Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE NIOSH SITE PROFILE FOR 

LAWRENCE BERKELEY NATIONAL LABORATORY 

Contract No. 200-2009-28555 

SCA-TR-SP2010-0002

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

January 22, 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-TR-SP2010-0002 

Effective Date: 

January 22, 2010 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation and Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 – Draft 

REVIEW OF THE NIOSH SITE PROFILE 

FOR LAWRENCE BERKELEY NATIONAL 

LABORATORY 

Page 2 of 83 

Task Manager: 

________________________ Date: ___________ 

Charles Phillips 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 
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TABLE OF CONTENTS 

Acronyms and Abbreviations ..........................................................................................................6 

1.0 Executive Summary.............................................................................................................8 

1.1 Finding 1: Inadequate Documentation of Historical Operations and Sources 

of Radiological Exposures .......................................................................................9 

1.2 Finding 2: Insufficient Information for Internal Dose Reconstruction, 

Especially during the Early Years............................................................................9 

1.3 Finding 3: Special Forms of Tritium and Plutonium not Addressed by 

NIOSH ...................................................................................................................10 

1.4 Finding 4: Bioassay Data Completeness and Adequacy have not been 

Verified ..................................................................................................................10 

1.5 Finding 5: Insufficient Justification for Selection of IREP Energy Range 

Fractions for Photon Exposures.............................................................................11 

1.6 Finding 6: Insufficiency of Neutron Dosimetry Treatment ..................................11 

1.6.1 NTA Film Energy Threshold Determination.............................................11 

1.6.2 Failure to Adjust Recorded Doses to Correct for Lack of Response 

of NTA and CR-39 in the Intermediate and Thermal Neutron Energy 

Range .........................................................................................................12 

1.6.3 Selection of Minimum Detectable Dose for CR-39 Dosimeters ...............13 

1.6.4 Use of Neutron-Gamma Ratios for Situations Where Neutron Data 

are Lacking: Seeming Inconsistency Between the Environmental 

and External Dose Sections .......................................................................13 

1.7 Finding 7: Failure to Justify the Shallow Dose: Deep Dose Assumption............13 

1.8 Finding 8: Uncertainty in Beta-Gamma Dosimeter Response to Radiation 

Types and Energies................................................................................................14 

1.8.1 The Use of Early Electroscope Data Needs Greater Definition ................14 

1.8.2 Dosimeter Response to Very High Energy Photons and Charged 

Particles......................................................................................................14 

1.9 Finding 9: X-ray Exposures are Uncertain ...........................................................15 

1.10 Finding 10: Uncertainty of Calculating Doses Prior to 1961 ...............................15 

1.11 Finding 11: Inadequacy of Bioassay Analyses Presentation ................................15 

1.12 Finding 12: Failure to Provide Sufficient Guidance for Unmonitored 

Workers..................................................................................................................16 

1.13 Finding 13: Inadequate Coverage of Occupational Environmental Dose ............17 

2.0 Introduction and Scope ......................................................................................................19 

2.1 Introduction............................................................................................................19 

2.2 Review Approach...................................................................................................20 

2.3 Report Organization...............................................................................................21 

3.0 Assessment Criteria and Methods......................................................................................23 
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3.1 Objectives ..............................................................................................................23 

3.1.1 Objective 1: Completeness of Data Sources.............................................23 

3.1.2 Objective 2: Technical Accuracy..............................................................23 

3.1.3 Objective 3: Adequacy of Data.................................................................24 

3.1.4 Objective 4: Consistency among Site Profiles..........................................24 

3.1.5 Objective 5: Regulatory Compliance........................................................24 

3.2 Site Profile Strengths .............................................................................................26 

4.0 Vertical Issues....................................................................................................................28 

4.1 Finding 1: Inadequate Documentation of Historical Operations and Sources 

of Radiological Exposures .....................................................................................28 

4.2 Finding 2: Insufficient Information for Internal Dose Reconstruction, 

Especially during the Early Years..........................................................................29 

4.3 Finding 3: Special Forms of Tritium and Plutonium not Addressed by 

NIOSH ...................................................................................................................30 

4.4 Finding 4: Bioassay Data Completeness and Adequacy have not been 

Verified ..................................................................................................................30 

4.5 Finding 5: Insufficient Justification for Selection of IREP Energy Range 

Fractions for Photon Exposures.............................................................................31 

4.6 Finding 6: Insufficiency of Neutron Dosimetry Treatment ..................................32 

4.6.1 NTA Film Energy Threshold Determination.............................................32 

4.6.2 Failure to Adjust Recorded Doses to Correct for Lack of Response 

of NTA and CR-39 in the Intermediate and Thermal Neutron Energy 

Range .........................................................................................................32 

4.6.3 Selection of Minimum Detectable Dose for CR-39 Dosimeters ...............33 

4.6.4 Use of Neutron-Gamma Ratios for Situations Where Neutron Data 

are Lacking: Seeming Inconsistency Between the Environmental 

and External Dose Sections .......................................................................33 

4.7 Finding 7: Failure to Justify the Shallow Dose-TO-Deep Dose Assumption.......34 

4.8 Finding 8: Uncertainty in Beta-Gamma Dosimeter Response to Radiation 

Types and Energies................................................................................................35 

4.8.1 The Use of Early Electroscope Data Needs Greater Definition ................35 

4.8.2 Dosimeter Response to Very High Energy Photons and Charged 

Particles......................................................................................................36 

4.9 Finding 9: X-ray Exposures are Uncertain ...........................................................36 

4.10 Finding 10: Uncertainty of Calculating Doses Prior to 1961 ...............................37 

4.11 Finding 11: Inadequacy of Bioassay Analyses Presentation ................................37 

4.12 Finding 12: Failure to Provide Sufficient Guidance for Unmonitored 

Workers..................................................................................................................38 

4.13 Finding 13: Inadequate Coverage of Occupational Environmental Dose ............39 

4.14 Secondary Issues....................................................................................................40 

5.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................44 
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5.1 Satisfying the Five Objectives ...............................................................................44 

5.1.1 Objective 1: Completeness of Data Sources.............................................44 

5.1.2 Objective 2: Technical Accuracy..............................................................44 

5.1.3 Objective 3: Adequacy of Data.................................................................45 

5.1.4 Objective 4: Consistency among Site Profiles..........................................45 

5.1.5 Objective 5: Regulatory Compliance........................................................45 

6.0 Usability of Site Profile for Intended Purpose...................................................................46 

6.1 Ambiguous Dose Reconstruction Direction ..........................................................46 

6.2 Inconsistencies and Editorial Errors in the Site Profiles........................................47 

6.3 Unresolved Policy or Generic Technical Issues ....................................................48 

7.0 References..........................................................................................................................49 

Attachment 1: Technical Documents Considered During the Review .........................................51 

Attachment 2: Master Interview Summary...................................................................................53 

Attachment 3: Issue Resolution Matrix for SC&A Findings on the LBNL Site Profile 

Review, ORAUT-TKBS-0049...........................................................................................70 
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ACRONYMS AND ABBREVIATIONS 

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

ANL-E Argonne National Laboratory-East 

AWE Atomic Weapons Employer 

Bq Becquerel 

CFR Code of Federal Regulations

D&D Decontamination and Decommissioning 

DOE Department of Energy 

DOL Department of Labor 

DL Detection Limit 

EDE Effective Dose Equivalent 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ESE Entrance Skin Exposure 

GSD Geometric Standard Deviation 

HEP High Energy Physics 

HHS Health and Human Services 

HILAC Heavy-Ion Linear Accelerator 

IREP Interactive RadioEpidemiological Program 

keV kilo electron volt; 1,000 electron volts 

LANL Los Alamos National Laboratory 

LBNL Lawrence Berkeley National Laboratory 

LLNL Lawrence Livermore National Laboratory 

LOD Limit of Detection 

LRL Lawrence Radiation Laboratory 

LRL-B Lawrence Radiation Laboratory Berkeley 

MDA Minimum Detectable Activity 

MDC Minimum Detectable Concentration 

MDL Minimum Detectable Level 

MeV Million electron volts 

mrem Millirem 

NESHAPs National Emissions Standards for Hazardous Air Pollutants 

NIOSH National Institute for Occupational Safety and Health 
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NOCTS NIOSH OCAS Claims Tracking System 

NTA Eastman Kodak Nuclear Track Film Type A 

NTLF National Tritium Labeling Facility

NTS Nevada Test Site 

OBT Organically Bound Tritium 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 

ORAUT Oak Ridge Associated Universities Team 

OTIB ORAUT Technical Information Bulletin 

PA Posterior-Anterior 

PFG Photofluorography 

POC Probability of Causation 

rem Roentgen equivalent man 

SC&A S. Cohen and Associates 

TBD Technical Basis Document 

TIB NIOSH Technical Information Bulletin 

TLD Thermoluminescent Dosimeter 

UC University of California 

UCB University of California-Berkeley 

WB Whole Body 

WBC Whole-Body Counting 
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1.0 EXECUTIVE SUMMARY 

This report provides the results of an independent review of the Lawrence Berkeley National 

Laboratory (LBNL) technical basis document (TBD) conducted by S. Cohen and Associates 

(SC&A). This review was authorized by the Advisory Board on Radiation and Worker Health 

(Advisory Board) during the Advisory Board meeting held in Augusta, Georgia, on December 

16–18, 2008. The TBD, ORAUT-TKBS-0049 (ORAUT 2007), is the site profile developed by 

the National Institute for Occupational Safety and Health (NIOSH) for the LBNL site. This 

review was conducted during the period January 2009–October 2009, in support of the Advisory 

Board’s statutory responsibility under the Energy Employees Occupational Illness Compensation 

Program Act of 2000 (EEOICPA). This authority includes the conduct of such reviews and 

advising the Secretary of Health and Human Services (HHS) on the “completeness and 

adequacy” of the EEOICPA program. 

LBNL was founded in 1931 on the University of California – Berkeley campus. It was 

originally known as the University of California Radiation Laboratory. Throughout its history, 

LBNL has been operated by the University of California – Berkeley for the Department of 

Energy (DOE) and its predecessors. In July 1945, LBNL moved from the Berkeley campus to a 

134-acre site in the hills to the east. LBNL began defense work in 1941, when the National 

Defense Research Committee appointed Ernest O. Lawrence to study the potential military uses 

of U-235. LBNL is alternatively referred to in reference documents as Berkeley Lab, Lawrence 

Radiation Laboratory (LRL), and Lawrence Radiation Laboratory – Berkeley (LRL-B). 

The TBD was evaluated for its completeness, technical accuracy, adequacy of data, compliance 

with stated objectives, and consistency with other site profiles, as stipulated in the SC&A

Standard Operating Procedure for Performing Site Profile Reviews (SC&A 2004). As “living” 

documents, TBDs are constantly being revised as new information, experience, or issues arise. 

The list of supporting documents that were reviewed by SC&A for this site profile review is 

provided in Attachment 1. 

This review found that the site profile provides an inadequate overview of LBNL historical 

operations and the primary radiological exposure sources and conditions. The presentation and 

analyses of the available data were generally technically sound, but not succinctly presented and 

documented to allow for a comprehensive review. The period covered is large, as it is for 

several of the other DOE sites and, like other sites, the earliest data are absent. The TBD failed 

to fully address the exposure implications of all the various radiation sources to the degree 

necessary to allow a comprehensive assignment of historical doses, including missed doses. 

Issues presented in this report are sorted into the following categories, in accordance with 

SC&A’s review procedures: 

(1) Completeness of Data Sources 

(2) Technical Accuracy 

(3) Adequacy of Data 

(4) Consistency among Site Profiles 

(5) Regulatory Compliance 
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Following the introduction and a description of the criteria and methods employed to perform the 

review, the report discusses the strengths of the TBD, followed by a description of the major 

issues identified during our review. The issues were carefully reviewed with respect to the five 

review criteria above. Thirteen of the issues were designated as findings, because they represent 

deficiencies in the TBD that need to be corrected, and which have the potential to materially 

impact at least some dose reconstructions. These findings are summarized below. 

1.1 FINDING 1: INADEQUATE DOCUMENTATION OF HISTORICAL 

OPERATIONS AND SOURCES OF RADIOLOGICAL EXPOSURES 

This review found that the site profile provides an inadequate overview of LBNL historical 

operations and the primary radiological exposure sources and conditions. The document lacks 

sufficient detail and analysis to provide comprehensive guidance to dose reconstructors. The 

period covered is large, as it is for several of the other DOE sites; however, the TBD failed to 

fully address the exposure implications of radiation sources to the degree necessary to allow a 

comprehensive assignment of historical doses, including missed doses. 

The site profile covers six areas; the Introduction, Site Description, Occupational Medical Dose, 

Occupational Environmental Dose, Occupational Internal Dose, and Occupational External 

Dose. SC&A’s review found that each of these sections was deficient in its presentation of the 

information available on the subject for LBNL. Site profiles for other DOE sites whose 

historical operations are equally or less complex and diverse are more complete and informative 

to their intended audience than ORAUT-TKBS-0049. SC&A has made this determination 

through a review of historical records and interviews with site experts. 

Specific operations and facilities are not discussed in sufficient detail. A prime example of the 

lack of significant detail and information is the coverage of the National Tritium Labeling 

Facility (NTLF). This facility provided tritium-labeled compounds for biological and medical 

research. The NTLF handled large quantities of tritium in a great variety of chemical forms, 

including organically bound tritium (OBT) compounds (see Finding 3). 

 

The site profile fails to discuss the accelerator program at LBNL. Since this is the major source 

of exposure to site workers, this represents a major exclusion. The site profile should discuss the 

historical development of accelerators at LBNL, and provide a discussion of the various 

accelerators developed and the potential for routine, unmonitored, and accidental exposure to 

workers from these sources. 

1.2 FINDING 2: INSUFFICIENT INFORMATION FOR INTERNAL DOSE 

RECONSTRUCTION, ESPECIALLY DURING THE EARLY YEARS 

There is insufficient information on bioassay monitoring before 1961, and the information on air 

sampling and building activities is not sufficient to calculate the workers’ dose due to internal 

exposures. Workers were potentially exposed to a diversity of radionuclides at LBNL, as shown 

in Table 2-1 of the TBD. Table 2-1 is incomplete in relation to the periods of time and quantities 

of radionuclides that were handled in the different areas. In addition, Table 2-1 gives no 

references for the source of information included in the table. 
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which LBNL dosimetry staff verified were not in the database; therefore; it appears that the 

Table 5-8 was derived for calendar years 2001–2004, based primarily on airborne release data 

reported under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs). No 

indication is given of the methodology used to convert air emissions to radionuclide inventory. 

Table 5-8 is of limited value, because of its inability to relate exposures during the various 

periods of time to the 2001–2004 emissions. 

Table 5-4 lists minimum detectable activities (MDAs) for in-vitro measurements, but is 

incomplete with regard to the totality of radionuclides and their MDAs that were handled at 

LBNL. The information on MDAs on the various periods is incomplete, posing a problem with 

the calculation of missed doses. Potential missed dose associated with inadequate bioassay 

techniques is not mentioned in this TBD. Discussions on the adequacy of monitoring techniques 

are missing, and the methods of analysis for many radionuclides are not specified; thus, the 

quality of the measurement techniques cannot be evaluated. 

Gross alpha, beta, and gamma analyses are reported as being used for the entire site operation, 

including the present time. The TBD does not discuss the fact that many radionuclides present at 

LBNL would not have been detected by gross measurements, or at least detected with low 

recoveries and resulting high minimum detectable concentrations (MDCs). In addition, the use 

of gross measurements results in an indeterminate MDC for a specific radionuclide. The 

potential missed dose associated with non-specific bioassay techniques should be further 

investigated to determine the impact on internal dose calculations. 

1.3 FINDING 3: SPECIAL FORMS OF TRITIUM AND PLUTONIUM NOT 

ADDRESSED BY NIOSH 

NIOSH fails to identify in the site profile that metal tritides and organically bound tritium (OBT) 

are included in the materials used at the site, and that tritium was used extensively at LBNL, in 

particular at the NTLF, Building 75. There is very little discussion about tritium exposures in the 

internal dose section (Section 5.0) of the site profile. It was stated during the interviews that 

OBT and metal (at least uranium and titanium) tritides were handled at NTLF. Section 5.0 does 

not discuss specifically the frequency of bioassay sampling that was performed at NTLF, which 

is the most important parameter in performing adequate bioassay monitoring for tritium. 

During the interviews, health physicists stated that it was possible that highly oxidized/high-fired 

forms of actinides were handled at the site. They stated that the most likely source of exposure 

to these forms would have been related to the production of sealed sources and targets that were 

made for use at LBNL and other national laboratories. It is possible that NIOSH is addressing 

this issue for plutonium exposures at LBNL; however, the site profile does not address high-fired 

forms of other actinides (thorium, uranium, etc.). NIOSH should update the site profile detailing 

how it will handle high-fired forms of actinides in dose reconstruction for this site. 

