favorable than the ICRP or NCRP assumptions. 79 Unchange

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 Work

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

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11 ORAUT- TKBS-0007-5 11 

Issue 11: (5.1.2.8) Non-Occupational Worker Elimination of DU 

Background - The derivation of the background value of 0.16 μg/L used for subtraction from each urinalysis result of uranium prior to assessment of occupational internal dose for SMC radiation workers is not technically sound. The baseline background (population) intake value was determined by a study of urine samples submitted by nonradiation workers at the SMC facility. A better approach would be to use the urine excretion samples by non-INL people in the Idaho Falls area. NIOSH should consider this subtraction from urinalysis results as a missed internal dose. 

79 Unchange

12 ORAUT- TKBS-0007-5 O 

Issue 12: (5.1.2.9) Unmonitored Workers - The potential missed 

doses for unmonitored workers would be from inhaling resuspended contaminated soils and ingesting contaminated materials while eating in a contaminated, previously considered uncontaminated, area (such as office and cafeteria). NIOSH should evaluate these potential missed doses. 

80 Unchange

13 

ORAUTTKBS-0007-

4/5/6 

O 

Issue 13: (5.1.2.10) Naval Reactor Facility Workers - As the internal 

dose TBD indicates, “some workers’ internal dose could have resulted from their support work at the NRF.” NIOSH should evaluate the potential missed dose at the NRF for these workers. 

80 Unchange

14 ORAUT- TKBS-0007-5 O 

Issue 14: (5.1.2.11) Plutonium Monitoring - The TBD does not 

provide any historical information on the plutonium analysis methods used at INL. It is entirely possible that selective plutonium monitoring on workers was used at INL until 1980, but without this information, the dose reconstructors would not be able to assign missed internal dose due to plutonium intakes in the time period before 1980. NIOSH should provide information on plutonium monitoring. 

80 Unchange

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 Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82.
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15 

ORAUTTKBS-0007-

4/5/6 

1 

Issue 15: (5.1.3) SL-1 Accident Dose Reconstructions - The TBDs do 

not evaluate the potential missed internal and external doses or the associated uncertainties for the over 1,000 rescue and cleanup workers involved with the SL-1 accident that occurred in January 1961. There was a high potential for significant exposures, because the equipment used and the radiological control policies in place in that era were not as advanced and protective as those in current use. The TBDs should develop adjustment factors related to stay time, dose field estimates, internal dose results, external dose readings, and contamination level estimates. 

80 Unchange

16 ORAUT- TKBS-0007-6 8 

Issue 16: (5.1.4.1.1) Completeness and Quality of INL Beta/Gamma 

Dosimetry and Record Keeping Programs - The identification and determination of missed external dose for workers are heavily influenced by this assumption of confidence, but SC&A found this premise to be unsupported after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, many site experts interviewed by SC&A indicated that there were significant deficiencies and inconsistencies in radiation work practices throughout the operating history of the INL facilities. These observations jeopardize the validity of the TBD approaches in reconstructing missed worker external doses. 

96 Unchange

17 ORAUT- TKBS-0007-6 4 Issue 17: (5.1.4.1.2) Penetrating and Non-Penetrating Doses - NIOSH should re-evaluate the missed gamma dose, due to the deficiencies in the procedures and algorithms. 96 Unchange18 ORAUT- TKBS-0007-6 O 

Issue 18: (5.1.4.1.3) Correction For Beta Doses – NIOSH should 

develop a method to consistently account for uncertainties in dosimetry readings. Claimant-favorable correction factors should be developed for beta dose reconstruction. 

97 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82.
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19 ORAUT- TKBS-0007-6 O 

Issue 19: (5.1.4.1.4) Angular Dependence Correction Factor for 

Gamma Dose - NIOSH should provide angular dependence (anatomic geometry) correction factors for external gamma doses, particularly for low-photon energies, where the angular dependence of the sensitivity of the dosimeter is most pronounced. These correction factors are used to account for, for example, the bias introduced by a dosimeter worn at the neck level and the higher doses received by tissues/organs below the waist. 

99 Unchange

20 ORAUT- TKBS-0007-6 O Issue 20: (5.1.4.1.5) Restating Beta Dose As Gamma Dose - It is not claimant favorable to state that the entire dose measured in the open window is due to the beta dose. 99 Unchange21 ORAUT- TKBS-0007-6 O Issue 21: (5.1.4.1.6) Photon Spectrum Split – NIOSH should provide guidance assigning dose values for the 30 keV<E<250 keV and E>250 keV regions. 99 Unchange22 ORAUT- TKBS-0007-6 O 

Issue 22: (5.1.4.1.7) Immersion Dose - The dose recorded on a 

dosimeter due to a semi-infinite cloud irradiation would be approximately half of the actual dose received. NIOSH should, therefore, consider a weighting factor of 2 for immersion dose. 

