Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Preliminary Issues from SC&A’s Review of NIOSH’s Evaluation Report 

for Brookhaven National Laboratory 

Special Exposure Cohort Petition SEC-00113 

 

Availability of Bioassay Records and Adequacy of Neutron Dosimetry 

Contract No. 200-2009-28555 

SCA-SEC-2010-0011, Revision 0

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2010 

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 pre-decisional 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.
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Document No. 

SCA-SEC-2010-0011 

Effective Date: 

Draft – February 23, 2010 

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 

Preliminary Issues from SC&A’s Review of NIOSH’s 

Evaluation Report for Brookhaven National 

Laboratory Special Exposure Cohort Petition SEC00113: Availability of Bioassay Records and Adequacy 

of Neutron Dosimetry

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Task Manager: 

________________________ Date: ___________ 

Ron Buchanan, PhD, CHP 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

Supersedes: 

0 
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TABLE OF CONTENTS 

1.0 Introduction and Summary ..................................................................................................4 

2.0 Availability of Bioassay Records.........................................................................................5 

2.1 1980 as a Turning Point ...........................................................................................5 

2.2 Bioassay Data...........................................................................................................6 

2.3 Bioassay Record Storage Systems.........................................................................10 

2.4 Summary of Availability of Bioassay Records......................................................11 

3.0 Adequacy of Neutron Dosimetry.......................................................................................12 

3.1 NIOSH Evaluation Report Analysis of Neutron Dosimetry..................................12 

3.2 Neutron Dosimetry Response Functions as Addressed in NIOSH’s 

Evaluation Report and Brookhaven National Laboratory Technical Basis 

Document...............................................................................................................13 

3.3 NTA Film Under-response to Low-Energy Neutrons ...........................................14 

3.4 High-Energy Neutron Detector (NTA/TLD/Lexan/CR-39) Problems..................15 

3.5 Summary of Adequacy of Neutron Dosimetry ......................................................16 

4.0 References..........................................................................................................................17 

Attachment A: Preliminary Matrix Issues for the Brookhaven National Laboratory SEC 

Petition and NIOSH Evaluation Report Review................................................................19 

Attachment B: Bioassay Data Issues for BNL-SEC Matrix .........................................................22 

Attachment C: Neutron Dosimetry Issues for BNL-SEC Matrix .................................................23 
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1.0 INTRODUCTION AND SUMMARY 

At the Advisory Board on Radiation and Worker Health (Advisory Board) meeting held in Port 

Jefferson, New York, on October 20–22, 2009, the Advisory Board authorized SC&A to perform 

a focused review of the Brookhaven National Laboratory (BNL) Special Exposure Cohort (SEC) 

Petition and National Institute for Occupational Safety and Health (NIOSH) Evaluation Report 

(ER). The SEC petition (BNL SEC-00113) requested that the time period covered include 1947 

through 2007. NIOSH’s ER of September 29, 2009, recommends that a time period of 1947–

1979 be granted SEC status, based on the lack of internal dose records. This leaves the period 

1980 through 2007 in question—a time period of particular interest to the Advisory Board. This 

report presents SC&A’s preliminary identification of potential BNL SEC issues with regard to 

this matter, based on a review of NIOSH’s SEC-00113 ER and the BNL Site Profile. SC&A’s 

focused investigations related to the BNL SEC petition and ER are continuing, as described in 

this, the first in a series of reports on this matter. SC&A has constructed a preliminary matrix 

that summarizes the two major SEC issues, bioassay records and neutron dosimetry, and 

included it in this report as Appendix A.

BNL bioassay records have been stored in hardcopy form in various departments at the 

laboratory until relatively recently (2002), when the Health Physics Record Storage (HPRS) 

system was used for storage of the bioassay records. Some electronic database systems were 

used to store bioassay records during the 1990s, but these were not centralized. Based on our 

review, it is not apparent that the electronic records are complete, nor do they appear to be 

readily accessible for dose reconstruction purposes. Some effort is currently ongoing to transfer 

the data from the older electronic databases to the HPRS system, but this has not been completed 

and may not be accomplished in the time frame necessary to process BNL claims. Therefore, 

dose reconstructors may need to rely on hardcopy bioassay records that are limited to those that 

are retrievable at BNL prior to 2002. There is no assurance that all the bioassay records are 

complete and retrievable for dose reconstruction purposes during either the earlier period (1947–

1979) or for 1980 forward; this could present a potential Special Exposure Cohort (SEC) issue 

for 1980–2007. 

In contrast to bioassay records, recordkeeping for external dose records at BNL appears to have 

been centralized, with hardcopies placed in the employee’s file and on microfiche as the main 

form of record retention through 1995, and then the use of the HPRS system beginning in 1996 

to store external dose records. Although dosimetry was prevalent and record keeping was more 

centralized for external exposures at BNL, neutron dosimetry is still a potential SEC issue. 
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2.0 AVAILABILITY OF BIOASSAY RECORDS 

In NIOSH’s September 29, 2009, ER of BNL SEC-00113, it is stated that there are sufficient 

bioassay records available after 1979 to perform dose reconstruction; therefore, the SEC is 

limited to 1947–1979. SC&A studied the ER and performed a preliminary review of the data 

used to support NIOSH’s assumption that 1980 was a turning point in bioassay record retention 

at BNL. The following is a summary of SC&A’s primary concerns. 