1.4 FINDING 4: BIOASSAY DATA COMPLETENESS AND ADEQUACY HAVE 

NOT BEEN VERIFIED 

During the site visit by SC&A, it was determined that the bioassay database does not contain all 

bioassay data for all workers. SC&A found bioassay data in old files during the records search, 
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ear 

 Tables 5-1 through 5-5 of the TBD, NIOSH listed many in-vitro and in-vivo bioassay 

any of 

uring the site interviews, it appeared that work conducted at the Donner Laboratory and other 

ility 

.5 FINDING 5: INSUFFICIENT JUSTIFICATION FOR SELECTION OF IREP 

 Table 6-2 of the TBD, beta and photon doses are assigned to energy ranges according to the 

tion is 

ergies 

egardless of the precise fraction that should be assigned, the choice of less than 100% to the 

e 

0% 

.6 FINDING 6: INSUFFICIENCY OF NEUTRON DOSIMETRY TREATMENT 

.6.1 NTA Film Energy Threshold Determination 

As has been the case in a number of site profiles prepared by NIOSH, there is an inconsistent 

tion 

r 

database may be incomplete. In addition, bioassay submittals were delinquent by at least 1 y

in some file records. This delay could increase the minimum detectable doses significantly, 

especially for soluble and short effective half-life nuclides. 

 

In

methods, along with information on frequency of sampling. Given the great number of 

radionuclides that could have resulted in internal exposures at LBNL, it is apparent that m

these are short-lived relative to the bioassay frequency. 

D

laboratories at the University of California – Berkeley campus was not monitored and/or 

controlled as stringently as at other LBNL facilities. NIOSH should investigate the possib

that internal dose information (bioassay and air sampling data) for the work at these laboratories

is adequate to reconstruct doses at these locations. 

1

ENERGY RANGE FRACTIONS FOR PHOTON EXPOSURES 

In

radioactive materials used in individual buildings at LBNL. For Buildings 51 and 71, a single 

photon energy distribution is given, and 10% of the measured dose is assigned to the 30–

250 keV range and 90% assigned to >250 keV. It appears that this photon energy distribu

being applied to the entire history of accelerator use at LBNL. It is questionable that this energy 

distribution is appropriate in all situations and timeframes. In the early years, it is much more 

likely that technicians and others would be exposed to low-energy emitters shortly after a 

machine was powered off, or even during operation. This was presumably less likely as en

and risks grew larger and commensurate standards and protective practices evolved. 

R

30–250 keV category should only be made where there is supporting evidence. As it stands, th

selection of a 10% fraction is not claimant favorable and not buttressed by the inclusion of 

supporting evidence. Although the other buildings have been assigned factors greater than 1

for the more claimant-favorable 30–250 keV photon energy range, the fact that the accelerator 

buildings have been assigned a single low factor creates doubt on the validity and process by 

which the other factors were determined for the remainder of the site. NIOSH should provide

justification, other than, “...it was done in a manner similar to the LLNL and LANL facilities” 

for the assignment of the fractional factors in Table 6.2 of the TBD. 

1

1

approach to the energy cut-off for the NTA neutron dosimeter. Callout “c.” in Table 6.5 

references NIOSH 2002 as listing the NTA lower energy threshold at 500 keV, yet attribu

number 47 discusses 800 keV as the threshold, and this is used as the basis for this TBD. Othe
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e. 

f 

.6.2 Failure to Adjust Recorded Doses to Correct for Lack of Response of NTA and 

Table 6.6 of the TBD, “Adjustments to Recorded Dose,” defines the corrections for photon and 

here is virtually no discussion of the potential for neutron fields throughout this historical 

dinghere is a remarkable silence as to thermal or slow neutron exposure in the site profile 

 that one 

Dose reconstructors should use the electroscope results in a qualitative manner 

ure or 

the 

o other mention of slow or thermal neutrons is made. A search of the “O” drive revealed only 

ld 

r the 

sources list 1,000 keV as the threshold for NTA response. The assumption that NTA film 

responds down to 500 keV is not justified by the technical data and is not claimant favorabl

This issue is especially important, as the field to which the individual was exposed is usually 

poorly characterized, and the neutron weighting factors are large and variable over the range o

0.1 to 2 MeV. 

1

CR-39 in the Intermediate and Thermal Neutron Energy Range 

neutron dosimeters to adjust the measured quantity. However, no adjustment is indicated for the

failure of NTA film to respond to intermediate energy neutrons. As presented, a significant part 

of the spectrum is inappropriately monitored and uncorrected. 

T

facility. Given that LBNL was a world leader in accelerator development, and given the lea

edge high energies developed by the machines, it is likely that there was the potential for 

unanticipated radiation fields and possible neutron exposures across a range of energies, 

especially in the early decades. Some discussion of this is called for in the TBD. 

T

document. Only one mention of slow neutrons is made in the site profile document and

is only made in passing (bold added for emphasis): 

because no data were found on the calibration or energy response of these 

devices; they should use the film or TLD results to estimate the actual expos

the electroscope reading if no corresponding dosimeter reading exists. The 

electroscope results include daily readings in tables captioned “dosimeter,”

“slow neutron,” and “electroscope.” The three readings, which occurred on 

same dates, were evidently used to measure exposure at the end of work shifts.... 

N

a single document (referenced in the above paragraph) that mentioned slow or thermal neutrons. 

Clearly there was the potential for exposure to slow neutrons, as slow neutron electroscopes were 

in use in 1956 and readings were documented for several individuals. NIOSH should investigate 

the issue as a part of a broader look at the intermediate and slow neutron exposure potential. 

It is unclear from the TBD how and when albedo TLD data were merged with CR-39 results. 

The gap in neutron response from above the cadmium cutoff to the lower energy threshold for 

CR-39 (also not mentioned, but assumed to be around 150 keV) is not discussed. NIOSH shou

evaluate the neutron program and determine how missed intermediate energy neutron dose 

should be determined for this period, as well as intermediate and thermal energy neutrons fo

NTA and pre-NTA years. 
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1.6.3 Selection of Minimum Detectable Dose for CR-39 Dosimeters 

Table 6-1 of the TBD shows that the MDL for CR-39 is 10 mrem, with no attribution provided. 

The Los Alamos TBD shows an MDL for CR-39 of 20 mrem. The current commercial service 

available from Landauer, Inc., also shows an MDL of 20 mrem. It is likely that the minimum 

detectable level for CR-39 is higher than 10 and more likely around 20 mrem. This number is 

important and it is likely to be amplified to take account of missed dose not only due to exposure 

below the detection limit (DL), but also to estimate dose due to lower energy neutrons that would 

have been missed entirely due to the inability of CR-39 to detect lower-energy neutrons. 

1.6.4 Use of Neutron-Gamma Ratios for Situations Where Neutron Data are Lacking: 

Seeming Inconsistency Between the Environmental and External Dose Sections 

Table 4.1 of the Environmental Occupational Dose section (Section 4.0) of the TBD contains 

estimates of annual environmental dose throughout the history of the facility. The values 

provided are totals of neutron and photon exposure. 

The Environmental Dose section utilizes a ≥70% factor and the External Dose section utilizes a 

42% factor. This significant difference in the average site-wide neutron-to-photon ratio is 

surprising. It is possible that the environmental dose includes more sky shine and other factors. 

However, this issue needs to be addressed and the large difference explained. 

This section on the determination of missed and missing neutron exposure needs a thorough 

review. Both the source terms and the dosimeter response specifications need to be addressed. 

1.7 FINDING 7: FAILURE TO JUSTIFY THE SHALLOW DOSE: DEEP DOSE 

ASSUMPTION 

The TBD provides guidance on the dose to be assigned in the “early” years (pre 1979) for which 

there is no record of beta exposure. In the general case, there is an assumption that a factor of 3 

for the ratio of shallow to deep dose is reasonable and claimant favorable. However, LBNL had 

a broad mandate, as the Site Description section states on page 8: 

From the 1950s to the present, the laboratory has maintained its status as a major 

international center for physics research and has diversified its research program 

into almost every realm of scientific investigation. 

In most cases, the site description does not provide sufficient detail as to the quantities, forms, 

and methods under which these materials were handled. What is known is that the levels of 

protection in the 1940s, 1950s, and 1960s were far from what would be considered good practice 

today. 

There is no mention of head and eye dose or non-uniform whole-body irradiation in the site 

profile. Typically, workers handling beta emitters and those performing maintenance inside 

accelerators can be exposed to significant non-uniform fields. Likewise, there is no mention in 

the TBD of potential skin and clothing contamination and resultant exposure. 
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It is unclear from the TBD if workers were exposed to significant shallow dose with possibly 

little deep dose to be used as an indicator. Possible activities that may have been conducted 

include fume hood operations, maintenance of accelerators, ventilation and plumbing systems, 

waste disposal operations, and spill cleanup. The lists of nuclides are extensive and include beta 

emitters, including some pure beta and low-energy x-ray emitters. For some personnel, the 3:1 

ratio may not be claimant favorable. NIOSH should identify the workers who could have 

received exposure from these beta or low-energy x-ray emitters, or provide an alternative method 

of estimating the shallow dose in a claimant-favorable manner. 

1.8 FINDING 8: UNCERTAINTY IN BETA-GAMMA DOSIMETER RESPONSE TO 

RADIATION TYPES AND ENERGIES 

1.8.1 The Use of Early Electroscope Data Needs Greater Definition 

Page 39 of the TBD describes the use of electroscope data as follows: 

... LBNL began operations using dosimeter and processing technical support 

provided by the Metallurgical Laboratory at the University of Chicago. After 

1952, LBNL operated its own fully functional personnel dosimetry program with 

in-house processing. Exposure data were recorded by film badges and 

thermoluminescent dosimeters (TLDs). Early exposure records also provided 

electroscope (or at times, electrometer or E was used) results, which 

supplemented the results measured by film. Dose reconstructors should use the 

electroscope results in a qualitative manner because no data were found on the 

calibration or energy response of these devices; they should use the film or TLD 

results to estimate the actual exposure or the electroscope reading if no 

corresponding dosimeter reading exists. 

A search of the “O” drive found that, anecdotally at least, there were significant problems with 

electroscopes. A study performed November 23, 1953, by Jim Bennett (Bennett 1953) showed 

that readings from the three electroscopes tested were widely divergent from the film that was 

exposed with them. Two gave a 10% response compared with the film, and the third was off 

scale. No details are provided as to the energy of the gamma source used for the exposure. 

However, the memo provides a cautionary statement as to using electroscope data even in a 

qualitative manner. 

1.8.2 Dosimeter Response to Very High Energy Photons and Charged Particles 

LBNL was a pioneer in the development of high energy physics (HEP) and in the search for 

exotic particles. The film and electroscopes in use in the early decades will likely not have been 

calibrated for energies above 1 or 2 MeV. NIOSH should evaluate the dosimetry and potential 

for exposure to radiation at energies above that commonly produced by radioisotopes. The 

detectors will have responded to some degree, but the correction factor size and sign are 

unknown and not mentioned in the TBD. The response of the detector element or film, for 

example, will depend greatly on the composition of the holder and filters. 
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1.9 FINDING 9: X-RAY EXPOSURES ARE UNCERTAIN 

Table 3-1 lists the entrance skin exposure (ESE) doses used for the posterior/anterior (PA) chest 

exam. It states that, until 1975, all dose estimates are defaulted to those provided in ORAUTOTIB-0006. There is no information identified as being available on x-ray equipment that was 

used prior to 1975. Depending on how one views this information, there is no indication that this 

default is claimant favorable for the years 1942 through 1975. NIOSH needs to better describe 

what measures were taken to determine what types of equipment were used. For example: 

• Where did workers get exams between the years 1942–1975? 

• Were medical records available and do they indicate if x-rays were taken? 

• Were workers sent to alternate locations for exams and were those records researched? 

• Did NIOSH research address the potential use of PFGs to screen workers up through 

1960? 

The TBD should be expanded in its discussion of the medical dose to address the issues indicated 

in the above questions in order to be considered complete. 

1.10 FINDING 10: UNCERTAINTY OF CALCULATING DOSES PRIOR TO 1961 

There is no information on how NIOSH is planning to reconstruct doses before 1961. In 

ORAUT-TKBS-0049: 

• Table 5-1 lists the in vitro types of bioassay, the periods, and the frequencies of 

monitoring. It does not contain any information that might be applicable to calculate 

doses for exposures before 1961. 

• Table 5-4 lists the MDAs for various analysis results. The only pre-1961 information 

available is the MDA for gross alpha, and gross beta is for 1957–1961. 

• Table 5.8 contains only one reference to exposures before 1961. 

• Looking at the files for LBNL in the NIOSH OCAS Claims Tracking System (NOCTS), 

24 claimants received compensation. Those were probably the most exposed workers, 

and 18 of the 24 claimants started working before 1961. There is only one bioassay 

record before 1961; a uranium urinalysis done in 1958. 

• Looking at the 99 claimant files for LBNL who did not receive compensation, 31 started 

working before 1961. There is only one bioassay record before 1961; a C-14 breath 

analysis performed after an incident in 1959. 

There is insufficient information related to bioassay monitoring before 1961 in the TBD. 

1.11 FINDING 11: INADEQUACY OF BIOASSAY ANALYSES PRESENTATION 

There was a diversity of radionuclides at LBNL. The Occupational Internal Dose section of 

ORAUT-TKBS-0049 specifies that, “from 1960 to 1996, both in vitro and in vivo monitoring 

records and associated interpretations exist.” On Table 5.4, MDAs are listed for gross alpha for 
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isotopes of thorium, plutonium, curium, actinium, and neptunium. The same method and MDA 

is listed for Cf-252 from 1965–1995. There is a remark specifying that “method descriptions 

note that uranium, radium, and polonium are not detected by this method (Author unknown, no 

date).” 

Table 5.8, “Radionuclides and fraction activity by facility,” is incomplete and difficult to use, in 

relation to discrimination between exposures during the various periods of time the rooms were 

used in the installation. 

In NOCTS, the files indicate that for the 24 claimants from LBNL that received 

compensation, 22 started working before 1969. Some claimants had just one bioassay 

record during their entire work life, which sometimes spanned to over three decades. 

• Of the 99 claimants for LBNL in NOCTS who did not receive compensation, 59 started 

working before 1969. No in-vivo monitoring was recorded in the period 1960–1969. 

• A document referenced in ORAUT-TKBS-0049, entitled, Individual Bioassay Reports 

for Employees Beginning Last Name with A - 1965–1990, indicates that only gross alpha 

is reported until 1968, and gross alpha, gross beta, and gamma are reported in 1969. The 

first whole-body counting (WBC) is reported in 1970. 

• The document SRDB 21986, titled, Terminated Bioassay Results of Employees With Last 

Name Beginning with A, 1961-1983, and referenced in ORAUT-TKBS-0049, lists 

bioassay monitoring of 106 employees with last names beginning with A and B. Only 

gross alpha is reported from 1960–1966, with except for a WBC in one year. In 1967, 

gross alpha and beta are reported and a few people involved in accidents were monitored 

in the WB. In 1968, gross alpha and beta are reported, and in two instances, specific 

monitoring for actinides and Cf-252 and Am-241. In 1969, gross alpha, gross beta, and 

gamma urine counting are reported, plus one analysis of P-32 and C-14, and two WBC, 

one related to an incident. 

Tables 5.1, 5.2, and 5.4 describing in vitro bioassay programs, methods, and MDAs are 

incomplete and do not give enough information on internal dose calculations for LBNL 

employees. Table 5.8 is also incomplete and difficult to use, in relation to discrimination 

between exposures during the various periods of time and the rooms used in the installation. 

1.12 FINDING 12: FAILURE TO PROVIDE SUFFICIENT GUIDANCE FOR 

UNMONITORED WORKERS 

The TBD fails to provide guidance on how to calculate doses to workers without a complete 

description of the monitoring programs (Table 5.1), and on how to assign monitoring results to 

specific radionuclides and compounds. The TBD admits that, for many of the radionuclides, 

there is no specific information on the compounds with which they may have been associated. 

Insufficient guidance is provided on estimating internal doses for unmonitored workers. The 

information on bioassay programs is incomplete, as well as the list of radionuclides and 
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compounds handled at the facility during the different time periods and in different locations. 

The TBD suggests that unmonitored workers should be assessed using coworker data and the 

tolerance levels, if there is evidence that they worked with uncontained radioactive materials; 

otherwise, environmental data should be used. This suggestion cannot be followed using the 

information available in the TBD. 

