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MEMO

TO: LBNL Work Group

FROM: Joe Fitzgerald and Ron Buchanan, SC&A

DATE: February 4, 2014

SUBJ: NIOSH December 4, 2013, Response to SC&A Comments

After reviewing NIOSH’s December 4, 2013, response in its two white papers, NIOSH 

Evaluation of the Internal and External Monitoring Programs at the Lawrence Berkeley 

National Laboratory and NIOSH Response to SC&A Comments Concerning Part of Issue 2 

Regarding the Internal Monitoring Program at the Lawrence Berkeley National Laboratory, we 

believed it useful to pose some clarifying questions and issues for the Work Group and NIOSH 

consideration prior to a formal Work Group meeting.

In general, our concern at this still early phase of review is over-reliance on contemporary 

technical studies and programmatic documents (e.g., policies and procedures) at the expense of a 

comprehensive assessment of actual routine and event-driven in-vivo and in-vitro bioassay 

records. As experience at other DOE sites (LANL, in particular) has illustrated, what bioassay 

data are actually recorded for exposure source terms often do not necessarily match the available 

monitoring technology or conform with existing policies or procedures governing routine 

bioassay program implementation. 

With respect to LBNL, it appears that in the 1960s, there was an initiative to begin identifying 

some of the specific radionuclides in bioassay samples (e.g., SRDB Ref IDs #117632, 117754, 

118311). However, when SC&A sampled LBNL claimants with job titles that would indicate 

potential exposures (i.e., Accelerator Operator, Chemist, Nuclear Physicists, HP, Technicians, 

Maintenance, etc.) who worked during the 1960s, 1970s, and 1980s, there appear to be few 

bioassays recorded (i.e., gross alpha, beta, gamma), and still fewer yet with any analyses for 

specific radionuclides.

The ability to identify, and the need to analyze, specific radionuclide intakes at the national labs 

(e.g., LANL, BNL, and LLNL) was still in its infancy in the 1960s; and, generally, these 

methods were not yet applied to bioassays on a routine basis (and the results recorded and 

rendered useful for dose reconstruction) until much later because they required considerable 

development time. An obvious question would be whether LBNL was much more advanced and 

ahead of its time than these other laboratories in this respect.

While LBNL was a forerunner in accelerator health physics, it appears from an SC&A 

preliminary evaluation of NIOSH claimant files for LBNL that the capability to analyze specific 

radionuclides may have remained in a laboratory development stage, as opposed to being applied 

to routine bioassays, especially for WBCs. LBNL claim files were searched for POCs <50% (to 

ensure a complete DR) and if there was a DR report on file (to see how the internal doses were 

determined). This resulted in 195 claims. Claims with job titles that indicated potential 

exposure were selected for investigation. This included Physicist, Nuclear Physicist, Chemist, 

Lab Tech, Technician, Researcher, Accelerator Operator, Maintenance, HP, Machinist, and 
To the LBNL WG – Response to Comments 2 SC&A – February 4, 2014

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.

Magnet Tester. A total of 25 claimants that worked some time during the period 1960s–1980s 

were analyzed by reviewing their DOE Response files and DR reports to determine if bioassays 

were recorded, and if so, what bioassay information is available; i.e., frequency, urinalyses, 

WBCs, and radionuclide identification. From this review, there did not appear to be many 

bioassay results recorded, and very few routine bioassays; only 4 claimants had any bioassay 

records out of the 25 reviewed. What bioassays were recorded generally did not contain nuclidespecific information (mainly gross gamma, beta, and alpha counts) and did not appear to be used 

in the DR process, except for a 1971 P-32 measurement for a potential acute intake. It would 

seem reasonable to expect that some of the personnel that worked at the facilities on a routine 

basis, such as operators and technicians, would have some records of routine, or at least periodic, 

bioassays in their records if the HP program was firmly in place and operational by 1962.

For comparison sake, the same review process was also conducted for five claimants that had 

worked during the 1990s and 2000s. From this limited review, there were likewise very little 

bioassay data or radionuclide-specific information recorded.