2.1 1980 AS A TURNING POINT 

NIOSH states the following on page 33 of the ER: 

However, personnel monitoring data retrievability issues, which are compounded 

by the site’s record-keeping practices over the years, present the most significant 

issues affecting this report’s evaluation. It is apparent that there was a turning 

point in the BNL radiological program and record-keeping requirements at the 

beginning of 1980 (following a 1979 site assessment). [Emphasis added.] 

NIOSH further states the following on page 51 of the ER: 

As discussed in this report, 1980 corresponds with a period when monitoring 

program records-management changes were implemented at the site. 

However, there are no references to support the statement that there was a turning point in 1980, 

or any information concerning the 1979 site assessment. These statements may have been based 

on the references provided on page 54; however, those documents do not confirm that a bioassay 

records storage system was successfully implemented. This is further examined in the following 

discussion. 

The following is stated on page 54 of the ER: 

It is also likely evidence that shifting the whole-body counting responsibilities 

from the Medical Division to the S&EP [Safety and Environmental Protection] 

division contributed to the improved record maintenance practices sought by BNL 

at that time. Centralization and improved control over personnel monitoring 

sample collection, analyses, follow-up work, and records maintenance were all 

goals of this reorganization (Hull, 1979; Cohn, 1980). 

The main concerns of the first reference (Hull 1979) were as follows: 

The principal weaknesses of our program that are suggested by this canvass of 

general practices are the lack of a required initial count for persons newly 

nominated to the list and/or of a final count for terminations from it. While it is 

not as apparent, I am also aware that our current program does not specifically 

provide for diagnostics or the followup of "positives," as disclosed either by 

routine or "special" whole body counts. [Emphasis added.] 
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Although the above could probably be accomplished within our current 

arrangement with the Medical Department, I feel that there are strong reasons 

why we should assume the program as a 100% S&EP operation now that we have 

the capability to do so. 

There was little emphasis on centralization and better bioassay record storage in this 

memorandum. 

The complete content of the second reference (Cohn 1980) is very short and is as follows: 

The medical whole body counter is always available for monitoring of BNL 

personnel in emergency situations, as you are aware. 

In response to your programatic needs in relation to the MIRSP [Medical Isotope 

Research and Production], we will make every effort to accommodate you for 

"interim service." Availability of the counter for routine monitoring of personnel 

is, of course, subject to the clinical research demands made on the counter. I 

assume that you will continue to be responsible for the analysis and interpretation 

of the whole body counting data obtained during this interim service period. 

It appears that this was a statement from the medical group [that at the time had whole-body 

counting (WBC) capabilities] to the monitoring group (that apparently was in the process of 

acquiring WBC capabilities, referred to as the interim period), indicating that the medical 

group’s WBC facility could be used, if available, for routine bioassays if necessary. It does not 

support the assumption that bioassay records were centralized and that there were improved 

controls over personnel monitoring, sample collection, analyses, follow-up work, and record 

maintenance as a result of a reorganization, as was indicated on page 54 of the ER report. 

Additionally, a related reference (Hull 1978) does not emphasize the need for improved record 

keeping; instead, the article is mainly concerned with the technical, personnel, and budget issues 

associated with S&EP obtaining a WBC facility. It is not apparent from these references that a 

definite plan was put into place and successfully carried out to centralize and improve 

storage/retrievability of bioassay data beginning in 1980. 

In general, SC&A did not find that the documentation provided in the ER supports the 

assumption that a plan to centralize and store bioassay records (urinalysis and others, as well as 

WBCs) was successfully initiated in 1980, carried through to completion, and maintained. 

2.2 BIOASSAY DATA 

NIOSH performed substantial BNL data capture for use in evaluating the BNL SEC. Much of 

the bioassay data capture is presented in the ER in the form of tables and attachments. SC&A 

performed a preliminary review of this data, looking at the number of bioassays as function of 

the year the bioassay was taken. If there is a pivot point (such as in 1980, as suggested by 

NIOSH) at which BNL instituted a program to centralize and store the bioassay records, then 

there should be trends in the data that indicates a change in: 
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• The number of bioassay records retrievable (generally, an increase would be expected). 

• The consistency of the number of bioassay records (less fluctuation would be expected). 

• Both the number and consistency of the bioassay records. 

Changes in facility operations and regulatory monitoring requirements could add perturbations to 

these trends that could complicate the analysis; however, some useful information should be able 

to be gathered from this data to verify NIOSH’s assumptions, if they are correct. SC&A plans to 

perform further analyses and create plots of this data to detect if there was any turning point at 

which bioassay records were more consistent and retrievable. The following is SC&A’s 

preliminary analysis of the bioassay data captured by NIOSH and presented in the ER. 

NIOSH’s ER Table 6-3 

NIOSH describes the data used in Table 6-3 (pages 36–38) of the ER on page 34, Section 6.1.1. 

Table 6-3 summarizes the data captured by NIOSH concerning the total number of in-vitro 

results by year (1949–1989) and by individual radionuclide and/or analytical procedure. 

From SC&A’s initial review of this data, it is not obvious that there is a change in the number of 

in-vitro results around 1980. SC&A plans to further analyze and plot the data to obtain more 

detailed information from it. 

NIOSH’s ER Table 6-4 

NIOSH describes the data used in Table 6-4 (pages 40–41) of the ER on page 39, Section 6.1.2. 