NIOSH should revise the site profile document to provide information sufficient for proper dose 

reconstruction, particularly for unmonitored workers. 

1.13 FINDING 13: INADEQUATE COVERAGE OF OCCUPATIONAL 

ENVIRONMENTAL DOSE 

Section 4.0 of ORAUT-TKBS-0049, Occupation Environmental Dose, is incomplete and should 

be revised to provide a more comprehensive description of the historical environmental dose to 

workers at LBNL. The deficiencies and omissions are such that inadequate guidance is provided 

for dose reconstructors. 

NIOSH uses the data reported from the site environmental reports for the years they are available 

(1959–2004) to generate Table 4-1 providing the external gamma and neutron doses for the site 

for the operational years. For 2 years, 2002 and 2004, the data were reported as “not detected,” 

and NIOSH provided estimates by averaging the five previous years’ results. In addition, no 

reports were available for the years 1942 through 1958. NIOSH used a parabolic curve method 

to estimate the gamma and neutron doses for these years. Both of the estimating methods seem 

appropriate and claimant favorable, given the time periods, rate of growth of the exposure 

sources, and the resulting estimates comparison. 

NIOSH assumes that the gamma and neutron environmental exposure is primarily from 

accelerators and thus using the maximum measured value from the onsite and fence-line 

monitors for a given year would be claimant favorable. NIOSH fails to discuss the possible 

exposure of unmonitored workers from irradiators. In particular, the Co-60 irradiator housed in 

Building 74 may have been capable of higher doses at locations at distances less than those to the 

site perimeter or onsite monitoring locations (LBNL 1995a). 

Table 4-2, “Maximum site-wide annual median intakes (Bq/yr) via inhalation,” contains the 

NIOSH best estimates of annual intakes. Except for tritium and C-14, the values in the table are 

based on gross alpha and beta measured values from the site environmental program. The site 

profile states the following: 

LBNL attributes gross alpha results to 232Th and gross beta results to 90Sr for the 

purposes of dose calculation; these assumptions should be made. 

The LBNL 1994 Environmental Report (LLNL 1995a) states the following: 

Throughout this report, unidentified radionuclides are assumed to be 232Th if they 

are alpha-emitting material or 90Sr if they are beta emitting material. This is a 
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conservative approach because these assigned radionuclides represent the most 

restrictive alpha and beta emitters listed in DOE Order 5400.5. 

While this may be a conservative assumption relative to the effective dose equivalent (EDE), this 

may not be claimant favorable for specific organ doses. For example, for exposure to I-131, 

where the committed dose equivalent per unit intake for the thyroid is almost two orders of 

magnitude greater than for Sr-90, the dose to the thyroid would be grossly underestimated. 

Given the wide range of radioisotopes used at LBNL, NIOSH should present a more claimantfavorable approach to dose reconstruction for radionuclides whose intakes were determined from 

gross alpha and beta measurements. 
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2.0 INTRODUCTION AND SCOPE 

2.1 INTRODUCTION 

This report provides the results of an independent review of Lawrence Berkeley National 

Laboratory (LBNL) technical basis document (TBD) conducted by S. Cohen and Associates 

(SC&A). The TBD reviewed makes up the site profile developed by the National Institute for 

Occupational Safety and Health (NIOSH) for the LBNL site. This review was conducted during 

the period January 2009–October 2009, in support of the Advisory Board on Radiation and 

Worker Health (Advisory Board) in its statutory responsibility under the Energy Employees 

Occupational Illness Compensation Program Act of 2000 (EEOICPA). This authority includes 

the conduct of such reviews and advising the Secretary of Health and Human Services (HHS) on 

the “completeness and adequacy” of the EEOICPA program. 

LBNL was founded in 1931 on the University of California – Berkeley (UCB) campus by Ernest 

O. Lawrence. It was originally known as the University of California Radiation Laboratory. 

Throughout its history, LBNL has been operated by the University of California for the 

Department of Energy (DOE) and its predecessor, the Atomic Energy Commission (AEC). In 

July 1945, LBNL moved from the Berkeley campus to a 134-acre site in the hills to the east. 

LBNL began defense work in 1941, when the National Defense Research Committee appointed 

Dr. Lawrence to study the potential military uses of U-235. LBNL is alternatively referred to in 

reference documents as Berkeley Lab, Lawrence Radiation Laboratory (LRL), and Lawrence 

Radiation Laboratory, Berkeley (LRL-B). 

Figure 1. Lawrence Berkeley National Laboratory 
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Under the direction of Dr. Lawrence, the first operating cyclotron was developed and, over the 

years, larger and more powerful particle accelerators were constructed to study basic atomic 

structure. The Laboratory also conducted basic radionuclide and biological studies. 

LBNL originated in 1931 as an accelerator laboratory with the construction of a 27-inch 

cyclotron on the University of California-Berkeley (UCB) campus. In 1940, it was relocated to 

its present site. The first major facility was the 184-inch Synchrocyclotron. During the 1940s, 

LBNL experienced rapid growth due to national defense needs and several temporary wooden 

buildings were constructed. From 1948 until 1972, LBNL was known as Lawrence Radiation 

Laboratory and was funded by the AEC. Beginning in the 1950s, facility layout was better 

planned and permanent concrete and steel structures were constructed. In 1972, the name was 

changed to Lawrence Berkeley Laboratory. In 1995, the name was changed to Lawrence 

Berkeley National Laboratory (LBNL). LBNL has developed and operates a number of 

experimental facilities, including three large accelerators, several small accelerators, and 

radiochemical laboratories, of which the Human Genome Center, National Tritium Labeling 

Facility, and National Center for Electron Microscopy are a part. The future use of the facility is 

expected to be similar to its past and current use for energy-related research. 

In performing this research, many types of chemicals, some radioactive and some hazardous, 

have been used in the operations at these facilities, or have been produced as waste from these 

facilities. 

2.2 REVIEW APPROACH 

Under the EEOICPA and Federal regulations defined in Title 42, Part 82, Methods for Radiation 

Dose Reconstruction Under the Energy Employees Occupational Illness Compensation 

Program, of the Code of Federal Regulations (42 CFR 82), the Advisory Board is mandated to 

conduct an independent review of the methods and procedures used by NIOSH and its 

contractors for dose reconstruction. As a contractor to the Advisory Board, SC&A has been 

charged under Task 1 to support the Advisory Board in this effort by independently evaluating a 

select number of site profiles that correspond to specific facilities at which energy employees 

worked and were exposed to ionizing radiation. 

This report provides a review of the TBD related to historical occupational exposures at LBNL, 

ORAUT-TKBS-0049, Site Profile for the Lawrence Berkeley National Laboratory, Rev. 01 

(ORAUT 2007). A complete list of documents reviewed for this audit, including the TBD, is 

provided in Attachment 1. 

SC&A, in support of the Advisory Board, has critically evaluated the LBNL TBD for the 

following: 

• Determine the completeness of the information gathered by NIOSH in behalf of the site 

profile, with a view to assessing its adequacy and accuracy in supporting individual dose 

reconstructions

• Evaluate the adequacy of NIOSH’s presentation of existing information in the TBD

• Assess the technical merit of the data/information
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• Assess NIOSH’s use of the data in dose reconstructions

SC&A’s review of the TBD focuses on the quality and completeness of the data that characterize 

the facility and its operations, and the use of these data in dose reconstruction. The review was 

conducted in accordance with SC&A Standard Operating Procedure for Performing Site Profile 

Reviews (SC&A 2004), which was approved by the Advisory Board. 

The review is directed at “sampling” the site profile analyses and data for validation purposes. 

The review does not provide a rigorous quality control process, whereby actual analyses and 

calculations are duplicated or verified. The scope and depth of the review are focused on aspects 

or parameters of the site profile that would be particularly influential in deriving dose 

reconstructions, bridging uncertainties, or correcting technical inaccuracies. 

The TBD serves as a site-specific guidance document used in support of dose reconstructions. 

This site profile provides the health physicists who conduct dose reconstructions on behalf of 

NIOSH with consistent general information and specifications to support their individual dose 

reconstructions. This report was prepared by SC&A to provide the Advisory Board with an 

evaluation of the degree to which the TBD can support dose reconstruction decisions. The 

criteria for evaluation include whether the TBD provides a basis for scientifically supportable 

dose reconstructions in a manner that is adequate, complete, efficient, and claimant favorable. 

Specifically, these criteria were viewed from the position of whether dose reconstructions based 

on the TBD would provide for robust compensation decisions. 

 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and determine the level of exposure a worker received in that 

environment through time. In accordance with the requirements of 42 CFR Part 82, the 

hierarchy of data used for developing dose reconstruction methodologies is dosimeter readings 

and bioassay data, co-worker data and workplace monitoring data, and process description 

information or source-term data, respectively. 

2.3 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board, this report is organized into 

the following sections: 

(1) Executive Summary 

(2) Introduction and Scope 

(3) Assessment Criteria and Method 

(4) Site Profile Strengths 

(5) Vertical Issues 

(6) Overall Adequacy of the LBNL Site Profile as a Basis for Dose Reconstruction 

Based on the issues raised in each of these sections, SC&A prepared a list of findings, which is 

found in the Executive Summary and in Section 4.0. Issues are designated as findings if SC&A 

believes that they represent deficiencies in the TBD that need to be corrected, and which have 
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the potential to have a material impact on at least some dose reconstructions. Issues can also be 

designated as secondary issues if they simply raise questions, which, if addressed, would further 

improve the TBD and may possibly reveal deficiencies that will need to be addressed in future 

revisions of the TBD. Eight secondary issues were identified in the LBNL site profile, and they 

are discussed in Section 4.0. 

Many of the issues that surfaced in the report correspond to more than one of the major 

objectives (i.e., strengths, completeness of data, technical accuracy, consistency among site 

profiles, and regulatory compliance). Section 6.0 provides a list of the issues in summary form, 

and to which objective the particular issue applies. 

In some ways, the TBD was successful in addressing a series of technical challenges. In many 

areas, the TBD exhibits shortcomings that could potentially influence some dose reconstructions 

in a substantial manner.
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3.0 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profile that is used in the 

individual dose reconstruction process. These documents are reviewed for their completeness, 

technical accuracy, adequacy of data, consistency with other site profiles, and compliance with 

the stated objectives, as defined in SC&A Standard Operating Procedure for Performing Site 

Profile Reviews (SC&A 2004). This review is specific to the LBNL Site Profile, supporting 

technical information bulletins (TIBs), and dose reconstruction workbooks; however, items 

identified in this report may be applied to other facilities, especially facilities with similar source 

terms and exposure conditions. The review identifies a number of issues and discusses the 

degree to which the site profile fulfills the review objectives delineated in SC&A’s site profile 

review procedure. 

3.1 OBJECTIVES 

SC&A reviewed the site profile with respect to the degree to which technically sound judgments 

or assumptions are employed. In addition, the review evaluates assumptions by NIOSH as to the 

degree that they are claimant favorable. 

3.1.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The two elements examined under this objective include (1) determining if the site 

profile made use of available data considered relevant and significant to the dose reconstruction, 

and (2) investigating whether other relevant/significant sources are available, but were not used 

in the development of the site profile. For example, if data are available in site technical reports 

or other available site documents for particular processes, and if the TBD has not taken into 

consideration these data where it should have, this would constitute a completeness-of-data issue. 

The Oak Ridge Associated Universities Team (ORAUT) site profile document database, 

including the referenced sources in the TBD, was evaluated to determine the relevance of the 

data collected by NIOSH to the development of the site profile. Additionally, SC&A evaluated 

records publicly available relating to LBNL and information provided by site experts during the 

onsite visit. 

3.1.2 Objective 2: Technical Accuracy 

SC&A reviewed the site profile with respect to Objective 2, which requires SC&A to perform a 

critical assessment of the methods used in the site profile to develop technically defensible 

guidance or instruction, including evaluating field characterization data, source term data, 

technical reports, standards and guidance documents, and literature related to processes that 

occurred at LBNL. The goal of this objective is to first analyze the data according to sound 

scientific principles, and then to evaluate this information in the context of compensation. If, for 

example, SC&A found that the technical approach used by NIOSH was not scientifically sound 

or claimant favorable, this would constitute a technical accuracy issue. 
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3.1.3 Objective 3: Adequacy of Data 

SC&A reviewed the site profile with respect to Objective 3, which requires SC&A to determine 

whether the data and guidance presented in the site profile are sufficiently detailed and complete 

to conduct dose reconstruction, and whether a defensible approach has been developed in the 

absence of data. In addition, this objective requires SC&A to assess the credibility of the data 

used for dose reconstruction. The adequacy of the data identifies gaps in the facility data that 

may influence the outcome of the dose reconstruction process. For example, if a site did not 

monitor all workers exposed to neutrons who should have been monitored, this would be 

considered a gap and, thus, an inadequacy in the data. 

3.1.4 Objective 4: Consistency among Site Profiles 

SC&A reviewed the site profile with respect to Objective 4, which requires SC&A to identify 

common elements within site profiles completed or reviewed to date, as appropriate. In order to 

accomplish this objective, the LBNL was compared with the Argonne National Laboratory-East 

(ANL-E) and Pinellas Plant site profiles. In particular, this dealt with how each site handled and 

is handling dose reconstruction for workers exposed to a wide range of radionuclides. 

3.1.5 Objective 5: Regulatory Compliance 

SC&A reviewed the site profile with respect to Objective 5, which requires SC&A to evaluate 

the degree to which the site profile complies with stated policy and directives contained in 

42 CFR 82. In addition, SC&A evaluated the TBD for adherence to general quality assurance 

policies and procedures utilized for the performance of dose reconstructions. 

In order to place the above objectives into the proper context as they pertain to the site profile, it 

is important to briefly review key elements of the dose reconstruction process, as specified in 

42 CFR 82. Federal regulations specify that a dose reconstruction can be broadly placed into one 

of three discrete categories. These three categories differ greatly in terms of their dependence on 

and the completeness of available dose data, as well as on the accuracy/uncertainty of data. 

Category 1: Least challenged by any deficiencies in available dose/monitoring data are dose 

reconstructions for which even a partial assessment [or minimized dose(s)] corresponds to a 

probability of causation (POC) value in excess of 50%, and assures compensability to the 

claimant. Such partial/incomplete dose reconstructions with a POC greater than 50% may, in 

some cases, involve only a limited amount of external or internal data. In extreme cases, even a 

total absence of a positive measurement may suffice for an assigned organ dose that results in a 

POC greater than 50%. For this reason, dose reconstructions in behalf of this category may only 

be marginally affected by incomplete/missing data or uncertainty of the measurements. In fact, 

regulatory guidelines recommend the use of a partial/incomplete dose reconstruction, the 

minimization of dose, and the exclusion of uncertainty for reasons of process efficiency, as long 

as this limited effort produces a POC of greater than or equal to 50%. 

Category 2: A second category of dose reconstruction is defined by Federal guidance, which 

recommends the use of “worst-case” assumptions. The purpose of worst-case assumptions in 
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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. 

dose reconstruction is to derive maximal or highly improbable dose assignments. For example, a 

worst-case assumption may place a worker at a given work location 24 hours per day and 

365 days per year. The use of such maximized (or upper-bound) values, however, is limited to 

those instances where the resultant maximized doses yield POC values below 50%, which are 

not compensated. For this second category, the dose reconstructor needs only to ensure that all 

potential internal and external exposure pathways have been considered. 

The obvious benefit of worst-case assumptions and the use of maximized doses in dose 

reconstruction is efficiency. Efficiency is achieved by the fact that maximized doses avoid the 

need for precise data and eliminates consideration for the uncertainty of the dose. Lastly, the use 

of bounding values in dose reconstruction minimizes any controversy regarding the decision not 

to compensate a claim. 

Although simplistic in design, to satisfy this type of a dose reconstruction, the TBD must, at a 

minimum, provide information and data that clearly identify (1) all potential radionuclides, 

(2) all potential modes of exposure, and (3) upper limits for each contaminant and mode of 

exposure. Thus, for external exposures, maximum dose rates must be identified in time and 

space that correspond to a worker’s employment period, work locations, and job assignments. 

Similarly, in order to maximize internal exposures, the highest air concentrations and surface 

contaminations must be identified. 

Category 3: The most complex and challenging dose reconstructions consist of claims where 

the case cannot be dealt with by one of the two categories above. For instance, when a minimum 

dose estimate does not result in compensation, a next step is required to make a more complete 

estimate. Or when a worst-case dose estimate that has assumptions that may be physically 

implausible results in a POC greater than 50%, a more refined analysis is required. A more 

refined estimate may be required either to deny or to compensate. In such dose reconstructions, 

which may be represented as “reasonable,” NIOSH has committed to resolve uncertainties in 

favor of the claimant. According to 42 CFR 82, NIOSH interprets “reasonable estimates” of 

radiation dose to mean the following: 

... estimates calculated using a substantial basis of fact and the application of 

science-based, logical assumptions to supplement or interpret the factual basis. 