100 Unchange

23 ORAUT- TKBS-0007-6 9 

Issue 23: (5.1.4.1.8) High-Risk Jobs (Beta/Gamma Exposure) - Site 

experts interviewed by SC&A classified INL as an “acute dose” site, with a significant number of facilities, operations, experiments, and occurrences providing the possibility of personnel receiving dangerous levels of radiation. NIOSH did not evaluate comprehensively the facility and field data to identify and separate out the high-risk or highdose jobs for worker external exposures. This information is essential for dose reconstructors to fill in the data gap when dose records in a claimant’s file are not complete. 

100 Unchange

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 Work

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

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24 ORAUT- TKBS-0007-6 O 

Issue 24: (5.1.4.1.9) Extremity Dose - NISOH should evaluate the 

potential for missed extremity dose for workers working in facilities where highly contaminated equipment, piping, instruments, valves, and systems resulted in exposures in confined spaces to hands. 

100 Unchange

25 ORAUT- TKBS-0007-6 O 

Issue 25: (5.1.4.1.10) Discrepancies between PIC and Film Reading – 

NIOSH should compare PIC versus film badge data (i.e., shallow and deep), and ensure that all the dose has been captured by the film badge. It is important to note that some PICs were worn for only the length of the job, so the discrepancy between readings of the twodosimeter systems cannot be explained by drifting. 

Expanded: Many difficulties in comparing PIC readings and film 

results make agreement within a factor of two the best that can be expected. 

100 Expande

26 ORAUT- TKBS-0007-6 12 

Issue 26: (5.1.4.1.11) Minimum Detection Limit – NIOSH should reevaluate the approach in determining the MDL of the dosimetry 

system by taking into account the system uncertainties. 

Expanded: The selection of 10 mrem as the MDL [minimum 

detection limit] for high energy gamma is questionable. Even for modern densitometers and film, it is a challenge to achieve this level, as a single density “click” can correspond to greater than 10 mrem for high-energy gamma radiation; this is not a problem, however, for intermediate and low-energy x-rays. Rather, one click of the densitometry system may correspond to 15 or 20 mrem for 660 keV or 1.2 MeV gammas, for example. If the claim is made that 10 mrem is a valid choice for the MDL, then supporting materials should be provided, such as film dose-to-density curves and densitometer calibration data. Other sites (e.g., Savannah River Site - SRS) have adopted 40 mrem as the high-energy gamma MDL for early film. 

101 Expanded/upg

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 Work

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

Number TBD Number Finding Number Issue Number and Description SC&A Page No.1 

27 ORAUT- TKBS-0007-6 3 

Issue 27: (5.1.4.1.12) Minimum Reporting Level (Beta/Gamma) - 

NIOSH does not provide adequate information supporting the use of chosen detection threshold levels to represent the MRL values for gamma film badges and TLDs. The use of MRL/2 as the missed external dose for dose reconstruction per OCAS-IG-001 is not claimant favorable for claims where the probability of causation value is close to 50%. In addition, NIOSH should re-evaluate the MRL values used and provide more supportable default values. 

103 Unchange

28 ORAUT- TKBS-0007-6 3 

Issue 28: (5.1.4.2.1) Minimum Reporting Level (Neutron) - NIOSH’s 

approach for determining the MRL values for NTA emulsion film is not thorough or supported. For example, NIOSH uses 10 neutron readings in one data sheet from March 1958 to determine the MRL values for the period between 1951 and 1957, and 6 neutron readings to represent all neutron measurements between 1959 and 1976. Furthermore, the use of MRL/2 as the missed external dose for dose reconstruction per OCAS-IG-001 is not claimant favorable for claims where the probability of causation value is close to 50%. In addition, NIOSH’s MRL values of 14 mrem and 20 mrem appear low and are inconsistent with generic values given for NTA dosimeters, as well as values cited by other DOE facilities with similar neutron source terms and detectors. NIOSH should re-evaluate the MRL values used and provide more supportable default values. 

108 Unchange

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 Work

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

 December 10, 2008 

Revision No.  0 – DRAFT 

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29 ORAUT- TKBS-0007-6 2 

Issue 29: (5.1.4.2.2) Failure to Properly Address Neutron Exposures - 

INL had a total of 52 reactors, most of which were experimental/ prototype in design, which typically operated with high-power densities and with minimum shielding and neutron moderation. It is unjustified to presume that there are no missed neutron doses. In addition, there are deficiencies associated with neutron calibrations. Due to the use of the PoBe source for neutron calibration, dosimeters would significantly under-measure neutron doses from sources with lower-energy spectra. NIOSH should re-evaluate the entire approach in the TBD to account for potential missed neutron doses. 