Table 6-4 summarizes the data captured by NIOSH concerning the total number of in-vivo 

WBCs results by year (1960–2000) and by individual radionuclide. According to the ER, 

page 39: 

Typical radionuclides measured included: Cs-137, Co-58/60, Zn-65, Fe-59, 

Mn-54, and Be-7. There are also results for Cs-134, Ce-141/144, Ba/La-140, and 

the radioiodines. Results for lung and thyroid dose were also captured. 

From SC&A’s preliminary review of this data, it appears that the number of WBCs increased 

substantially around 1973, and continued to increase until 1990. However, such a trend would 

be expected of a new technology that could replace numerous, more time-consuming, analytical 

procedures. There was considerable fluctuation in the number of WBCs from the early 1970s to 

the late 1990s; therefore, it is not obvious that a more precise method to store and retrieve 

bioassay records was instituted and maintained at any point during this 30-year period. SC&A 

plans to further analyze and plot the data to obtain more information. 
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NIOSH’s ER Table 7-2 

NIOSH describes the data used in Table 7-2 (page 54) of the ER on page 54, Section 7.1.1. 

Table 7-2 summarizes the results of using the data captured by NIOSH to compare the number of 

bioassays requested to the number actually performed and recorded for 69 persons between 1948 

and 1992 for certain time intervals. 

SC&A finds that the data in Table 7-2 indicate that there was an increase in the consistency of 

performing and recording requested bioassays as time progressed. These appear to be 

specifically requested bioassays; therefore, this trend may or may not apply to routine

bioassays. 

NIOSH’s ER Attachment 1 

NIOSH describes the data used in Attachment 1 (pages 102–105) of the ER on page 34, 

Section 6.1. Attachment 1 summarizes the results of NIOSH’s data capture concerning the 

number of employees, in eight different work groups, monitored per year (1949–2000) by WBC 

and urinalysis (with the urinalyses broken down into different radionuclides and/or methods of 

analysis). 

SC&A found that Attachment 1 contains a large amount of data that needs to be further analyzed 

and plotted. A preliminary review of the data indicates that there were considerably more, and 

varied, analytical procedures performed before 1980, as compared to 1980 and afterwards; 

however, a number of these analyses may have been replaced by the advent of WBC, which 

showed a substantial increase in the 1970s for most of the work groups. A preliminary review of 

this data does not indicate a pivot point around 1980; further analysis of this data may confirm, 

or change, this initial indication.

NIOSH’s ER Attachment 3 

NIOSH describes the data used in Attachment 3 (pages 112–113) of the ER on page 53, 

Section 7.1.1. Attachment 3 contains the results of NIOSH’s data capture for 200 BNL workers 

and summarizes the number of persons, in eight different work groups, monitored per year 

(1949–2008) by tritium urinalysis, WBC, and miscellaneous bioassays (urinalysis).

Similar to Attachment 1, SC&A found that Attachment 2 contains a large amount of data that 

needs to be further analyzed and plotted. A preliminary review of the data on both sides of 1980 

indicates that there is a considerable amount of data during each time period, but with numerous 

fluctuations. A preliminary review of this data does not indicate a pivot point around 1980; 

further analysis of this data may confirm, or change, this initial indication.

NIOSH’s ER Attachments 4, 5, and 6 

NIOSH describes the data used in Attachments 4, 5, and 6 (pages 114–116) of the ER on 

page 53, Section 7.1.1. 
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NIOSH’s ER Attachment 4

Attachment 4, page 114, summarizes the results of NIOSH’s data capture concerning the number 

of persons with H-3 bioassays results in the Index files and the Medical files, plus the Personnel 

Monitoring (PM) files by year (1949–2008). It also provides the number of tritium bioassays 

found in NIOSH’s data capture not found in any of these three sets of files (Index files, Medical, 

and PM files) by vertical red bars. NIOSH describes the term “Index” file on page 53 of the ER 

as follows: 

All data available for the selected employees were captured from BNL’s two 

primary hard copy data repositories: (1) employees’ personal monitoring (PM) 

files; and (2) employees’ medical files. Comparisons were made to data that 

already existed for some of the selected 200 workers in NIOSH’s existing Excel 

spreadsheet. Comparisons were also made to BNL’s “Historical Bioassay 

Index.” This index is used to link a growing collection of miscellaneous hard 

copy data being recovered from various on-site locations (i.e., other than 

employees’ PM and medical files). The captured monitoring data were assessed 

and reviewed to compile data availability summaries for the 200-person sample 

group. [Emphasis added.] 

For these 200 BNL workers, this information indicates that most of the bioassay data for tritium 

is contained in the Medical and PM files after 1976, and that there was none in the NIOSH data 

capture that was not also found in the Medical, PM, and/or Index files after 1973. Therefore, 

starting in the mid-1970s, the tritium bioassay data for these 200 workers appear to be consistent 

in the major databases, which are discussed further in Section 2.3. 

NIOSH’s ER Attachment 5

Attachment 5, page 115, shows the same type of information for Misc. bioassay data. 

For these 200 BNL workers, this information indicates that most of the data for miscellaneous 

(urinalysis) bioassays is contained in the Index files before 1974 and in the Medical and PM files 

after 1974. The number of bioassays began to decrease noticeably in the 1970s, most likely 

because of the introduction of WBC technology. The red bars indicate that there were several 

instances where the contents of the data capture by NIOSH do not match that found in the three 

major databases prior to 1985. 