Claimants will in no case be harmed by any level of uncertainty involved in 

their claims, since assumptions applied by NIOSH will consistently give the 

benefit of the doubt to claimants. [Emphasis added.] 

In order to achieve the five objectives described above, SC&A reviewed the TBD and its 

supplemental attachments, giving due consideration to the three categories of dose 

reconstructions that the site profiles are intended to support. The LBNL TBD generally provided 

adequate information for the dose reconstructor when adequate data were available to do that 

comprehensively. Exceptions are noted in the findings in Section 4.0. 

• ORAUT-TKBS-0049, Site Profile for the Lawrence Berkeley National Laboratory, 

Rev. 01 (ORAUT 2007), contains an Introduction that explains the purpose and the scope 

of the site profile. In addition, five other topics related to potential site radiological 
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exposure are contained in this one site profile document. In most of the site profiles 

developed by NIOSH for DOE sites, these six distinct areas are contained in six 

individual documents. During the course of its review, SC&A was cognizant of the fact 

that the site profile is not required by the EEOICPA or by 42 CFR 82, which implements 

the statute. Site profiles were developed by NIOSH as a resource to the dose 

reconstructors for identifying site-specific practices, parameter values, and factors that 

are relevant to dose reconstruction. SC&A understands that site profiles are living 

documents that are revised, refined, and supplemented with TIBs, as required, to assist 

dose reconstructors. Site profiles are not intended to be prescriptive or necessarily 

complete in terms of addressing every possible issue that may be relevant to a given dose 

reconstruction. The introduction in the single document helps in framing the scope of the 

site profile. As will be discussed later in this report, the “Purpose” (Section 1.1) and 

“Scope” (Section 1.2) sections are unusually brief and lack sufficient information to serve 

any useful purpose. The same applies for the “Site Description” (Section 2.0). 

Section 3.0, “Occupational Medical Dose,” provides an overview of the sources, types of 

exposure, and the frequency of exams that workers potentially received. Section 4.0, 

“Occupational Environmental Dose,” provides background information and guidance to 

dose reconstructors for reconstructing the doses to unmonitored workers outside of the 

facilities at the site who may have been exposed to routine and episodic airborne 

emissions from these facilities. 

 

Section 5.0, “Occupational Internal Dose,” presents background information and 

guidance to dose reconstructors for deriving occupational internal doses to workers. 

Section 6.0, “Occupational External Dose,” contains background information and 

guidance to dose reconstructors for deriving occupational external doses to workers. 

 

After the Advisory Board and NIOSH have an opportunity to review this draft, SC&A plans to 

meet with the work group appointed by the Advisory Board and NIOSH to discuss our findings. 

Following these meetings, the draft may be revised, depending on direction we receive from the 

Advisory Board. We anticipate that, in accordance with the procedures followed during previous 

site profile reviews, the draft report and any subsequent revisions will be published on the 

NIOSH Web site. This last step in the review cycle completes SC&A’s role in the review 

process, unless the Advisory Board requests SC&A to participate in additional discussions 

regarding the closeout of issues, or if NIOSH issues revisions to the TBD or additional TIBs, and 

the Advisory Board requests SC&A to review these documents. 

Finally, it is important to note that SC&A’s review of the TBD is not exhaustive. This document 

deals with a complex site and many documents, and SC&A used its judgment in selecting those 

issues that we believe are important with respect to dose reconstruction. 

3.2 SITE PROFILE STRENGTHS 

In developing a TBD, the assumptions used must be fair, consistent, and scientifically robust, 

and uncertainties and inadequacies in source data must be explicitly addressed. The 

development of the TBD must also consider efficiency in the process of analyzing individual 
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exposure histories, so that claims can be processed in a timely manner. With this perspective in 

mind, we identified a number of strengths in the LBNL TBD. These strengths are described in 

the following sections. 

(1) The method used in Section 4.0, “Occupational Environmental Dose,” for projecting 

environmental doses for the early years (prior to 1959) is consistent with the site 

development and appears to be both claimant favorable and plausible. The site profile 

fits the available data to a parabolic curve, which more nearly estimates the growth of site 

exposure sources than would a linear projection. The parabolic fit begins with a 

background value in 1942 and peaks with the value reported in 1959, the first year for 

which environmental data were available. The use of a linear growth would under-report 

doses in the late 1950s, and the use of the average dose from 1959 to 2004 would 

overestimate the doses in the 1940s. 

(2) The use of “Attribution and Annotations” in the site profile document as a means of 

identifying and illuminating conclusions and recommendations contained in the site 

profile is helpful to the review. However, additional information is required for many of 

the items, since they are conclusions drawn by the site profile contributors, but give 

minimal justification and verification so that the conclusions of the authors can be 

validated. 

(3) The level of information provided appears to be consistent with the supporting documents 

reviewed and the magnitude of the potential doses associated with LBNL operations. 

There are omissions in the TBD and additional information and considerations that 

should be included in revisions of the documents. These shortcomings are detailed in 

Section 4.0. 
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4.0 VERTICAL ISSUES 

SC&A has developed a list of key issues regarding the LBNL Site Profile. These issues relate to 

each of the five objectives defined in SC&A 2004. Some issues are related to a particular 

objective, while others cover several objectives. Many of the issues raised below are applicable 

to other Department of Energy (DOE) and Atomic Weapons Employer (AWE) sites, and should 

be considered in the preparation and revision of other site profiles. 

4.1 FINDING 1: INADEQUATE DOCUMENTATION OF HISTORICAL 

OPERATIONS AND SOURCES OF RADIOLOGICAL EXPOSURES 

This review found that the site profile provides an inadequate overview of LBNL historical 

operations and the primary radiological exposure sources and conditions. The document lacks 

sufficient detail and analysis to provide comprehensive guidance to dose reconstructors. The 

period covered is large, as it is for several of the other DOE sites; however, the TBD failed to 

fully address the exposure implications of radiation sources to the degree necessary to allow a 

comprehensive assignment of historical doses, including missed doses. 

 

The site profile document consists of one document that covers six areas; the Introduction, Site 

Description, Occupational Medical Dose, Occupational Environmental Dose, Occupational 

Internal Dose, and Occupational External Dose. SC&A’s review found that each of these 

sections was deficient in its presentation of the information available on the subject for LBNL. 

Site profiles for other DOE sites, whose historical operations are equally or less complex and 

diverse, are more complete and informative to their intended audience than ORAUT-TKBS0049. SC&A has made this determination through a review of historical records and interviews 

with site experts. 

Specific operations and facilities are not discussed in sufficient detail. A prime example of the 

lack of significant detail and information is the coverage of the National Tritium Labeling 

Facility (NTLF). This facility operated for more than 19 years before closing in 2001, due to 

lack of funding. This facility provided tritium-labeled compounds for biological and medical 

research. There was considerable concern within the Berkeley community over the offsite 

exposure from this facility during its latter years of operation, to the point that the community 

hired an independent consultant to evaluate the safety of the facility. The NTLF handled large 

quantities of tritium in a great variety of chemical forms, including organically bound tritium 

(OBT) compounds (see Finding 3). 

 

The site profile fails to discuss the accelerator program at LBNL. Since this is the major source 

of exposure to site workers, this represents a major exclusion. The site profile should discuss the 

historical development of accelerators at LBNL and provide a discussion of the various 

accelerators developed, and the potential for routine, unmonitored, and accidental exposure to 

workers from these sources.
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4.2 FINDING 2: INSUFFICIENT INFORMATION FOR INTERNAL DOSE 

RECONSTRUCTION, ESPECIALLY DURING THE EARLY YEARS 

There is insufficient information on bioassay monitoring before 1961, and the information on air 

sampling and building activities is not sufficient to calculate the workers’ dose due to internal 

exposures. Workers were potentially exposed to a diversity of radionuclides at LBNL, as shown 

in Table 2-1 of the TBD, which lists the radionuclides of concern by building. Table 2-1 is 

incomplete in relation to the periods of time and quantities of radionuclides that were handled in 

the different areas. In addition, Table 2-1 gives no references for the source of information 

included in the table. 

Table 2-2 lists the radionuclides that workers could have encountered in various areas and the 

maximum quantities that were present in some buildings, and occasionally, dates are indicated. 

However, many of the entries have no quantities specified. Table 5.8 in Section 5 lists the 

radionuclides and fractional activity by building, but the table is incomplete when compared to 

Tables 2-1 and 2-2 in terms of the buildings and radionuclides that were handled. 

Table 5-8 was derived for calendar years 2001–2004, based primarily on airborne release data 

reported under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs). No 

indication is given of the methodology used to convert air emissions to radionuclide inventory. 

Table 5-8 is of limited value because of its inability to relate exposures during the various 

periods of time to the 2001–2004 emissions. 

Table 5-4 lists minimum detectable activities (MDAs) for in-vitro measurements, but is 

incomplete with regard to the totality of radionuclides that were handled at LBNL. Many 

radionuclides are presented with specific MDAs for the period after 1995, but the method of 

analysis is not specified. In-vitro detection limits for many radionuclides are not specified or 

assumed equal to ANSI HPS N13.30 values (Fe, Na, Ra, Th, U). The information on MDAs on 

the various periods is incomplete, posing a problem with the calculation of missed doses. 

Potential missed dose associated with inadequate bioassay techniques is not mentioned in this 

TBD. Discussions on the adequacy of monitoring techniques are missing, and the methods of 

analysis for many radionuclides are not specified; thus, the quality of the measurement 

techniques cannot be evaluated. 

Gross alpha, beta, and gamma analyses are reported as being used for the entire site operation, 

including the present time. The TBD does not discuss the fact that many radionuclides present at 

LBNL would not have been detected by gross measurements, or at least detected with low 

recoveries and resulting high MDCs. In addition, the use of gross measurements results in an 

indeterminate MDC for a specific radionuclide. The potential missed dose associated with nonspecific bioassay techniques should be further investigated to determine the impact on internal 

dose calculations. The TBD fails to provide guidance to the dose reconstructor on how to deal 

with mixtures of alpha or beta emitters for bioassay techniques that may analyze for multiple 

radionuclides using gross measurements. 
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4.3 FINDING 3: SPECIAL FORMS OF TRITIUM AND PLUTONIUM NOT 

ADDRESSED BY NIOSH 

NIOSH fails to identify in the site profile that metal tritides and OBT are included in the 

materials used at the site. The site interviewees verified that tritium was used extensively at 

LBNL, in particular at the NTLF, Building 75. There is very little discussion about tritium 

exposures in the internal dose section (Section 5.0) of the site profile; however, during the 

interviews, it was stated several times by health physicists and another knowledgeable former 

worker that tritium at NTLF was the largest internal dose producer at the site after the opening of 

NTLF in 1979. It was also stated during the interviews that OBT and metal (at least uranium and 

titanium) tritides were handled at NTLF. Section 5.0 does not discuss specifically the frequency 

of bioassay sampling that was performed at NTLF, which is the most important parameter in 

performing adequate bioassay monitoring for tritium. 

The lack of coverage in the site profile for NTLF tritium-related doses is a major weakness in 

this profile, especially when all interviewees discussing the NTLF pointed to it as the largest 

internal dose contributor on the site during its operation. NIOSH should include a more 

comprehensive discussion of the types of materials processed in the NTLF and the methods it 

will use to perform dose reconstruction for any exposures to the various forms of tritium used at 

the facility. 

During the interviews, health physicists stated that it was possible that highly oxidized/high-fired 

forms of actinides were handled at the site. They stated that the most likely source of exposure 

to these forms would have been related to the production of sealed sources and targets that were 

made for use at LBNL and other national laboratories. A recent letter from the U.S. Department 

of Labor to claimants (dated February 22, 2008) has identified LBNL as one of the sites where 

NIOSH started using a new model for “Super S” (highly insoluble forms) plutonium in 

performing dose reconstructions. Therefore, it is possible that NIOSH is addressing this issue for 

plutonium exposures at LBNL; however, the site profile does not address high-fired forms of 

other actinides (thorium, uranium, etc.). NIOSH should update the site profile detailing how it 

will handle high-fired forms of actinides in dose reconstruction for this site. 

4.4 FINDING 4: BIOASSAY DATA COMPLETENESS AND ADEQUACY HAVE 

NOT BEEN VERIFIED 

During the site visit by SC&A, it was determined that the bioassay database does not contain all 

bioassay data for all workers. SC&A found bioassay data in old files during the records search, 

which LBNL dosimetry staff verified were not in the database; therefore, it appears the database 

may be incomplete. In addition, bioassay submittals were delinquent by at least 1 year in some 

file records. This delay could increase the minimum detectable doses significantly, especially 

for soluble and short effective half-life nuclides. 

 

In Tables 5-1 through 5-5 of the TBD, NIOSH listed many in-vitro and in-vivo bioassay 

methods, along with information on frequency of sampling. Given the great number of 

radionuclides that could have been involved with internal exposures at LBNL, it is apparent that 

many of these are short-lived relative to the bioassay frequency. An example for this is the 
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production and use of I-131, which has an approximately 8-day physical half-life. The in-vivo 

frequency for whole-body counts is shown as annual in Table 5-3. In-vivo counting for I-131 

should be done within a few weeks after the possible exposure, due to the short half-life; 

therefore, an annual whole-body count would not detect an intake that occurred several months 

before the count. There are several other short-lived nuclides that LBNL handled (e.g., Na-24 

with a half-life of 15 hours, In-112 with a half-life of 21 minutes, and Ba-127/CS-127 with a 

half-life of 6 hours, among others), which would not be detected in most cases by an annual 

bioassay in most cases. 

During the site records search, a list of personnel that were delinquent for turning in their 

required bioassay samples was found. Some of the samples were late by several months. 

NIOSH should determine if the late bioassay samples could diminish their usefulness for the 

purpose of reconstructing internal doses. 

During the site interviews, it appeared that work conducted at the Donner Laboratory and other 

laboratories at the Berkeley campus was not monitored and/or controlled as stringently as at 

other LBNL facilities. NIOSH should investigate the possibility that internal dose information 

(bioassay and air sampling data) for the work at these laboratories is adequate to reconstruct 

doses at these locations. 

4.5 FINDING 5: INSUFFICIENT JUSTIFICATION FOR SELECTION OF IREP 

ENERGY RANGE FRACTIONS FOR PHOTON EXPOSURES 

In Table 6-2 of the TBD, beta and photon doses are assigned to energy ranges according to the 

radioactive materials used in individual buildings at LBNL. For Buildings 51 and 71, entitled 

Cyclotrons and Accelerators, a single photon energy distribution is given, and 10% of the 

measured dose is assigned to the 30–250 keV range and 90% assigned to >250 keV. It appears 

that this photon energy distribution is being applied to the entire history of accelerator use at 

LBNL. It is questionable that this energy distribution is appropriate in all situations and 

timeframes. For example, technicians who handled targets, ion sources, and internal components 

of accelerators would have been exposed to a very different spectrum than those only exposed to 

radiation transmitted and degraded by several feet of concrete or metal shielding. In the early 

years, it is much more likely that technicians and others would be exposed to low-energy 

emitters shortly after a machine was powered off or even during operation. This was presumably 

less likely as energies and risks grew larger and commensurate standards and protective practices 

evolved. 

Regardless of the precise fraction that should be assigned, the choice of less than 100% to the 

30–250 keV category should only be made where there is supporting evidence. As it stands, the 

selection of a 10% fraction is not claimant favorable and not buttressed by the inclusion of 

supporting evidence. Although the other buildings have been assigned factors greater than 10% 

for the more claimant favorable 30–250 keV photon energy range, the fact that the accelerator 

buildings have been assigned a single low factor creates doubt on the validity of the factors and 

the process by which the factors were determined for the remainder of the site. NIOSH should 

provide justification other than, “...it was done in a manner similar to the LLNL and LANL 

facilities” for the assignment of the fractional factors in Table 6.2 of the TBD. 
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4.6 FINDING 6: INSUFFICIENCY OF NEUTRON DOSIMETRY TREATMENT 

4.6.1 NTA Film Energy Threshold Determination 

As has been the case in a number of site profiles prepared by NIOSH, there is an inconsistent 

approach to the energy cutoff for the NTA neutron dosimeter. Callout “c.” in Table 6.5 

references NIOSH 2002 as listing the NTA lower energy threshold at 500 keV, yet attribution 

number 47 discusses 800 keV as the threshold, and this is used as the basis for this TBD. Other 

sources list 1,000 keV as the threshold for NTA response. The assumption that NTA film 

responds down to 500 keV is not justified by the technical data and is not claimant favorable. 