SC&A has the following comments and proposes that the following clarifying questions be 

addressed by NIOSH to help resolve the aforementioned issues:

1. Recorded Bioassays – In response to SC&A’s e-mail request of January 17, 2014,

concerning the lack of claimant bioassay records, NIOSH provided a list of SRDB 

references in an e-mail response on January 23, 2014. SC&A reviewed some of the 

pages of all of these references (which consisted of thousands of pages) and found:

a. Ref ID #21985 contained handwritten bioassay cards for workers with the last 

names beginning with A for the period 1965–1990, with some radionuclides 

recorded, but generally the results were gross beta dpm, alpha dpm, and gamma

dpm or “negative.” Results of WBCs were generally listed as “Normal” without 

providing any radionuclides, their quantities, or MDA values. Ref ID #21986 

generally contained the same information for persons terminated during 1961–

1983 with last names beginning with A.

b. Ref IDs #32378–#32379 contained handwritten bioassay cards that listed the 

bioassays to be performed during the period 1960 through approximately 1967 for 

persons with last names starting from A–Z, with some bioassay results in the form 

of gross alpha, gross beta, and sometimes “no gamma peaks” noted; however, 

generally there were no specific radionuclides recorded. 

 

c. Ref IDs #32380–32392 generally contained computer-generated bioassay punch

cards that listed the bioassays to be performed during the period 1960 through 

approximately 2002 for persons with last names starting from A–Z; however,

generally there did not appear to be any results recorded in these files. 

d. Ref IDs #32393–32294 provide some examples of bioassay lab procedures for 

specific radionuclides during the period 1980–2002.
To the LBNL WG – Response to Comments 3 SC&A – February 4, 2014

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.

These documents indicate that bioassays were conducted at LBNL beginning by at least 

the 1960s; however, it is still not obvious that the persons that needed to be monitored 

were bioassayed on a routine basis, and sufficient radionuclide information recorded for 

DR purposes. This is especially true considering the results of SC&A’s preliminary 

investigation of claimant files for bioassay records. How does NIOSH reconcile the 

differences between what is indicated in these documents with what appears to be lacking 

in the claimant files? How does NIOSH propose to use gross alpha, beta, and gamma 

results (without specific radionuclide recorded) for DR purposes?

2. WBCs – Are there recorded bioassays during the period 1960s–1990s where the WBCs 

provided analyses of specific radionuclides on a routine basis? If so, please identify 

some of the bioassays and radionuclides involved. 

3. Location-Specific Radionuclides – Are there examples of the recorded bioassay data 

providing results for specific radionuclides that match those that the worker was 

potentially exposed to for the given work location and time period? Considering the 

number of accelerators and their long periods of use at LBNL, the use of WBCs to 

identify individual radionuclides (and recording the results) for mixed activation products 

(MAP) are of special concern since alpha urinalyses would not detect them. Were 

workers around the accelerators monitored for MAP? From some of the references (e.g., 

SRDB Ref IDs #117632, #117754, #118311), it appears that LBNL was developing the 

capability to analyze for specific radionuclides (these may have been for radionuclides 

brought into the labs in relatively large quantities). However, SC&A has not located any

comprehensive characterization of some of the other potential exposure intakes, such as 

from accelerator activation of beamlines, shielding, targets, target enclosures, and 

radioisotope production, with their corresponding bioassay methodology for radionuclide 

identification, quantification, and recording. The TBDs for other national labs with 

accelerators, such as BNL, ANL, LANL, as well as LBNL, indicate a number of 

radionuclides generated from accelerator operations. What results indicate that the LBNL 

workers were appropriately bioassayed and the results recorded for the radionuclides 

they were potentially exposed to?

A bridge between LBNL written procedures, monitoring requirements, and capabilities for 

radionuclide identification, compared to the recorded bioassay data available for dose 

reconstruction, is not clear at this time. As we have found in the past, program directives and 

instrument capabilities do not necessarily equate to what was actually put into practice and is 

available for dose reconstruction.