NIOSH’s ER Attachment 6 

Attachment 6, page 116, shows the same type of information for WBC bioassay data. 

For these 200 BNL workers, this information indicates that the bioassay data for WBC increased 

rapidly in the 1970, as expected, and continued to the early 1990s. The WBC data in the PM and 

Medical files encompass that contained in the Index files. The red bars indicate that there were 

several instances where the contents of the data capture by NIOSH do not match that found in 

the three major databases during the 1980–1994 timeframe. 

 
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SC&A’s preliminary analyses of the number and consistency of the bioassay data in the ER does 

not indicate that there was an effective change in the bioassay recording and retention system 

beginning in 1980 and continuing through 2007 at BNL. 

2.3 BIOASSAY RECORD STORAGE SYSTEMS 

The above analyses were mainly concerned with the details of the number of bioassay records as 

a function of time; however, it is also necessary to consider how/where these bioassay records 

are presently stored and if they can be sufficiently coordinated, so that they can be made 

available for use by the dose reconstructor in a reasonable amount of time. NIOSH provides a 

description of the bioassay record storage systems in Table 6-1 (page 32) and Table 6-2 (page 

33) of the ER, which helps to summarize the location of bioassay (urinalysis, WBC, and others) 

records at BNL. SC&A used the information in Tables 6-1 and 6-2 to create a spreadsheet that 

illustrates where the bioassay data that were recorded were/are stored as a function of time. This 

spreadsheet helps to illustrate the progression of the recordkeeping process up to and beyond 

NIOSH’s recommended pivot year of 1980, and is included in this report as Attachment B. This 

information indicates that the bioassay records were not consolidated into one electronic 

database (HPRS) until 2002. Before 2002, the majority of the bioassay records that are available 

are stored in the PM, Medical, and Index files, with some files in stand-alone electronic 

databases beginning in the 1990s. Additionally, NIOSH has recently captured and retained some 

of this bioassay data that could be used for dose reconstruction purposes. Unfortunately, as 

Attachment B indicates, the bioassay data at BNL are not conveniently located in any one 

database system, nor is it known if all of the bioassay records are contained in the presently 

available databases. On page 58 of the ER, third paragraph, it is indicated that all three sources 

(PM, Medical, and Index files) are checked by BNL for information when an EEOICPA request 

is received; however, this brings up several questions: 

• Are all the other various data sources [microfiche, WBC office, hard copies, electronic 

databases (i.e., NIOSH ER, page 32, Table 6-1, Column 3, Row 1), ASL, etc.] complete 

and are they also queried during each response? 

• What time periods are currently addressed in the HPRS with respect to bioassays records 

that are available for dose reconstruction purposes? Does it indeed contain all bioassay 

records during this time period? 

• Is all relevant data contained in the HPRS also supplied to the dose reconstructor? 

• Does NIOSH have a procedure that automatically retrieves any relevant data from their 

data-captured spreadsheets and then provides it to the dose reconstructor? 

It is unclear at this point if all the BNL bioassay records still exist, and for the ones that do exist, 

if they are retrievable (from old electronic databases, etc.), and if there is a protocol in place at 

BNL/NIOSH that ensures all this bioassay data is gathered and supplied to the dose reconstructor 

for each case. Even if bioassay data do exist in some form (old electronic databases, etc.), if it 

cannot be extracted because it is no longer supported, then it is potentially an SEC issue. 
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Bioassay records were not routinely entered in the HPRS until after 2001 (NIOSH ER, page 32, 

Table 6-1), with some earlier bioassay data currently being added. This brings up several areas 

of concern that could be potential SEC issues: 

• Why does the number of bioassay records decline and become erratic in the 1990s? 

• Were there procedural and/or operational changes instituted in the early 1990s that 

caused this decrease in bioassays? According to Table 2-2 and Table 2-3 in ORAUTTKBS-0048, many of the facilities continued to operate to the present, or at least to 1999. 

One of the main facilities that necessitated bioassays was the HFBR, which operated 

from 1965–1989 and 1991–1996. Therefore, it is not obvious why the number of 

bioassays changed noticeably in the 1990s. 

NIOSH’s ER concentrated on addressing the availability of bioassay data in the 1980–1990 era; 

however, the retrievability and completeness of bioassay records during the period of 1990–2007 

is unclear at this point. 

2.4 SUMMARY OF AVAILABILITY OF BIOASSAY RECORDS 

There does not appear to be a clear indication of any certain time period when a methodology 

was implemented to improve the recording and retention/retrievability of bioassay results at BNL 

until perhaps 2002, when bioassay records were added to the HPRS. The documents reviewed 

to date do not reveal that a definite plan was implemented during a certain period (such as in 

1980) and maintained to improve the recording and retrieval of bioassay records, which would 

ensure that all bioassay results are available for dose reconstruction purposes. Neither does a 

preliminary analysis of the currently available data, as described above, produce reasonably 

conclusive results that would indicate that the number and/or consistency of the bioassay data 

improved during the period 1980–2007, as suggested in NIOSH’s ER. Additionally, this review 

brings up questions concerning the completeness and location of bioassay records for 1990s–