This issue is especially important, as the field to which the individual was exposed is usually 

poorly characterized and the neutron weighting factors are large and variable over the range of 

0.1 to 2 MeV. 

4.6.2 Failure to Adjust Recorded Doses to Correct for Lack of Response of NTA and CR39 in the Intermediate and Thermal Neutron Energy Range 

Table 6.6 of the TBD, “Adjustments to Recorded Dose,” defines the corrections for photon and 

neutron dosimeters to adjust the measured quantity; however, no adjustment is indicated for the 

failure of NTA film to respond to intermediate energy neutrons. The priority should be to 

ascertain the neutron dose and then correct it for weighting factors, etc. As presented, a 

significant part of the spectrum is inappropriately monitored and uncorrected. 

There is virtually no discussion of the potential for neutron fields throughout this historical 

facility. Given that LBNL was a world leader in accelerator development, and given the leadingedge high energies developed by the machines, it is likely that there was the potential for 

unanticipated radiation fields and possible neutron exposures across a range of energies, 

especially in the early decades. Some discussion of this is called for in the TBD. 

The scale of the issue with regard to under-response of NTA to intermediate neutron energies is 

fully explored in the Los Alamos TBD. Although LANL and LBNL are quite different in terms 

of sources of neutrons, many of the same detection issues remain. One part of the LANL TBD 

expresses the issue well: 

...6.2.3.6 Workplace Neutron Dosimeter Response 

The AEC held a series of Personnel Neutron Dosimetry Workshops to address 

problems experienced by its sites concerning accurate measurement of neutron 

dose. The first workshop was held September 23 and 24, 1969 (Vallario, 

Hankins, and Unruh 1969) with the stated concern: “... for intermediate energy 

(i.e., > 0.4 eV to < 700 keV) ... neutron sources, NTA personnel neutron 

dosimeters cannot be effectively used. This leaves a gap in the personnel 

dosimetry program which at many installations may be quite serious.... 

There is a remarkable silence as to thermal or slow neutron exposure in the site profile 

document. Only one mention of slow neutrons is made in the site profile document and that one 

is only made in passing (bold added for emphasis): 
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...Dose reconstructors should use the electroscope results in a qualitative manner 

because no data were found on the calibration or energy response of these 

devices; they should use the film or TLD results to estimate the actual exposure or 

the electroscope reading if no corresponding dosimeter reading exists. The 

electroscope results include daily readings in tables captioned “dosimeter,” 

“slow neutron,” and “electroscope.” The three readings, which occurred on the 

same dates, were evidently used to measure exposure at the end of work shifts .... 

No other mention of slow or thermal neutrons is made. A search of the “O” drive revealed only 

a single document (referenced in the above paragraph) that mentioned slow or thermal neutrons. 

Clearly there was the potential for exposure to slow neutrons, as slow neutron electroscopes were 

in use in 1956 and readings were documented for several individuals. NIOSH should investigate 

the issue as part of a broader look at the intermediate and slow neutron exposure potential. If 

there was minimal opportunity for thermal neutron exposure, then the TBD should document this 

conclusion. 

It is unclear from the TBD how and when albedo TLD results were merged with CR-39 results. 

The gap in neutron response from above the cadmium cutoff to the lower energy threshold for 

CR-39 (also not mentioned, but assumed to be around 150 keV) is not discussed. NIOSH should 

evaluate the neutron program and determine how missed intermediate energy neutron dose 

should be determined for this period, as well as intermediate and thermal energy neutrons for the 

NTA and pre-NTA years. 

4.6.3 Selection of Minimum Detectable Dose for CR-39 Dosimeters 

Table 6-1 of the TBD shows that the MDL for CR-39 is 10 mrem, with no attribution provided. 

The Los Alamos TBD shows an MDL for CR-39 of 20 mrem. The current commercial service 

available from Landauer, Inc., also shows an MDL of 20 mrem. It is likely that the minimum 

detectable level for CR-39 is higher than 10 and more likely around 20 mrem. This number is 

important and it is likely to be amplified to take account of missed dose not only due to exposure 

below the detection limit, but also to estimate dose due to lower energy neutrons that would have 

been missed entirely, due to the inability of CR39 to detect lower energy neutrons. 

4.6.4 Use of Neutron-Gamma Ratios for Situations Where Neutron Data are Lacking: 

Seeming Inconsistency Between the Environmental and External Dose Sections 

Table 4.1 of the Environmental Occupational Dose section (Section 4.0) of the TBD contains 

estimates of annual environmental dose throughout the history of the facility. The values 

provided are totals of neutron and photon exposure. The following footnote describes the 

assumption as to the proportion of neutron and gamma: 

c. Energies are 30 to 250 keV for photons and 0.1 to 2 MeV for neutrons. 

Neutron component of dose is typically ≥70% of total.... 

However, Note c. in Table 6-6 of the External Dose section of the TBD states that the ratio of 

neutron-to-photon dose should be assumed to be 0.73: 
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c. The NTA dosimeter (1941 to 1969) exhibited a lower energy threshold of 

approximately 500 keV (NIOSH 2002). The photon dose was measured 

adequately and all LBNL neutron dose was accompanied by a significant photon 

dose. For neutron dose received before 1969, the dose should be adjusted by 

using a neutron-to-photon ratio. The neutron exposure was determined with a 

neutron-to-photon ratio of 0.73 ±2.1 .... The geometric mean was 0.73, and the 

geometric standard deviation was 2.1.... The assumed upper 95th percentile was 

assumed to be 2.47.... 

Thus, the Environmental Dose section utilizes a ≥70% factor and the External Dose section 

utilizes a 42% factor. This significant difference in the average site-wide neutron-to-photon ratio 

is surprising. It is possible that the environmental dose includes more sky shine and other 

factors. However, this issue needs to be addressed and the large difference explained. 

This section on the determination of missed and missing neutron exposure needs a thorough 

review. Both the source terms and the dosimeter response specifications need to be addressed. 

4.7 FINDING 7: FAILURE TO JUSTIFY THE SHALLOW DOSE-TO-DEEP DOSE 

ASSUMPTION 

The TBD provides guidance on the dose to be assigned in the “early” years (pre-1979) for which 

there is no record of beta exposure. The Occupational Dose section suggests the following 

(pg. 39): 

...There are no records of reporting beta exposure using film from before 1979. 

This is presumed to be because the radiation protection staff at the time felt that 

deep dose was controlling to meet regulatory limits (i.e., that the shallow dose 

could not exceed the deep dose by a high enough amount to come close to the 

higher regulatory limit). The radiation protection staff was aware of the need to 

monitor for nonpenetrating radiation and used a film badge containing filters 

(LRL 1958e). Inasmuch as the limit for WB (deep) dose was 5 rem/yr and for 

skin (shallow) dose was 15 rem/yr, it is reasonable to assume that the shallow 

dose could not exceed the deep dose by more than a factor of 3.... For cases 

where the shallow dose is important to reconstruction and is not reported, dose 

reconstructors should apply a factor of 3 to the WB dose to estimate the shallow 

dose... 

In the general case, the assumption of a factor of 3 for the ratio of shallow dose-to-deep dose is 

reasonable and claimant favorable. However, LBNL had a broad mandate and, as the site 

description states on page 8: 

From the 1950s to the present, the laboratory has maintained its status as a major 

international center for physics research and has diversified its research program 

into almost every realm of scientific investigation. 
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Table 2.1 of the LBNL TBD shows that for the year 1931, H-3, C-14, P-32, P-33, Sr-90, I-125, 

Th-232, and U-238 were handled in the Donner Laboratory. Likewise, in Buildings 55/56 in 

1964, H-3, C-14, F-18, P-32, I-131, Sr-90, Xe-127, Nb-95, Ru-103, Gd-153, Tl-201, I-123, I125, Sn-113, Tc-99m, Co-57, Cr-51, Nb-95, O-15, Cu-64, Ce-141, N-13, Sr-85, Sc-46, C-11, and 

Co-55 were used. There are many other examples in the table of a broad array of nuclides that 

were present at a given location. Unfortunately, in most cases, the site description does not 

provide sufficient detail as to the quantities, forms, and methods under which these materials 

were handled. What is known is that the levels of protection in the 1940s, 1950s, and 1960s 

were far from what would be considered good practice today. 

There is no mention of head and eye dose or non-uniform whole-body irradiation in the site 

profile. Typically, workers handling beta emitters and those performing maintenance inside 

accelerators can be exposed to significant non-uniform fields. Likewise, there is no mention in 

the TBD of potential skin and clothing contamination and resultant exposure. 

It is unclear from the TBD if workers were exposed to significant shallow dose with possibly 

little deep dose to be used as an indicator. Possible activities that may have been conducted 

include fume hood operations, maintenance of accelerators, ventilation and plumbing systems, 

waste disposal operations and spill cleanup. The lists of nuclides are extensive and include beta 

emitters, including some pure beta and low-energy x-ray emitters. For some personnel, the 3:1 

ratio may not be claimant favorable. NIOSH needs to identify the workers who could have 

received exposure from these beta or low-energy x-ray emitters, or provide an alternative method 

of estimating the shallow dose in a claimant-favorable manner. 

4.8 FINDING 8: UNCERTAINTY IN BETA-GAMMA DOSIMETER RESPONSE TO 

RADIATION TYPES AND ENERGIES 

4.8.1 The Use of Early Electroscope Data Needs Greater Definition 

Page 39 of The TBD Describes The Use Of Electroscope Data: 

... LBNL began operations using dosimeter and processing technical support 

provided by the Metallurgical Laboratory at the University of Chicago. After 

1952, LBNL operated its own fully functional personnel dosimetry program with 

in-house processing. Exposure data were recorded by film badges and 

thermoluminescent dosimeters (TLDs). Early exposure records also provided 

electroscope (or at times, electrometer or E was used) results, which 

supplemented the results measured by film. Dose reconstructors should use the 

electroscope results in a qualitative manner because no data were found on the 

calibration or energy response of these devices; they should use the film or TLD 

results to estimate the actual exposure or the electroscope reading if no 

corresponding dosimeter reading exists. The electroscope results include daily 

readings in tables captioned "dosimeter," "slow neutron," and "electroscope." 

The three readings, which occurred on the same dates, were evidently used to 

measure exposure at the end of work shifts .... There are data in worker records 

that show a comparison of the film dosimeter to electroscope records for the same 
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interval; the data are similar and correlate, but they are not identical. This is 

probably due to a combination of differences in energy dependence, calibration 

techniques, where the dosimeters were worn in relation to each other, exposure 

geometry, etc. 

A search of the “O” drive found that, anecdotally at least, there were significant problems with 

electroscopes. A study performed November 23, 1953, by Jim Bennett (Bennett 1953) showed 

that readings from the three electroscopes tested were widely divergent from the film that was 

exposed with them. Two gave a 10% response compared with the film and the third was off 

scale. No details are provided as to the energy of the gamma source used for the exposure. 

However, the memo provides a cautionary statement as to using electroscope data even in a 

qualitative manner. 

4.8.2 Dosimeter Response to Very High Energy Photons and Charged Particles 

LBNL was a pioneer in the development of high energy physics and in the search for exotic 

particles. The film and electroscopes in use in the early decades will likely not have been 

calibrated for energies above 1 or 2 MeV. NIOSH should evaluate the dosimetry and potential 

for exposure to radiation at energies above that commonly produced by radioisotopes. The 

detectors will have responded to some degree, but the correction factor size and sign are 

unknown and not mentioned in the TBD. The response of the detector element or film, for 

example, will depend greatly on the composition of the holder and filters. 

Among the questions that arise from the review for consideration by NIOSH include: 

What information is available as to fields of radiation surrounding the newly developed 

accelerators? Were there opportunities for individuals to be inadvertently (or intentionally) 

exposed to beams of high energy charged particles or photons? Was shielding sufficient to 

reduce effective energy levels to less than 1–2 MeV for practical purposes? Information needs to 

be provided by NIOSH relative to these questions. 

4.9 FINDING 9: X-RAY EXPOSURES ARE UNCERTAIN 

Table 3-1 of the TBD lists the entrance skin exposure (ESE) doses used for the PA chest exam. 

It states that until 1975, all dose estimates are defaulted as being what is provided in ORAUTOTIB-0006 (ORAUT 2005a). There is no information identified as being available on x-ray 

equipment that was used prior to 1975. Depending on how one views this information, there is 

no indication that this default is claimant favorable for the years 1942 through 1975. NIOSH 

needs to better describe what measures were taken to determine what types of equipment were 

used. For example: 

• Where did workers get exams between the years 1942–1975? 

• Were medical records available, and do they indicate if x-rays were taken? 

• Were workers sent to alternate locations for exams, and were those records researched? 

• Did NIOSH research address the potential use of photofluorography (PFGs) to screen 

workers up through 1960? 
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The TBD should be expanded in its discussion of the medical dose to address the issues indicated 

in the above questions in order to be considered complete. 

4.10 FINDING 10: UNCERTAINTY OF CALCULATING DOSES PRIOR TO 1961 

There is no information on how NIOSH is planning to reconstruct doses before 1961. 

In ORAUT-TKBS-0049 (ORAUT 2007): 

• Table 5-1 lists the in vitro types of bioassay, the periods, and the frequencies of 

monitoring. It does not contain any information that might be applicable to calculate 

doses for exposures before 1961. 

• Table 5-4 lists the MDA for various analysis results. The only pre-1961 information 

available is the MDA for gross alpha, and gross beta is for 1957–1961. 

• Table 5-8 contains only one reference to exposures before 1961. 

• Looking at the files for LBNL in NOCTS, 24 claimants received compensation. Those 

were probably the most exposed workers, and 18 of the 24 claimants started working 

before 1961. There is only one bioassay record before 1961; a uranium urinalysis done in 

1958. 

• Looking at the 99 claimant files for LBNL who did not receive compensation, 31 started 

working before 1961. There is only one bioassay record before 1961; a C-14 breath 

analysis performed after an incident in 1959. 

There is insufficient information related to bioassay monitoring before 1961 in the TBD. 

4.11 FINDING 11: INADEQUACY OF BIOASSAY ANALYSES PRESENTATION 

There was a diversity of radionuclides at LBNL. The Occupational Internal Dose section of 

ORAUT-TKBS-0049 specifies that, “from 1960 to 1996, both in vitro and in vivo monitoring 

records and associated interpretations exist.” In Table 5-4, MDAs are listed for gross alpha for 

the isotopes of thorium, plutonium, curium, actinium, and neptunium. The same method and 

MDA is listed for Cf-252 from 1965–1995. There is a remark specifying that, “method 

descriptions note that uranium, radium, and polonium are not detected by this method (Author 

unknown, no date).” The MDA for U is specified for 1961–1988. In this table, MDAs are also 

listed for gross beta, Sr/Y-90, Sr-89, Ba/La-140, Ce/Pr-144, and fission products. There is an 

MDA listed for S-35 for 1962–1992, and one for rare earths (primarily Pm-147) just for 1961. 

Table 5-5 specifies in-vivo detection limits for gamma-emitting radionuclides 50 keV–2 MeV 

(including thyroid counts for I-131, I-123), Be-7, Na-22/24, Mn-54, Ni-57/63, Fe-55/59, 

Co-57/58/60 and Zn-65 for 1960–1996. For the same period of time, MDA for gamma-emitting 

radionuclides <50 keV (e.g., I-125) are also specified. 

Table 5-8, “Radionuclides and fraction activity by facility,” is incomplete and difficult to use in 

relation to discrimination between exposures during the various periods of time the rooms were 

used in the installation. 
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• In NOCTS, the files of the 24 claimants from LBNL that received compensation show 

that 22 started working before 1969. No in-vivo monitoring was recorded in the period 

1960–1969. 

• Of the 99 claimants for LBNL in NOCTS who did not receive compensation, 59 started 

working before 1969. No in-vivo monitoring was recorded in the period 1960–1969. 

• A document referenced in ORAUT-TKBS-0049 entitled, “Individual Bioassay Reports 

for Employees Beginning Last Name with A – 1965–1990,” reports bioassay done from 

1960–1990. Only gross alpha is reported until 1968, and gross alpha, gross beta, and 

gamma are reported in 1969. The first WBC is reported in 1970. 

• The document SRDB 21986 referenced in ORAUT-TKBS-0049 titled, “Terminated 

Bioassay Results of Employees with Last Name Beginning with A, 1961–1983,” lists 

bioassay monitoring of 106 employees, with last name beginning with A and B. Only 

gross alpha is reported from 1960–1966, with one exception of a WB counting in 1965. 

In 1967, gross alpha and beta are reported and several people involved in accidents were 

monitored in the WB counter. In 1968, gross alpha and beta are reported, plus in two 

cases, specific monitoring for actinides for Cf-252 and Am-241. In 1969, gross alpha, 

gross beta, and gamma urine counting are reported, plus a limited number of specific 

radionuclide analyses and WBCs. 