Expanded: The method presented in the TBD of determining who 

needs to be assigned a missed neutron dose is circular: Section 6.5.4 states: “If no neutron dose was assigned to the worker or coworkers for several months, the dose reconstructor should assume that the person was not exposed to neutrons.” Clearly this does not allow for individual workers having temporary or varying assignments. Also, if the program failed to correctly identify that they should have been monitored, the record will show no assigned neutron dose. In addition, the TBD makes the assumption that high Z materials, such as iron and lead, were never used (e.g., for shield penetrations) in place of hydrogenous materials, such as water and concrete. However, no attempt is made to validate or qualify this assumption. ORAUT-OTIB-0051, Effect of Threshold Energy and Angular Response of NTA Film on Missed Neutron Dose at the Oak Ridge Y-12 Facility, was issued after the 2004 Site Profile and has a bearing on neutron dosimetry issues; hence, it should be considered in this TBD. 

109 Expande

30 ORAUT- TKBS-0007-6 2 

Issue 30: (5.1.4.2.3) Neutron Calibration Deficiencies - Due to the 

use of the PoBe source for neutron calibration, dosimeters would significantly under-measure neutron doses from sources with lower energy spectra. NIOSH should re-evaluate the approach in the TBD to account for potential missed neutron doses. 

110 Unchange

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 Work

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

 December 10, 2008 

Revision No.  0 – DRAFT 

Document No. 

SCA-TR-TASK-0005-S1 

Page No. 

27 of 28 

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31 ORAUT- TKBS-0007-6 8 

Issue 31: (5.1.4.2.4) Completeness and Quality of INL Neutron 

Dosimetry and Record Keeping Programs - The identification and determination of missed neutron dose for workers are heavily influenced by this assumption of confidence, but SC&A found this premise to be unsupported after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, many site experts interviewed by SC&A indicated that there were significant deficiencies and inconsistencies in radiation work practices throughout the operating history of the INL facilities. These observations jeopardize the validity of the TBD approaches in reconstructing missed worker neutron doses. 

110 Unchange

32 ORAUT- TKBS-0007-6 O Issue 32: (5.1.4.2.5) Uncertainty Estimation for Neutron Doses – NIOSH should explain how the FNCFs were obtained and provide instruction to dose reconstructors on how to apply them. 110 Unchange33 ORAUT- TKBS-0007-6 O Issue 33: (5.1.4.2.6) Neutron Organ Dose – NIOSH should provide neutron spectrum information and guidance for organ dose reconstruction for workers at ZPPR and TREAT. 110 Unchange34 ORAUT- TKBS-0007-6 9 

Issue 34: (5.1.4.2.7) High-Risk Jobs (Neutron Exposure) - NIOSH 

did not evaluate comprehensively the facility and field data to identify and separate out the high-risk or high-dose jobs for worker neutron exposures. This information is essential for dose reconstructors to fill in the data gap when dose records in a claimant’s file are not complete. 

111 Unchange

35 ORAUT- TKBS-0007-6 O 

Issue 35: (5.1.4.2.8) Multiplying Factors for Missed Neutron Dose – 

NIOSH should provide data to support the two multiplying factors (1.25 and 2) and the fixed missed neutron dose default value of 50 mrem. Expanded: See ORAUT-OTIB-0051 and Issue No. 29. 

111 Expande

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 Work

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

 December 10, 2008 

Revision No.  0 – DRAFT 

Document No. 

SCA-TR-TASK-0005-S1 

Page No. 

28 of 28 

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Upgraded 

Unchanged

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No.1 

36 ORAUT- TKBS-0007-6 13 

Issue 36: (6.3.2.2) Missed Low Energy Beta Dose - Section 6.3.2.2 of 

the TBD discusses the 100mg/cm2 plastic dosimeter holder and the 

fact that betas of less than 360 keV will not penetrate the holder. (It is unclear if this density includes the film wrapper.) However, the TBD does not discuss allowance for or consideration of the possibility of the complete failure to detect these betas. 

The general, averaging approach to missed beta is questionable. The concern is that beta exposure is always assumed to be due to a mix of 

energies and thus the dose component from low energies is known and can be corrected. Clearly this is not the case, as is stated in the attribution. A specific concern is the Rare Gas Processing Facility (CPP-604), which harvested Kr-85. This nuclide is a pure beta emitter, with an endpoint energy of 670 keV. The film badges in use at the time were far from ideal for betas and failed to see any below 360 keV. NIOSH should determine if the maximum modifier recommended for betas of 2.8 is sufficient for this environment. 

NA Added 

37 ORAUT- TKBS-0007-6 O Issue 37: (6.5.4) Error in Reference - The second paragraph of page 41 of the External Dose TBD (ORAUT 2007f) references Table 6-16 for IREP groups; it should refer to Table 6-14 instead. NA Added 38 ORAUT- TKBS-0007-6 O 

Issue 38: Shallow Dose - NIOSH should consider making use of 

ORAUT-OTIB-0017, Technical Information Bulletin: Interpretation of Dosimetry Data for Assignment of Shallow Dose, where 

appropriate. Additionally, contrary to the OTIB’s claim (p. 15) that the assumption of undergarment and pants thicknesses of 2 mm each is claimant favorable, SC&A believes that measured thicknesses are about half that and, hence, the OTIB assumptions are not claimant favorable. 

NA Added 

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 Work

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