2007, as well as for the 1980–1990 time period. 
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3.0 ADEQUACY OF NEUTRON DOSIMETRY 

In contrast to bioassay records, the records for external exposures at BNL appear to be more 

centralized, complete, and retrievable. External monitoring was instituted when operations 

began at BNL, and the records were kept on hard copies in the Personnel Monitoring (PM) 

organization files through 1985, then on microfiche for the period 1986–1995, and then on the 

BNL HPRS database starting in 1996 and continuing to the present. NIOSH’s ER summarizes 

the external monitoring records in Attachment 2, pages 106–111. The information in 

Attachment 2 covers the period 1958–2007 (except for 1971) and provides a list of the total 

number of persons monitored, number with measureable dose, average measured dose, number 

of persons with no measurable dose, and a breakdown of the number of recorded doses in nine 

dose intervals ranging from <1,000 mrem to 8,999 mrem. Additionally, there is some 

breakdown into general categories of the persons’ affiliation (i.e., BNL employee, visitor, etc.). 

The external monitoring data appear to be reasonably adequate (concerning the amount 

available) and accurate (concerning the dependability of the records). 

However, the neutron dosimetry/processing/recording methodologies used to generate the dose 

of record could create potential SEC issues. The period in question could extend from 1980–

2007. SC&A reviewed a number of documents (mainly BNL memorandums) that indicate that 

there were significant neutron dosimetry problems in the 1985–1995 timeframe; no 

documentation of the resolutions to these problems has been located to date. SC&A has not 

located documented evidence of neutron dosimetry problems in adjacent time periods (i.e., 

1980–1984 and 1996–2007); but, barring any new developments, it would have to be assumed 

that these problems were not isolated to only the 1985–1995 time period and could have existed 

prior to, and sometime after, this time period, considering that high-energy accelerators were 

operational at BNL during most of its recent history. 

3.1 NIOSH EVALUATION REPORT ANALYSIS OF NEUTRON DOSIMETRY 

NIOSH’s ER addresses neutron dosimetry briefly on pages 71–72. NTA film was used from the 

start-up of BNL through 1995, when it was replaced by TLDs. Additionally, in locations where 

there was a potential for exposure from high-energy neutrons, such as around some accelerators, 

CR-39 was used during the period 1985 through the present, and Lexan was used during the 

period 1985 through June 1997. The use of neutron dosimetry is summarized in the following 

table: 

Table 1. Neutron Dosimeters at BNL 

Dosimeter Period of use 

NTA 1950s–1995 

TLD 1996–Present 

CR-29 1985–Present 

Lexan 1985–June 1997 

From the beginning, BNL used a relative biological effectiveness (RBE) or quality factor (QF) of 

10 to encompass the possible range of potential, but not fully known, QFs. An RBE or QF is a 

numerical value by which the absorbed dose (rads) is multiplied to derive the dose equivalent 
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(rem). In NIOSH’s ER and the BNL Site Profile document (ORAUT 2006a), it is assumed that 

the dosimetry at BNL was appropriate, because of the use of RBE or QF = 10; and hence, this 

created a built-in safety factor. This is stated on page 71 of the ER: 

Numerous references attest to the appropriateness of the personnel neutron 

dosimetry used at BNL. Cowan discussed the adequacy of the dosimeter to 

radiation fields encountered at the AGS and concluded it was “fail safe” for the 

radiations typically found at the accelerators (Cowan et al. 1964). Throughout 

BNL history, the evaluation of the film always assumed a QF or RBE of 10. 

A review of the reference Cowan et al. (1964) shows that the main items of concern in that 

article were as follows: 

After a discussion of methods of high energy dosimetry, data on linear energy 

transfer and quality factors of pions, protons, deuterons, and alpha particles in 

water are summarized. [Emphasis added.] 

Neutrons were only briefly mentioned in this article, and no QF analysis was performed for 

them. Regardless of the conservatism of the QF used, the recorded dose will not be 

representative of the dose received if there are portions of the neutron energy spectra that the 

neutron dosimeter is not responsive to, or under-responds in a manner that substantially 

diminishes the usefulness of the data. Additionally, correct and consistent calibration and 

processing of the dosimeters is required. These are the main issues concerning the neutron dose 

of record at BNL, as discussed below. 

3.2 NEUTRON DOSIMETRY RESPONSE FUNCTIONS AS ADDRESSED IN 

NIOSH’S EVALUATION REPORT AND BROOKHAVEN NATIONAL 

LABORATORY TECHNICAL BASIS DOCUMENT 

NIOSH’s ER addressed the response functions of BNL neutron dosimetry on page 71 as follows: 

The NTA film was known by BNL to under-respond to the low-energy neutrons 

that would have been more prevalent at the reactors; this was the best available 

technology at the time. The Cd-shielded portion of the film badge was also used 

as an indication of low-energy neutron exposures. The correction factors 

provided in ORAUT-TKBS-0048 [ORAUT 2006a], Table 6-7, appropriately 

account for this known under-response. The dosimetry in place in the mid-90s 

and later successfully passed the DOELAP Performance Tests, demonstrating its 

adequacy for personnel monitoring applications. 