From these four lists of bioassay results, it is possible to conclude that the bioassay monitoring 

relied largely on measurements of gross alpha until 1964, and from 1964–1967 on gross alpha, 

beta, and gamma. Table 5-4 from ORAUT-TKBS-0049 does not give the MDA for gamma invitro monitoring before 1969, although this kind of monitoring is reported. WBC results are 

reported after 1965 for all related to incidents. 

Tables 5-1, 5-2, and 5-4 describing in-vitro bioassay programs, methods, and MDAs are 

incomplete and do not give enough information on internal dose calculations for LBNL 

employees. Table 5-8 is also incomplete and difficult to use, in relation to discrimination 

between exposures during the various periods of time and the rooms used in the installation. 

4.12 FINDING 12: FAILURE TO PROVIDE SUFFICIENT GUIDANCE FOR 

UNMONITORED WORKERS 

The TBD fails to provide guidance on how to calculate doses to workers without a complete 

description of the monitoring programs (Table 5-1), and on how to assign monitoring results to 

specific radionuclides and compounds. The TBD admits that, for many of the radionuclides, 

there is no specific information on the compounds with which they may have been associated. 

Insufficient guidance is provided on estimating internal doses for unmonitored workers. The 

information on bioassay programs is incomplete, as well as the list of radionuclides and 

compounds handled at the facility, in the different times and locations. The TBD suggests that 

unmonitored workers should be assessed using coworker data and the tolerance levels, if there is 
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evidence that they worked with uncontained radioactive materials; otherwise, environmental data 

should be used. This suggestion cannot be followed using the information available in the TBD. 

NIOSH should revise the site profile document to provide information sufficient for proper dose 

reconstruction, particularly for unmonitored workers. 

4.13 FINDING 13: INADEQUATE COVERAGE OF OCCUPATIONAL 

ENVIRONMENTAL DOSE 

Section 4.0 of ORAUT-TKBS-0049, “Occupation Environmental Dose,” is incomplete and 

should be revised to provide a more comprehensive description of the historical environmental 

dose to workers at LBNL. The deficiencies and omissions are such that inadequate guidance is 

provided for dose reconstructors. 

NIOSH uses the data reported from the site environmental reports, for the years they are 

available (1959–2004), to generate Table 4-1 providing the external gamma and neutron doses 

for the site for the operational years. For 2 years, 2002 and 2004, the data were reported as “not 

detected,” and NIOSH provided estimates by averaging the 5 previous years’ results. In 

addition, no reports were available for the years 1942 through 1958. NIOSH used a parabolic 

curve method to estimate the gamma and neutron doses for these years. Both of the estimating 

methods seem appropriate, given the time periods, rate of growth of the exposure sources, and 

the resulting estimates comparison. 

NIOSH assumes that the gamma and neutron environmental exposure is primarily from 

accelerators, and thus using the maximum measured value from the onsite and fence-line 

monitors for a given year would be claimant favorable. NIOSH fails to discuss the possible 

exposure to unmonitored workers from irradiators. In particular, the Co-60 irradiator housed in 

Building 74 may have been capable of higher doses at locations at distances less than those to the 

site perimeter or onsite monitoring locations (LBNL 1995a). 

Table 4-2, “Maximum site-wide annual median intakes (Bq/yr) via inhalation,” contains the 

NIOSH best estimates of annual intakes. Except for tritium and C-14, the values in the table are 

based on gross alpha and beta measured values from the site environmental program. The site 

profile states: 

LBNL attributes gross alpha results to 232Th and gross beta results to 90Sr for the 

purposes of dose calculation; these assumptions should be made. 

The LBNL 1994 Environmental Report (LBNL 1995a) states: 

Throughout this report, unidentified radionuclides are assumed to be 232Th if they 

are alpha-emitting material or 90Sr if they are beta emitting material. This is a 

conservative approach because these assigned radionuclides represent the most 

restrictive alpha and beta emitters listed in DOE Order 5400.5 [DOE 1990]. 
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While this may be a conservative assumption relative to the effective dose equivalent, this may 

not be claimant favorable for specific organ doses. For example, for exposure to I-131, where 

the committed dose equivalent per unit intake for the thyroid is almost two orders of magnitude 

greater than for Sr-90, the dose to the thyroid would be grossly underestimated. Given the wide 

range of radioisotopes used at LBNL, NIOSH should present a more claimant-favorable 

approach to dose reconstruction for radionuclides whose intakes were determined from gross 

alpha and beta measurements. 

4.14 SECONDARY ISSUES 

In addition to the above findings, there were additional concerns with the TBD. While these 

secondary issues do not rise to the level of a finding, they should be addressed by NIOSH to 

achieve a comprehensive site profile document. 

Secondary Issue 1: The Site Profile does Not Address LBNL Staff Assigned to the Nevada 

Test Site or the Significance of Its Employees Working at Other DOE/AWE Sites 

During the site visit, a file was identified that contained data for an LRL-Nevada contingent 

assigned to the Nevada Test Site. One of the accelerator scientists interviewed stated he had 

worked at several other national accelerator sites (Fermi Lab, SLAC National Accelerator Site, 

etc.) while employed at LBNL and never received dose reports from those sites. NIOSH should 

determine if all DOE/AWE dosimetry data for each LBNL employee that worked at other sites 

can be retrieved and merged into the dosimetry records used by dose reconstructors. 

Secondary Issue 2: More Information Needed for Internal Dose Assignment for ShortLived Radionuclides 

It is apparent from Table 2-1, “Area information and parameters,” that workers were exposed to 

short-lived nuclides and nuclides with little or no gamma emissions whose burdens from intakes 

would be difficult to detect with an annual WBC. For these radionuclides, very timely urine 

bioassay or representative air sampling would be needed if there was potential for intakes. 

NIOSH offers no guidance for assigning doses for these short-lived radionuclides. 

Secondary Issue 3: Lack of Discussion of Radiological Incidents 

There is no discussion on radiological incidents, although records of several accidents and spills 

were discovered during the site visit. These include the vaporization of a Cm-244 target, which 

went into the ventilation system at HILAC. It does appear that for major incidents, the exposure 

for the persons involved was documented in their personal exposure data. However, there is 

concern that for small incidents (such as a skin contamination events), the exposure for the 

workers involved would be recorded in their personal data file and not in their exposure folder. 

Secondary Issue 4: Need to Provide Information on Metallurgical Laboratory 

The TBD mentions the fact that the Metallurgical Laboratory at the University of Chicago 

provided dosimeter processing and technical support until 1952. Section 6 of the TBD states: 
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LBNL began operations using dosimeter and processing technical support 

provided by the Metallurgical Laboratory at the University of Chicago. After 

1952, LBNL operated its own fully functional personnel dosimetry program with 

in-house processing. 

No further mention is made of this in the site profile. NIOSH should provide information as to 

how the work was performed, calibration methods, and differences observed in measured 

exposures once LBNL began their own dosimetry operations. 

Secondary Issue 5: Lack of Information on Isotopes, Facilities, and Handling Methods 

A wide variety of activities were apparently conducted to discover and understand new elements 

and isotopes. As quoted in the Internal Dose section, Section 5 of the TBD: 

The Laboratory’s work was devoted to fundamental research on new elements, 

new isotopes, or properties of already known isotopes (Thaxter 1958). 

Other than a very broad list of the isotopes that were handled, there is no information as to the 

facilities and methods used for handling. For example, there is no information on shielding 

utilized, if remote handling tools were used, and the processes involved in the use of isotopes. In 

addition, some indication of specific activity, as well as overall activity, is needed to determine 

whether shallow and extremity dose issues arose. Given the large number of laboratories and 

isotopes handled, it is recognized that this is a complex task, but additional information and 

discussion in the TBD are needed. 

Secondary Issue 6: Extremity Dosimetry Needs Revisiting 

On page 40, the site profile describes the limited information available regarding extremity 

monitoring and notes the lack of mention of wrist badges: 

...There is limited information about the use of extremity dosimeters before 1982. 

It appears that X-ray film was used as finger rings; there is no reference to wrist 

dosimeters (as were used at LANL or Oak Ridge National Laboratory) ... 

There is some discussion of “palm film” use that appears in documents on the “O” drive. Two 

reports, Ref IDs 21503 (Unknown Author 1978) and 20881 (Unknown Author 1979), give palm 

film results for 1972–1979 and 1979, respectively. These reports were added to the database in 

January 2006, and should have been available during the period that the site profile was being 

prepared. NIOSH should revisit the extremity dosimetry issue and ascertain whether additional 

relevant information is available that was overlooked. 

Secondary Issue 7: Lack of Sufficient Information for External Dose Evaluation 

There is a litany of issues that are not addressed in the external dose review. The following list 

contains items that are needed in order to fully understand the capabilities of the dosimetry 

system. Many of these items are critical, as they determine whether or not particular radiations 
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and energies were even detected by the dosimeter. In addition, the dosimetry program 

underwent several changes over the course of time. The dates of these changes and the data for 

each period are needed. 

Dosimetry Program Specifics 

• Film emulsion type and wrapper specifications 

• Holder specifications 

• Angular response to various radiation types 

• Wear location on the body (including under or over protective clothing) 

• Calibration source, protocol 

• Processing methods for film, including methods for calibrating and controlling individual 

batches of processed film 

• Quality Control and Quality Assurance programs 

• Algorithm for each badge type, radiation type, and combinations of radiations 

• Method of handing control, blank, and background badges 

• Badge storage locations 

• Limit of detection (LOD) broken down for beta, x-ray, and gamma radiations 

• Chain of custody procedures 

• Handling of visitors and subcontractors 

Site Description 

• Maps and figures of the site, so that assumptions regarding source terms, for example, 

can be placed in context. 

• Design criteria and how they evolved over time. For example, what was the acceptable 

shielded dose rate in both continuously and occasionally occupied restricted and public 

spaces? 

• Surveys and typical dose rates for all facilities and timeframes across the site. 

Secondary Issue 8: Overuse of Generalizations and Assumptions 

There are a number of places in the TBD where broad site-wide and time-encompassing 

correction factors or energy group breakdowns are made. 

The shallow-to-deep dose, the selection of IREP photon energy fractions, and the neutron-togamma dose ratios are examples of this tendency to generalize across broad disciplines, radiation 

source terms, and timeframes. NIOSH needs to review all the situations where broad brush 
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factors such as these have been proposed and determine appropriate sub-divisions and break out 

specific factors based on location, timeframe, job function, etc. 

An example of a broad generalization is in Table 6-5, which includes the following paragraph 

regarding monitored/unmonitored individuals (bold added for emphasis): 

From review of LBNL documents, it is not clear if all employees were 

continuously monitored. However, the monitoring records appear to be complete. 

It can be assumed if no monitoring records are included in an employee's file 

that the individual was not monitored. 

This generalization is not reasonable nor claimant favorable. It suggests that over the last 

67 years, monitoring files have never been mislaid or lost at LBNL. In addition, it makes the 

sweeping assumption that chain of custody was always perfect and that, for example, a 

measurement was never inadvertently placed in a record for someone with a similar name or 

identification number. NIOSH should adjust instructions to ensure that dose reconstructors take 

due care to research the individual’s record in a variety of ways to ensure that sweeping 

assumptions are not used. 
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5.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for a “vertical” assessment of a site profile for purposes of evaluation 

of specific issues of adequacy and completeness, as well as a “horizontal” assessment pertaining 

to how the profile satisfies its intended purpose and scope. This section addresses the latter 

objective in a summary manner by evaluation of (1) how, and to what extent, the site profile 

satisfies the five objectives defined by the Advisory Board for ascertaining adequacy; (2) the 

usability of the site profile for its intended purpose, i.e., to provide a generalized technical 

resource for the dose reconstructor when individual dose records are unavailable; and (3) generic 

technical or policy issues that transcend any single site profile that need to be addressed by the 

Advisory Board and NIOSH. 

5.1 SATISFYING THE FIVE OBJECTIVES 

The SC&A review procedures, as approved by the Advisory Board, require that each site profile 

be evaluated against five measures of adequacy—completeness of data sources, technical 

accuracy, adequacy of data, site profile consistency, and regulatory compliance. The SC&A 

review found that the NIOSH site profile for LBNL falls short in fully characterizing a number 

of key underlying issues that are fundamental to guiding dose reconstruction. Section 6.0 

summarizes the key issues. Detailed evaluation of these issues is found in Section 4.0 of this 

report, “Vertical Issues.” 

5.1.1 Objective 1: Completeness of Data Sources 

The breadth of data sources used as a basis for the LBNL site profile is evident in the number of 

reports available in the Site Profile Research Database, as well as the number of reports cited in 

the site profile references. ORAUT’s use of the available sources indicates an understanding of 

site operations, radionuclide usage, and personnel monitoring data. However, as at most of the 

DOE sites, there is a lack of data for the early years of operation. 

In Table 2-1 of the TBD, radionuclides are identified by their usage in site buildings; however, 

no source term data are included. It is unclear from this table and site profile text the amount of 

the individual radionuclides and the usage parameters that would assist in evaluation of the 

exposure parameters for the nuclides. 

For time periods prior to 1959, there are virtually no data characterizing the external radiation 

fields outdoors. Procedures for estimating these missing data appear to be appropriately applied 

and claimant favorable; however, the degree to which these estimates conform to the actual 

radiation data is unknown. 

 

5.1.2 Objective 2: Technical Accuracy 

In general, the TBD for LBNL favorably reflects the depth of knowledge and technical 

understanding of the various authors and experts who developed the documents. The analyses 
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and recommendations are generally consistent with NIOSH guidance and the available data from 

the site. Some exceptions are noted below. 

 

The uncertainty in the values of the minimum decision levels or minimum detectable 

concentrations (MDC) for bioassay samples has not been adequately discussed in the LBNL site 

profile. This is exacerbated by the fact that a large number of radionuclides were present at the 

site and gross analyses were performed on the bioassay samples. This is a major concern, since 

the uncertainty associated with these parameters may have a significant impact on the estimate of 

missed dose. 

The lack of information or contradictory information on the radionuclides, compounds, and 

quantities that were handled, during different time periods, among the rooms and buildings are a 

concern to the technical accuracy of dose reconstruction. The lack of knowledge concerning the 

methods of analysis of specific radionuclides presents a significant uncertainty to the estimation 

of doses. The uncertainty in the values of the MDAs of many specific methods is problematic in 

terms of accuracy of the dose calculations and missed doses. In addition, for bioassay results 

relying on gross alpha, beta, and gamma analyses and the lack of information on chemical 

recovery for specific radionuclides, on the ability to detect radionuclides in bioassay samples, on 

interferences from other radionuclides, and on the chemical solubility contribute to the 

uncertainty of dose reconstruction. 

5.1.3 Objective 3: Adequacy of Data 

On the whole, the TBD addresses the data necessary for assignment of occupational dose, 

including missed and unmonitored dose, for LBNL. However, the presentation and discussion of 

the data are not adequate to calculate internal doses, and are not always addressed in a succinct 

and easily understandable manner. 

5.1.4 Objective 4: Consistency among Site Profiles 

SC&A compared and contrasted the methodologies to determine external, internal, medical, and 

environmental dose used in the LBNL Site Profile with other site profiles reviewed to date. 

These comparisons focused on the methodologies and assumptions associated with dose 

assessments and the derivation of values used to obtain a POC for individual claimants. 

Specifically, we compared the LBNL Site Profile to those for ANL-E and the Pinellas Plant. 

SC&A found a consistent application of NIOSH guidance and claimant-favorable assumptions at 

the sites, but found the LBNL site profile deficient in its presentation of the material necessary to 

verify the approaches taken. 

5.1.5 Objective 5: Regulatory Compliance 

SC&A reviewed the site profile with respect to Objective 5, which requires SC&A to evaluate 

the degree to which the site profile complies with stated policy and directives contained in 

42 CFR 82. In addition, SC&A evaluated the TBD for adherence to general quality assurance 

policies and procedures utilized for the performance of dose reconstructions. Section 6 addresses 

this topic.
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6.0 USABILITY OF SITE PROFILE FOR INTENDED PURPOSE 

SC&A has identified seven criteria that reflect the intent of the EEOICPA and the regulatory 

requirements of 42 CFR 82 for dose reconstruction. Because the purpose of a site profile is to 

support the dose reconstruction process, it is critical that the site profile assumptions, analytic 

approaches, and procedural directions be clear, accurate, complete, and defensible. SC&A used 

the following seven objectives to guide its review of the LBNL Site Profile TBD to determine 

whether it meets these criteria: 

Objective 1 − Determine the degree to which procedures support a process that is expeditious 

and timely for dose reconstruction. 