Table 6-7 from ORAUT-TKBS-0048 (ORAUT 2006a) is reproduced below: 
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Table 6-7. Bias and Uncertainty 

Bias magnitude and range Uncertainty factors Site-specific dosimetry system Overall biasb Range in bias Systematicc Randomd

Multi element Start-up thru 1995a 1.02 0.86–10 1.1 1.4 

Site TLD 1.01 0.95–1.05 1.05 1.2 

NTA film 

0.1 to 2 MeV 

2.0 to 14 MeV 

CR-39 

1.35 

1.35 

Unknown 

0.5–1.5 

0.65–1.35 

Unknown 

1.5 

1.35 

Unknown 

a. These values agree with Landauer since NVLAP certification (Yoder 2005). 

b. Based on most likely distribution of energy levels and geometries. Divide recorded dose by table’s bias value 

to determine deep dose. 

c. Systematic uncertainty due to lack of knowledge of actual distributions of energies and geometries. 

d. Random uncertainty due to variations among workers in energy levels and geometry. 

SC&A assumes that NIOSH is stating that if the dose reconstructor uses the information in 

ORAUT-TKBS-0048 (ORAUT 2006a, Table 6-7), then the under-response of NTA film to lowenergy neutrons and any problems with NTA film, CR-39, and/or Lexan neutron 

dosimetry/processing at any neutron energy will be adequately corrected. The following sections 

explore these issues further. 

3.3 NTA FILM UNDER-RESPONSE TO LOW-ENERGY NEUTRONS 

The threshold energy of NTA film (0.5–1.0 MeV) and the amount of dose not registered because 

of this threshold is important in neutron dosimetry and should be accounted for. 

If the information in ORAUT-TKBS-0048 (ORAUT 2006a), Section 6.11, pages 95–97, is 

analyzed, it can be seen that: 

• There were no bias or uncertainty factors found for the BNL site. 

• The values in Table 6-7 for photon film and TLDs were taken from the Hanford TBD 

(ORAUT 2004), because they should be similar to BNL. 

• The NTA film values were taken from the Atomics International (formerly ETEC) TBD 

(ORAUT 2006b), because the adjusted neutron energy values are similar and were based

on Y-12 data (ORAUT 2005a). 

• Footnote (b) of Table 6-7 of ORAUT-TKBS-0048 (ORAUT 2006a) instructs the dose 

reconstructor to divide the recorded dose by the bias value to obtain the deep dose (DD), 

Therefore, contrary to the statement on page 71 of the ER that the correction factors in 

ORAUT-TKBS-0048 (ORAUT 2006a) Table 7-6 would appropriately account for the 

NTA film under-response, the bias value would decrease the assigned dose even further. 

Additionally, SC&A could not locate any statement in the Hanford TBD (ORAUT 2004) that 

specifically lists the bias value of 1.35 for NTA film. 

From this information, it is unclear exactly where the values were obtained, and there is no 

supporting evidence to link the BNL neutron energy spectra to these other sites from which the 

parameters were obtained. The lack of details on this issue may lead to a lack of understanding 
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on the part of the dose reconstructor of how to address low-energy neutrons in dose 

reconstruction. For example, SC&A found that 80% of the final dose reconstruction reports 

for BNL claimants that required neutron dose determination, completed after the site 

profile was issued, did not include the neutron adjustment factors of 1.35 for bias or 1.5 for 

uncertainty for low-energy neutrons; only the ICRP factors of 1.91 or 2.00 as listed in 

ORAUT-TBKS-0048 were used. 

However, even if these bias and uncertainty factors were used, they are not specific to BNL and 

have not been shown to be applicable to BNL radiation exposures, dosimetry, dosimeter 

processing, and methods of data interpretation. 

Additionally, the subject of lost recorded neutron dose because of track fading is not addressed in 

the ER or the site profile. The magnitude of the proton recoil tracks in NTA film resulting from 

neutron interactions depends on the energy of the interacting neutron. Lower-energy neutrons 

create less dense proton recoil tracks; these tracks fade more rapidly with time than heavier 

tracks caused by more energetic recoil protons resulting from energetic neutrons (i.e., 0.5–

1.0 MeV neutrons in the workplace versus 1.3 MeV neutrons from a calibration source). The ER 

should address this issue and make clear and technically sound recommendations to compensate 

for the incomplete neutron doses as would be read from NTA film because of track fading. 

It is apparent from this information that the decreased response of NTA film to lower-energy 

neutrons and associated track fading has not been sufficiently investigated and compensated for 

in the dose reconstruction process for BNL workers. These findings indicate insufficient 

accuracy concerning neutron doses and could lead to potential SEC issues. 

3.4 HIGH-ENERGY NEUTRON DETECTOR (NTA/TLD/LEXAN/CR-39) 

PROBLEMS 

The problems associated with the NTA film’s 0.5–1.0 MeV threshold, track fading, and the fact 

that NTA film has a practical upper neutron energy limit for personnel monitoring initiated a 

search for other neutron dosimeters; among those tested and selected for use at BNL were the 

TLD, CR-39, and Lexan neutron dosimeters. However, these neutron dosimeters were not 

without their own problems. From the BNL documents that SC&A has analyzed, the two major 

issues that were prevalent are (1) no single neutron detector sufficiently covered all the neutron 

energies encountered in the many different radiation environments; and (2) there were problems 

with the vendors of these detectors providing consistent and accurate neutron and photon dose 

results. 

Data, such as that found in some BNL documents (e.g., Xie and Rohrig 1985 and Schaefer 

1995), indicate that there were locations at BNL accelerator facilities where the NTA film may 

not have sufficient sensitivity and/or be correctly calibrated to adequately measure neutron dose 

because of its decreased sensitivity at higher neutron energies. This information points out the 

need to have dosimetry results that compliment each other, are consistent and reliable, and to 

work with a vendor that is aware of the mixed and varied radiation fields and who is responsive 

to the facility’s needs. However, this does not appear to have always been the case at BNL, and 

this has led to two important issues, one concerned with the fact that no single neutron detector 
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sufficiently covered all the neutron energies, and the other one related to problems with the 

results from the vendors who processed the dosimeters. These issues are inter-related, because 

the properties of the neutron detectors were such that several types of detectors had to be used to 

cover the neutron energy range found at BNL; and if the readings from the vendors were not 

consistent, the obvious question is which dosimeter(s) results should have been used for the dose 

of record? From the BNL documents reviewed by SC&A and from interviews conducted with 

contemporary health physicists, it appears that there was a problem in this area, as found in a 

number of documents dating from 1986–1995, examples of which are discussed below. A 

summary spreadsheet depicting the timeline of events of these problems is provided in 

Attachment C of this document. This condensed version of the neutron dosimetry problems at 

BNL will be expanded upon in the near future (similar to SC&A’s analysis of this issue for the 

BNL site profile review) using material found in references, such as Casey 1987, Miltenberger 

1995, Musolino 1988, Schopfer 1986, Schopfer 1988, Schaefer 1995, and SM 1987. 

3.5 SUMMARY OF ADEQUACY OF NEUTRON DOSIMETRY 

In general, there appears to be sufficient recorded and retrievable external dose data at BNL for 

dose reconstruction purposes, and that a conservative RBE/QF factor has been used at BNL to 

provide a safety factor to compensate for the uncertainties involved in the different radiation 

fields found around BNL facilities. However, it is apparent that neither an RBE/QF of 10, or a 

bias factor of 1.35, nor an uncertainty factor of 1.5 is going to adequately, and consistently, 

compensate for the problems with the neutron dosimetry at some of the BNL facilities, as 

outlined above. Neither the NIOSH’s ER nor the BNL site profile mentioned these dosimetry 

problems, if they were solved, or made any recommendations concerning the use of the neutron 

dose records in light of these significant issues. 
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4.0 REFERENCES 

BNL SEC-00113. 2008. SEC Petition for All employees who worked in any area at the 

Brookhaven National Laboratory from January 1, 1947 through December 31, 2007. National 

Institute for Occupational Safety and Health, Office of Compensation Analysis and Support, 

Cincinnati, Ohio. June 27, 2008.

Cohn, S.H. 1980. BNL Memorandum: Response to Memo of August 27 Concerning Biomedical 

Whole-Body Counter, correspondence to R. Miltenberger (BNL); September 4, 1980; SRDB Ref 

ID: 55220 

Casey, W. 1987. BNL Memorandum: High Radiation Events in the External Beam. June 29, 

1987. Brookhaven National Laboratory, Upton, New York. Ref ID 50509. 

Cowan, F.P., L.F. Phillips, and R.J. King, 1964. Some Dosimetry Problems of the Alternating 

Gradient Synchrotron (AGS), Health Physics Journal, Vol. 10, pp. 33-40; February 1964; SRDB 

Ref ID: 22492 

Hull, A.P. 1978. BNL Memorandum: Institution of Routine Whole-Body Counting by Safety 

and Environmental Protection Division, correspondence to C. Meinhold (BNL); August 28, 

1978; SRDB Ref ID: 55254 

Hull, A.P. 1979. BNL Memorandum: Whole-Body Counting Program Review and 

Recommendations, Response to C. B. Meinhold (BNL); October 31, 1979; SRDB Ref ID: 55177 

ICRP (International Commission on Radiological Protection) 1990. Recommendations of the 

International Commission on Radiological Protection, Publication 60, Pergamon Press, Oxford, 

England. 

Miltenberger, R. 1995. BNL Memorandum, Subject: Neutron Dose Records at the AGS. April 

19, 1995. Brookhaven National Laboratory, Upton, New York. Ref ID 22456. 

Musolino, S. 1988. BNL Memorandum, Subject: February AGS Neutron Dose Adjustment. 

April 18, 1988. Brookhaven National Laboratory, Upton, New York. Ref ID 50948. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00113, Rev. 0. National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. September 29, 2009. 

ORAUT (Oak Ridge Associated Universities) 2004. Technical Basis Document for the Hanford 

Site – Occupational External Dose, ORAUT-TKBS-0006-6, Rev. 01, Oak Ridge Associated 

Universities Team, Oak Ridge, Tennessee. January 9, 2004. 

ORAUT (Oak Ridge Associated Universities Team) 2005a. Technical Basis Document for the 

Y-12 National Security Complex – Occupational External Dose, ORAUT-TKBS-0014-6, Rev. 

00 PC-1, Cincinnati, Ohio. October 11, 2005. 
Effective Date: 

February 23, 2010 

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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. 

ORAUT (Oak Ridge Associated Universities Team) 2006a. Technical Basis Document for the 

Brookhaven National Laboratory - Summary Site Profile, ORAUT-TKBS-0048, Rev. 00, 

Cincinnati, Ohio. August 30, 2006. 