Objective 2 − Determine whether procedures provide adequate guidance to be efficient in select 

instances where a more detailed approach to dose reconstruction would not affect the outcome. 

Objective 3 − Assess the extent to which procedures account for all potential exposures, and 

ensure that resultant doses are complete and are based on adequate data. 

Objective 4 − Assess procedures for providing a consistent approach to dose reconstruction, 

regardless of claimants’ exposures by time and employment location. 

Objective 5 − Evaluate procedures with regard to fairness and the extent to which the claimant is 

given the benefit of the doubt when there are unknowns and uncertainties concerning radiation 

exposures. 

Objective 6 − Evaluate procedures for their approach to quantifying the uncertainty distribution 

of annual dose estimates that is consistent with and supports a DOL POC estimate at the upper 

99% confidence level. 

Objective 7 − Assess the scientific and technical quality of methods and guidance contained in 

procedures to ensure that they reflect the proper balance between current/consensus scientific 

methods and dose reconstruction efficiency. 

6.1 AMBIGUOUS DOSE RECONSTRUCTION DIRECTION 

It is not clear from the Internal Dosimetry TBD (ORAUT-TKBS-0049) how dose estimation 

would be performed for workers who were not classified as radiation workers and who had 

access to LBNL radiological operations. Guidance is provided in this TBD with respect to 

missed dose calculations for unmonitored workers; however, the guidance is not adequately 

justified. 

It is not clear from the Occupational Internal Dose section, Section 5 of the TBD, how dose 

estimation would be performed, with the incomplete, and many times contradictory, information 

that was given. 
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6.2 INCONSISTENCIES AND EDITORIAL ERRORS IN THE SITE PROFILES 

Table 4-1 of the site profile contains an error in the final “Dose” entry. The dose for 2004 should 

be 2.41 mrem/yr, as opposed to 0.28, as indicated in the table. 

Table 6-6 of the TBD contains erroneous citations (see Finding 6). 

• The Attribution erroneously refers to annotation/attribution [52]. The correct 

attribution/attribution is presumably [47]. The notes are shown below: 

[52] Thomas, Bill R. ORAU Team, Task 3. May 1, 2006. Mr. Thomas reviewed 

the results provided in the NOCTS database to identify the frequency that 

dosimeters were exchanged. Design and type of film was described in the 

Argonne East TBD (ORAUT, 2006). Mr. Joe Guido, ORAU Task 5, June 5, 2006 

confirmed that film badges were used through 1981 by reviewing claims in the 

NOCTS database. 

• The Attribution also erroneously refers to annotation/attribution [54]. Again, the correct 

annotation/attribution is presumably [47]: 

[54] Thomas, Bill R. ORAU Team, Task 3. May 1, 2006. Mr. Thomas reviewed 

the results provided in the NOCTS database to identify the frequency that 

dosimeters were exchanged. The MDL was equivalent to that of the LLNL and 

LANL programs. 

• Note c. describes the lower energy threshold as “approximately 500 keV (NIOSH 2002).” 

Yet annotation/attribution [47] says that the threshold is 800 keV. 

[47] Smith, Matthew H. ORAU Team. May 22, 2006. Mr. Smith and Mr. 

Thomas discussed the limited response of NTA film to neutrons with an energy 

below 800 keV. There were no documented studies of the poor response provided 

by LBNL. Mr. Smith suggested a response similar to that selected in the Hanford 

TBD (ORAUT, 2004) and information derived for the Rocky Flats Plant in OTIB0027 (ORAUT, 2005c). It was necessary to establish a neutron to photon ratio in 

order to modify the NTA dosimeter results. For operations handling transuranics 

including plutonium, the neutron to photon ratio was judged to be similar to 

Hanford plutonium operations with a geometric mean of 0.73, GSD 2.1, and 

upper 95% 2.47 (ORAUT, 2004). 

The Occupational Internal Dose section of ORAUT-TKBS-0049 specifies that “from 1960 to 

1996, both in vitro and in vivo monitoring records and associated interpretations exist.” 

However, Table 5-1, “In vitro Internal Dose Control Program,” only includes the years of 1961, 

1962, 1974, 1975, and 1995-present. 
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6.3 UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES 

A number of issues were identified that are common in the LBNL and other site profiles 

reviewed to date and, in some cases, represent potential generic policy issues that transcend any 

individual site profile. These issues may involve the interpretation of existing standards, how 

certain critical worker populations should be profiled for historic radiation exposure (e.g., 

construction workers and early workers), and how exposure itself should be analyzed (e.g., 

treatment of incidents and statistical treatment of dose distributions). NIOSH has indicated that 

it may develop separate TIBs in order to address these more generic issues. The following 

represents those issues identified in the LBNL and previous site profile reviews that, in SC&A’s 

view, represent transcendent issues that need to be considered by NIOSH as unresolved policy or 

generic technical issues. 

(1) Resolution is required on the availability of early records. 

(2) Direction on the applicability of the TBD to individual dose reconstructions is absent. 

(3) The method for dose assignment for alpha-emitting radionuclides, when only gross 

analyses were performed on bioassay samples, requires definition. 

(4) Statistical techniques used in the application of the data to individual workers should be 

further considered and substantiated. 

(5) The significance of various exposure pathways and the assumptions made that influence 

dose contributions need to be considered (most notably) for solubility and ingestion. 

(6) Analysis needs to be performed regarding how “frequent or routine incidents” should be 

addressed, given the possibility that such “spike” exposures may often be missed by 

routine monitoring as a function of how often and in what manner it was conducted. 

(7) Availability of monitoring records for “transient or outside workers,” e.g., subcontractors, 

construction workers, and visitors, who may have potential exposure while working on or 

visiting a facility should be ascertained. 

(8) Dose to contract decontamination and decommissioning (D&D) workers should be 

assessed. Many facilities have large-scale D&D operations, which extend back many 

years. Decontamination and decommissioning operations often require working in 

unknown situations, which may provide unique exposure situations. 

(9) Dose reconstruction for occupational medical exposures remains incomplete. NIOSH 

needs to reconsider the definition to include all forms of radiation medical exposure to 

ensure its considerations are claimant favorable.
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7.0 REFERENCES 

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program, of the Code of Federal Regulation.

Author unknown, no date, untitled document describing bioassay program. [SRDB Ref ID: 

21251]. 

Bennett, J., 1953. Memorandum on “Film Badge Testing,” Lawrence Berkeley Laboratory, 

Berkeley, California. December 2. 

DOE (U.S. Department of Energy) 1990 (amended 1993). Radiation Protection of the Public 

and the Environment, DOE Order 5400.5. 

LBL (Lawrence Berkeley Laboratory) 1965–1990, collection of employee bioassay records, 

University of California, Berkeley, California. [SRDB Ref ID: 21985, 21986]. 

LBNL (Lawrence Berkeley National Laboratory) 1995a. 1994 Site Environmental Report, LBL27170 (1995 rev.), University of California, Berkeley, California, May. [SRDB Ref ID: 6448]. 

LRL (Lawrence Radiation Laboratory), 1958e, "General Radiation Safety Practices (1957)," 

memorandum from Health Physics Department, UCRL, University of California, Berkeley, 

California, November. [SRDB Ref ID: 21745]. 

NIOSH (National Institute for Occupational Safety and Health), 2002. External Dose 

Reconstruction Implementation Guideline, OCAS-IG-001, Rev. 1, Office of Compensation 

Analysis and Support, Cincinnati, Ohio, August. 

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

Hanford Site – Occupational External Dosimetry, ORAUT-TKBS-0006-6, Rev. 01, Cincinnati, 

Ohio. January 9, 2004. 

ORAUT (Oak Ridge Associated Universities Team) 2005a. Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures, ORAUT-OTIB-0006, Rev. 03 PC-1. 

Cincinnati, Ohio. December 21, 2005. 

ORAUT (Oak Ridge Associated Universities Team) 2005c. Interpretation of Dosimetry Data 

for Assignment of Shallow Dose, ORAUT-OTIB-0017, Rev. 00. Cincinnati, Ohio. January 

11, 2005. 

ORAUT (Oak Ridge Associated Universities Team) 2007. Site Profile for the Lawrence 

Berkeley National Laboratory, ORAUT-TKBS-0049, Rev. 1. Cincinnati, Ohio. April 2, 2007. 

SC&A 2004. SC&A Standard Operating Procedure for Performing Site Profile Reviews, Rev. 0. 

S. Cohen & Associates, McLean, Virginia. March 18, 2004. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Thaxter, M. D., 1958. “Protection Factors for Respirators, Action Levels for Respirator Use,” 

Letter from M.D. Thaxter (LBNL) to D. Ross (U. S. Atomic Energy Commission), August 28. 

[SRDB Ref ID: 21995] 

Unknown author, 1978. Palm Film Folder Extremity Dosimeter Results by Name, Lawrence 

Berkeley National Laboratory, Berkeley, California. [SRDB Ref ID: 21503] 

Unknown author, 1979. Palm Film Report 1979, Lawrence Berkeley National Laboratory, 

Berkeley, California. [SRDB Ref ID: 20881]. 

Vallario, E.J., D.E. Hankins, and C.M. Unruh, 1969. AEC Workshop on Personnel Neutron 

Dosimetry, September 23 to 24, 1969, BNWL-1340, Battelle Memorial Institute, Pacific 

Northwest Laboratory, Richland, Washington. [SRDB Ref ID: 11096].
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ATTACHMENT 1: TECHNICAL DOCUMENTS 

CONSIDERED DURING THE REVIEW 

Technical Basis Document 

ORAUT-TKBS-0049, Site Profile for the Lawrence Berkeley National Laboratory, Rev. 01 

(ORAUT 2007) 

Technical Support Documents 

NIOSH (National Institute for Occupational Safety and Health) 2002. External Dose 

Reconstruction Implementation Guideline, OCAS-IG-001, Rev. 1, Office of Compensation 

Analysis and Support, Cincinnati, Ohio. 

ORAUT-OTIB-0002, Rev. 01 PC-2, 2004. Technical Information Bulletin, Maximum Internal 

Dose Estimates for Certain DOE Complex Claims, Oak Ridge Associated Universities, 

Cincinnati, Ohio. May 7, 2004. 

ORAUT-OTIB-0006, Rev. 03 PC-1, 2005. Dose Reconstruction from Occupationally Related 

Diagnostic X-Ray Procedures, Oak Ridge Associated Universities, Cincinnati, Ohio. December 

21. 

ORAUT-OTIB-0017, Rev. 00, 2005. Interpretation of Dosimetry Data for Assignment of 

Shallow Dose. Oak Ridge Associated Universities, Cincinnati, Ohio. January11. 

ORAUT-TKBS-0029-1, 2005. Technical Basis Document for Pinellas Plant – Introduction, 

Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0029-2, 2005. Technical Basis Document for Pinellas Plant – Site Description, 

Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0029-3, 2006. Technical Basis Document for Pinellas Plant – Occupational 

Medical Dose, Rev. 00 PC-1. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0029-4, 2005. Technical Basis Document for Pinellas Plant – Occupational 

Environmental Dose, Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0029-5, 2005. Technical Basis Document for Pinellas Plant – Occupational 

Internal Dose, Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0029-6, 2005. Technical Basis Document for Pinellas Plant – Occupational 

External Dosimetry, Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0036-1, 2005. Argonne National Laboratory - East – Introduction, Rev. 00. 

Oak Ridge Associated Universities, Cincinnati, Ohio. 
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ORAUT-TKBS-0036-2, 2006. Argonne National Laboratory – East – Site Description, Rev. 00 

PC-1. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0036-3, 2006. Argonne National Laboratory – East – Occupational Medical 

Dose, Rev. 01 PC-1. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0036-4, 2006. Argonne National Laboratory – East – Occupational 

Environmental Dose, Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0036-5, 2006. Argonne National Laboratory – East – Occupational Internal 

Dose, Rev 00. Oak Ridge Associated Universities, Cincinnati, Ohio. 

ORAUT-TKBS-0036-6, 2006. Argonne National Laboratory – East – Occupational External 

Dosimetry, Rev. 00. Oak Ridge Associated Universities, Cincinnati, Ohio.
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ATTACHMENT 2: MASTER INTERVIEW SUMMARY 

INTRODUCTION 

As a technical support contractor to the Advisory Board on Radiation and Worker Health 

(Advisory Board), SC&A has been tasked with reviewing NIOSH’s Lawrence Berkeley National 

Laboratory (LBNL) site profile. One component of SC&A’s review is a series of interviews 

with site experts, including current site workers, former site workers, and worker representatives. 

The purpose of these interviews was to hear first-hand accounts of past radiological control and 

personnel monitoring practices, and to better understand how operations and safety programs 

were implemented at the site over time. Interviewees were identified through available site 

reports, public meeting transcripts, local advocates, and other interviewees. This report 

summarizes the results of those interviews that were reviewed and accepted by the interviewees. 

A team of SC&A interviewers, William James, Kathryn Robertson-DeMers, and Abe Zeitoun, 

conducted interviews at LBNL in Berkeley, California, between May 11 and May 15, 2009. One 

participant was interviewed by telephone on July 31, 2009. A total of 31 site experts participated 

in these interviews. However, due to a limited response to SC&A’s request for participants’ 

review of interview summaries, only 14 interviewee statements are included in this master 

summary. 

The workers whose interviews are summarized below represent the time period from 1955 

through the present (2009). Their work took them to the Bevatron, HILAC, SuperHILAC, 

Advanced Light Source (ALS), National Tritium Labeling Facility (NTLF), accelerators, hot 

cells, medical facilities, Donner Laboratory, Calvin Laboratory, and other research labs on 

campus and on the hill. Interviewees participated in research, production, medical services, 

radiation protection, dosimetry, environmental monitoring, maintenance, and administrative 

activities. Some participants have assisted other workers with medical issues, claims, and/or 

petitions. The worker categories represented by the interviewees include the following: 

• Administrative Staff 

• Dosimetry 

• Environmental Protection 

• Health Physics/Radiation Protection 

• Industrial Hygiene 

• Laboratory Directors Office 

• Maintenance 

• Medical Services 

• Radiological Control and Monitoring Operations 

• Scientists/Physicists 

• X-ray Safety 

SC&A explained that the interviews were being conducted on behalf of the Advisory Board as 

part of their review of NIOSH’s LBNL site profile report. Participants were told that the 

interviews were unclassified, and that they should not disclose any classified information. 

Summaries from each interview set were prepared and provided to the interviewees for review. 
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Approximately 55% of participants did not respond to the request for review; the information 

obtained from interviews that were not validated by participants has been withheld from this 

master summary. 

The information provided by the workers and site experts is invaluable in helping SC&A to 

better understand the operations at the LBNL. This summary report is not a verbatim 

presentation of the material contained in the interview notes, nor is it a statement of SC&A 

findings or opinions. It is a consolidated summary of statements, opinions, observations, and 

comments that the interviewees communicated to SC&A. Its sole intent is to communicate to the 

Advisory Board and other interested parties information acquired by SC&A during these 

interviews. Comments are included in brackets where SC&A has provided clarification on a 

statement made by an interviewee. 

Information provided by the interviewees was based entirely on their personal experience at 

LBNL. It is recognized that the site experts’ recollections and statements may need to be further 

substantiated; however, they stand as critical operational feedback and reality reference checks. 

These interview summaries are provided in that context. Key issues raised by site experts are 

similarly reflected in our discussion, either directly or indirectly. Interviews from all workers 

who reviewed and approved their individual interview summaries have been consolidated into 

this single summary document. The information has been categorized into topical areas related 

to research and production operations, maintenance, dosimetry, radiological controls and 

monitoring, incidents and accidents, medical services, radiological records, environmental 

monitoring, and miscellaneous comments. Where conflicting observations and statements have 

been received, both perspectives have been retained in this summary report. 

With the preceding qualifications in mind, this summary has contributed to SC&A’s 

understanding of issues raised in the LBNL site profile. 

RESEARCH AND PRODUCTION OPERATIONS 

The interviewees, collectively, provided their characterization of radiation related work in 

various onsite facilities, as follows. 

The primary radiation areas were in Buildings 4, 5, 6, 7, 14, 16, 70, 70A, and 75. There are 

detectable radiation levels around the accelerators. Buildings 1, 3, and 4 (Actinide Chemistry) 

have radioactive materials. In the case of Building 4, the material is in the duct system and 

sewer lines. Areas that have or had radioactive material or radiation-producing devices include 

the Advanced Light Source (ALS), the 88” Cyclotron, the Laser Wakefield Facility (Building 

71), Medical Cyclotrons, radiographic testing x-ray equipment (Building 27), electron 

microscopes, and Van de Graaff accelerators (basement of Building 58 and Building 62). The 

hottest jobs onsite were target handling at the 88” Cyclotron, target handling at the 

184” Cyclotron, and the tritium facility. 