ORAUT (Oak Ridge Associated Universities) 2006b. Technical Basis Document for the Energy 

Technology Center - External Dosimetry, ORAUT-TKBS-0038-6, Oak Ridge Tennessee. 

Schopfer, C. 1986. Letter to Landauer, Inc., December 15, 1986. Brookhaven National 

Laboratory, Upton, New York. Ref ID 50798. 

Schopfer, C. 1988. Letter to Landauer, Inc., May 5, 1988. Brookhaven National Laboratory, 

Upton, New York. Ref ID 55394. 

Schaefer, C. 1995. BNL Memorandum. AGS Neutron Dosimetry. July 26, 1995. Brookhaven 

National Laboratory, Upton, New York. Ref ID 22456. 

S.M. 1987. Memorandum from S.M. of BNL to C. Schopfer of BNL. Problems in AGS 

Personnel Monitoring. February 24, 1987. Brookhaven National Laboratory, Upton, New York. 

Ref ID 50954. 

Yoder, R.C., 2005. “Landauer film info,” e-mail to L Faust, Landauer Inc, Glenwood, Illinois. 

December 7, 2005. 

Xie, Y, and Rohrig, N. 1985. BNL Memorandum from Xie and Rohrig to Malinowski, T. of 

BNL. Bonner sphere neutron measurements at the AGS. November 22, 1985. Brookhaven 

National Laboratory, Upton, New York. Ref ID 50833. 
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NOTICE:

ATTACHMENT A: PRELIMINARY MATRIX ISSUES FOR THE 

BROOKHAVEN NATIONAL LABORATORY SEC PETITION AND 

NIOSH EVALUATION REPORT REVIEW 

This matrix contains a list of the preliminary issues for the Brookhaven National Laboratory 

(BNL) SEC Petition with a proposed class from January 1, 1947, through December 31, 2007. It 

is based on a preliminary assessment of the following: 

• The NIOSH Evaluation Report dated September 29, 2009 

• The BNL Petition SEC-00113 

• SC&A’s Site Profile Review 

• A partial review of BNL documents 

NIOSH has proposed that the classes of workers be reduced to cover only the period of 

January 1, 1947, to December 31, 1979, because sufficient monitoring data are available to 

estimate exposures with sufficient accuracy for all workers employed beginning January 1, 1980. 
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Preliminary Issues Matrix for the Brookhaven National Laboratory SEC Petition and NIOSH Ev

February 23, 2010 

No. Issue NIOSH ER position (SC&A reading) SC&A I

1 Availability of 

Bioassay Records: 1980–2007 

• NIOSH has stated in their ER for BNL SEC-00113 that 

according to the information in the BNL documents NIOSH has 

captured, 1980 was the turning point at which bioassay data become sufficiently available to perform adequate dose reconstruction. 

• NIOSH has stated that according to the data presented in the 

ER, there are sufficient bioassay records available, beginning around 1980, to perform adequate dose reconstruction; therefore, the SEC should be limited to 1947–1979. 

• NIOSH assumes that all the bioassay records contained in the 

numerous historical database systems have been coordinated and are available to the dose reconstructor. 

• NIOSH assumes that there are no SEC issues concerning 

bioassay data for the period 1980–2007. 

(1) SC&A’s analyses of the 

do not support the assumpoint, such as 1980, in wrecords became sufficieadequate dose reconstru

(2) SC&A’s preliminary tec

amount of bioassay data indicate that bioassay dsufficiently available ardose reconstruction. 

(3) The ER does not establi

been stored on numerousystems at BNL have beare accessible for the do

(4) The reason(s) for and im

number, and erratic behbioassay data beginning many of the facilities waddressed in the ER. 

(5) In summary, SC&A did 

and data provided in the that a plan to centralize (urinalysis and others, asuccessfully initiated in completion, and maintaadequate dose reconstru

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Preliminary Issues Matrix for the Brookhaven National Laboratory SEC Petition and NIOSH Ev

February 23, 2010 

No. Issue NIOSH ER position (SC&A reading) SC&A I

2 Adequacy of Neutron 

Dosimetry 

• NIOSH apparently did not consider neutron dosimetry to be an 

issue at BNL; therefore, it only required a brief mention on 

pages 71–72 of the ER. 

• NIOSH apparently did not consider neutron energy fields in the 

work place, and associated dosimetry responses, to be an issue 

at BNL; therefore, it was not addressed in detail in either the BNL TBD or the ER. 

• NIOSH recommends relying on the BNL tradition of using a 

quality factor (QF) of 10, and the bias and uncertainty values in 

Table 6-7 of the TBD, to compensate for: 

o Any under-response or undetected neutron doses at low or 

high energies 

o Differences in neutron dosimetry methods o Problems with vendor dosimetry processing, calibration, 

and reporting procedures. 

(1) SC&A did not find that 

BNL were without prob

nor fading of NTA film problems with NTA, TLresponse, vendor dosimdetermination were not 

(2) The reliance on the trad

bias and uncertainty facnot adequately address the varied facilities at B

(3) Most of the bias and un

the TBD were from othderived from BNL data

(4) Using a QF of 10 canno

under-response or unde

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ATTACHMENT B: BIOASSAY DATA ISSUES FOR BNL-SEC MATRIX 

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ATTACHMENT C: NEUTRON DOSIMETRY ISSUES FOR BNL-SEC MAT

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