[There were several accelerator facilities at LBNL.] The Bevatron was used for physics 

experiments. It used sealed radioactive targets to avoid any radioactive contamination. The 

HILAC was a linear accelerator that beamed the lighter elements up to Ar. During [the 1970s], 
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there was a lot of development work with the Bevalac, including upgrades and modifications. 

The HILAC was renamed the SuperHILAC and was connected to the Bevatron [in the late 

1970s]. At that point, there was a beam line across the laboratory. The SuperHILAC had the 

ability to beam heavy ions up to uranium. The ALS was housed in Building 6. While the old 

accelerator was torn out, the walls that housed the old accelerator were not removed. 

Non-traditional forms of radiation [at LBNL] include protons, muons, and heavy ions. Heavy 

ions are used for intentional exposure of patients. There is some activation of components [at the 

accelerators], including W-181, Co-57, Na-22, Sc, Re, Os, etc. Airborne activation was removed 

from the accelerator via ventilation. 

The Electron Ring Accelerator (ERA) project was an experimental design for a quick, high 

energy accelerator. There were some experimental tests and theoretical analysis to demonstrate 

only slow acceleration. The program was not successful, because they showed that only slow 

(not “quick”) acceleration was possible. The peak energy was approximately 5 MeV. The 

maximum current was thousands of amps. The unit accelerated electrons with a pulse duration 

of nanoseconds and a pulse frequency of 1 Hertz. The running time was about 2–3 years (20%–

25% of the time). There were no radionuclides produced [in this project]. 

The laboratory was heavily involved in Research and Development work. Radionuclides used in 

research included pretty much everything in the periodic table in some amount. There were a 

number of projects that occurred, such as the production of medical isotopes, gram quantity 

production of uranium, and tritium labeling of compounds. Thorium was used sporadically, but 

primarily came along with other radioactive materials. Pu-238 and Pu-239 were handled at the 

HILAC to produce heavy elements, and by the Nuclear Physics group in Buildings 70 and 70A. 

There were μCi to mCi amounts of tritium, C-14, P-32, and other beta emitters used in medical 

research at LBNL and areas of campus. Originally, there was some plutonium in Buildings 4 

and 5. There was some U-233 stored in the pit room. LBNL used a lot of chemical forms of 

radionuclides (e.g., oxides) and may have had high-fired oxides. Metal tritide targets were used 

at the 88” Cyclotron in the form of titanium tritide. They produced all types of accelerator 

targets and sources for LBNL and other facilities. Sealed sources were encapsulated. There is a 

small project with a radon generator. 

LBNL made many of the heavy elements. Some of these elements were used as target material 

at the LBNL accelerators. The researchers started with plutonium, americium, and curium as the 

main material in the capsule. At different times, capsules were irradiated for one or more years 

at the Idaho reactors. The [irradiated] capsules were transported down to Building 70 and put 

into the hot cells for the separation of the produced heavy elements. The hot cell operators 

worked outside the neutron/gamma shield that contained a ventilated enclosure where the 

separation chemistry was conducted. The first step in the chemistry was to dissolve the capsule. 

There was a dead-end system (evacuated gas bottles with activated carbon) used only during the 

capsule dissolution process. The next chemistry steps were centrifuging and column chemistry 

to separate the heavy elements. These steps were performed in the same hot cell enclosure. The 

separated products were given to the LBNL researchers for analysis. 

LBNL started out with a focus on cyclotrons for nuclear physics, but broadened into medical 

uses. The production of medical isotopes at LBNL started probably in the 1930s. The National 
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Academy of Science (NAS) did a study on production of medical isotopes, such as Tc-99m. The 

laboratory was involved in production and use of Positron Emission Tomography (PET) isotopes 

with short half-lives (e.g., F-18). The lab treated patients with neutron beams. There were some 

irradiations of patients with the cyclotron. They used radioactive isotopes to study biological 

and chemical interactions. LBNL Medical maintained a Human Use Committee that reviewed 

and approved the applications of radioisotopes with humans. 

There were LBNL radioactive laboratories on the University of California - Berkeley campus 

conducting research. The Old Radiation Lab building was decommissioned and demolished in 

the mid-1950s. [Radioactive work was also performed at] Donner Laboratory, Calvin 

Laboratory, and a few other individual labs in large campus buildings. The Donner Laboratory 

was located on campus in Building 1. Donner Laboratory housed a clinic where they treated 

polycythemia with P-32 and thyroid cancer with I-131. There was a whole-body counter at this 

facility. There was possibly some actinide chemistry and some americium contamination. The 

Calvin Laboratory was located on campus in Building 3. They worked with C-14. Tritium work 

was initially done in Building 3 (Calvin Laboratory). They made tritiated compounds for 

biochemical researchers. There was concern that this work was being done too close to a 

population center, so it was transferred to Building 75 on the hill. The work conducted here was 

primarily for Biomedical and Radiopharmaceutical companies. 

In Building 4 in the 1950s, researchers were trying to characterize the heavy elements (i.e., Am, 

Pu, Cm, etc.). There was a column separation to isolate the radionuclides. They were 

investigating the physical characteristics of the elements. 

There was a tunnel underneath Building 46. There were very large sealed black drums as far 

back as the interviewee could see. The interviewee did not see any markings on the drums; some 

of the lids were rusty. The interviewee asked a laborer why these drums were there. The laborer 

said he did not know, but they had been there as long as he could remember. The parking lot for 

the building was above the tunnel. Building 46 was not ventilated and did not have air 

conditioning. 

The National Tritium Labeling Facility (NTLF) was a source-making laboratory, which housed 

an analytical area, a pit room, an instrument repair and calibration shop, the dosimetry office, 

and other offices (not all at the same time, but over the years). Building 75 [NTLF] had a tritium 

tagging system. NTLF received various chemical compounds from inside and outside 

customers, and labeled these chemical compounds with tritium. Most of the tritium at the NTLF 

was organic material. They worked with curie-level tritium concentrations. The maximum 

tritium inventory at NTLF was 15,000–16,000 curies of tritium, which was stored in uranium 

beds. The uranium bed was heated to release the tritium into a vacuum tagging system. The 

tritium production area and the pit area had a separate ventilation system from other parts of the 

building. The tritium gas had to be converted to tritiated water to collect it on silica gel and 

dispose of it. The tritium diffused into the steel, which rusted. This was the only lab at LBNL 

that low-level radioactive contamination could be temporarily allowed. Organically Bound 

Tritium was handled at Donner Laboratory. 
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A study was done by the DOE, who came through and tested the laboratory for radon levels. 

LBNL has had no compromised Ra-226 sources. 

The focus on high-energy physics has ended as time has progressed. LBNL expanded into 

materials work with radioactive material, molecular biology, and photon research at the ALS, 

which is the main focus now. The lab continues to look at alternative energy sources and is 

moving away from nuclear work. There have also been efforts in computer science. 

MAINTENANCE 

The interviewees with maintenance experience, collectively, provided their characterization of 

their radiation related work in various onsite facilities, as follows. 

Many maintenance workers were assigned to specific areas, such as Buildings 51 and 71. 

Maintenance was available for specialty areas 24 hours per day, 7 days a week. There was also a 

regular dayshift crew. About 15 years ago, there was a consolidation effort, and maintenance 

migrated back to the Building 76 Central Shop. 

Different trades helped each other if they needed to get the job done. For example, plumbers 

were responsible for underground repair work and installation of piping, and above and below 

ground plumbing. Pipefitters were responsible for installing new piping systems (i.e., there was 

a fine line between Pipefitters and Plumbers). Carpenters were responsible for any work done 

with wood or metal. They would tear down and put up structures. Carpenters worked closely 

with Riggers. A Plant Maintenance technician was responsible for the building utilities—

ventilation, water, vacuum pumps, cryogenics, generators, heat exchangers, generators, air 

compressors and handlers, oxygen supply, and acid waste in some buildings (2, 70A, 76). 

Mondays were routine maintenance days. On an annual basis, the Bevatron was shut down for a 

couple of weeks [for maintenance]. At the 88” Cyclotron, the unit was shut down in the 

summertime. At the Bevatron, they did cancer research. When there was a patient on the table, 

maintenance workers did whatever they had to do to get the machine going. 

Maintenance workers entered unoccupied areas. They went in and around the ducting, 

ventilation system, all around the magnets, inside the shielding blocks, etc. A plumbing 

supervisor accessed every storm drain and sewage line onsite. There were numerous sewer 

problems with solvents and oils. One interviewee has been in the pit room, a pit area down 

beneath the Motor Generator (MG) room in Building 51. This was where the oil tanks for MG 

sets, resister banks, and sump pumps were located. In Building 71, there was something called 

the weeder row (a small tank with coils inside for particle acceleration). This area had lead 

shielding around it. 

RADIOLOGICAL CONTROLS 

The interviewees, collectively, provided their characterization of radiological control activities at 

LBNL, as follows. 
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Historically, the Radiological Control (RadCon) organization was divided into Health Chemistry 

and Health Physics. The Health Chemistry group was responsible for unsealed sources and 

contamination monitoring; they worked with the researchers that handled radioactive material in 

the field. They were responsible for minimizing external and internal exposures from radioactive 

materials by providing engineering controls, supporting operations, and surveillance services 

(e.g., air sampling, surface contamination monitoring, training, maintenance of protective 

equipment, etc.). The Health Physics group was responsible for the radiation-producing sources 

and machines, and for external dosimetry. They covered all of the penetrating radiation from 

machines, such as accelerators, x-ray devices, and neutron-generating machines. They also 

provided film badge services to the laboratory. The Medical Services Department operated the 

bioassay laboratory and whole-body counter for evaluation of internal exposures. 

In the 1950s, Radiation Monitors (RMs) in the Health Chemistry group performed all radiation 

protection-related tasks, working with the researchers, nuclear chemists, doctors, etc., who 

handled radioactive material. The RMs worked side by side with the researchers and were 

hands-on. They were always there when there was a pass out from a glovebox or for other 

operations that required extensive monitoring. The RM delivered all the radioisotopes to the 

researcher and characterized/packaged the radioactive waste. An HP Coordinator evaluated 

research projects for radiological hazards, wrote permits and procedures, identified bioassay 

requirements, and established engineering controls. The RM contacted the researchers, found 

out what plans they had, and communicated the information to the coordinator. The coordinator 

would come see what was happening in the field. Health Chemistry workers were also involved 

with waste disposal, ventilation for airborne material, and shielding design for the radioactive 

laboratory, hood, gloveboxes and hot cells (caves). 

The level of staffing depended on the director who was in charge and if they thought the 

scientists could do their own radiation protection. There were about 25 Radiation Monitors 

working throughout LBNL during the late 1950s and early 1960s. Coverage was provided 

24 hours per day, 7 days per week, when Building 70 first started. The monitors kept up with the 

level of research. Currently, there are 30 individuals in radiation protection. Environmental 

Health and Safety (EH&S) has 160 people supporting about 4,000 laboratory employees. 

Individuals understood the hazards of radiation and took care. People operated within the 

requirements of safety as defined by the safety staff. One interviewee noted that the largest 

interest at the laboratory was energy and research, rather than safety. The laboratory was not 

negligent about safety, but it was not as concerned with it. Historically, only 0.4% of the budget 

was devoted to safety. Larger amounts of materials were handled, and monitoring was not as 

strict. At some facilities, safety staff did not report to Health Physics/Health Chemistry. For 

example, at the Junior Cave (i.e., lead-lined gloveboxes), they used to hand-walk radioactive 

sources from the beams to the chemical separation area with tongs. There was a change at 

LBNL in the mid-1990s, motivated by the Tiger Team visit and later by the implementation of 

10 CFR 835. The full transition of the radiation protection culture took about 10 years. 

LBNL’s philosophy was to confine and control radioactive material, instead of dilute and 

disperse. Low-level airborne radioactive contamination was not allowed in work areas. Air 

sampling includes high volume air samples, lapel air sampling, and general air sampling. There 

is routine air monitoring, including lapel air sampling and DAC-hour tracking, at the Heavy 
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Elements Research Laboratory, Building 70A. [In the heavy element separation facility], there 

was air sampling in the room in the hot cell (cave) and on the stacks. Tritium monitoring was 

done at the NTLF with Femtotechs, which are ionization chambers. No particle size studies have 

been conducted. General air samples were also collected, tracked, and archived from all over the 

laboratory. Every room where there was a possibility of airborne contamination had air 

samplers. General area air sampling units were placed as closely to the breathing zone as 

possible. The samplers were placed in the air flow pattern of the room; sometimes there were 

multiple units in a room. An RM was assigned to a room or station [office]. The RM’s daily 

work included preparing technical smears and preparing the required information on the fixed 

and breathing zone filter paper air samplers. The RM would then exchange the air samples and 

take smears. If the air sample was elevated, the workers were required to submit a bioassay. 

Health Physics was aware of the radiological hazards at the lab. LBNL is fairly clean as a site. 

Frisking surveys were done to check the areas where the scientists were working. Any spills or 

contamination spreads were cleaned up right away. There has been some legacy contamination 

encountered during D&D [decontamination and decommissioning]. For legacy contamination, 

there is some isotopic characterization for Buildings 51 and 71. There have been 

reconnaissance-level characterizations to identify activation products in structures. Very small 

activity of fine Am-241 powder was discovered in ducting at Building 4 on one occasion. Due to 

the complexity and cost of ductwork removal (issues with transite, asbestos, radiological 

contamination, and difficulty sealing the area from the floor below), it was left in place until the 

building demolition. 

In the past, there was potential skyshine from Buildings 51, 71, and 88. This was particularly 

true when the accelerators had no shielding on the roof. 

Engineering Controls have improved by leaps and bounds. For example, major improvements 

have been made in interlock systems. The lab has employed key control and relay logic. The 

LBNL accelerators (the 184”, the 60” on campus, the HILAC and the 88”) had systems 

designated to remove radioactive targets and be transported to chemistry and counting labs for 

analysis. All radioactive internal transfers were made by EH&S Transportation group. 

At the ALS, they allowed immediate entry after beam shutdown. At the 88” Cyclotron, there 

was a delay period before entry. The length of the delay period depended on the types of targets 

used. There was no delay period after shutdown during patient treatments at the Bevatron, 

because the unit required immediate response. After an accelerator was shut down, a 

Radiological Control Technician would go and make radiation measurements. If there was a 

breech of the system of the 88” Cyclotron, Health Physics would do air sampling. Shielding was 

in place at accelerators. 

One of the more difficult isotopes to work with is Cf-252, having alpha, gamma, and neutron 

emissions. Special shielding for neutrons and gamma were designed into hot cells (caves) to 

handle the produced heavy elements, including Cf-252. 

Since 1948 to 1952, they started to develop gloveboxes. The original gloveboxes were wooden. 

EH&S had to do all the work in the case of design. They had a shop to build a glovebox. They 

had liners inside the glovebox, so they could be removed and replaced, so it could be used again. 
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They had to wipe the window. There were gloveboxes in Building 88. Maintenance workers 

repaired the gloves and cracked glass in this area. 

LBNL had some kind of [work] permits [from the 1960s]. The coordinator would fill out a form 

describing the job and the recommendations on what to do. In the 1980s, the program became 

more formal, and the laboratory implemented work permits. 

At various times, maintenance workers went to areas that were posted as contamination areas. 

Generally, Personal Protective Equipment (PPE) was not worn 25 years ago. In some cases, 

workers wore rubber gloves when working with chemicals, such as TCE and Freon R11. There 

was an improvement in this philosophy in the 1980s. PPE use was formalized in the 1990s after 

the Tiger Team came to LBNL. The Lead Standard and other standards came into being also. 

Plumbers wore Tyvec suits with an RM observing and monitoring the job. LBNL became more 

cautious as time went on, and new postings went up all of the sudden. Workers could no longer 

access all the areas they used to go to. 

Every once in a while, administrative staff had to drop off documents at Building 75. On either 

side of the stairs and the walkway that led to the door, there were gas cylinders on both sides of 

the walkway. These cylinders were of every shape, size, and color. An interviewee had no idea 

what was in these cylinders, but everyone inside the building was working behind protective 

glass. Most of the workers wore white suits and gloves. Some of these employees were wearing 

full headgear or special masks. 

Hand and foot monitors were stationed at exits from radioactive work areas. Portable 

instruments were maintained at radioactive work areas (e.g., gloveboxes and chemistry bench 

tops). Workers were required to monitor themselves when leaving and during radioactivity 

operations. Workers monitored their hands when pulling their hands out of gloveboxes and 

hoods. The RM did glovebox glove changes and monitored the gloveboxes themselves. 

Surveys of the diagnostic x-ray unit were conducted, as well as industrial and analytical units; 

the surveys were maintained in a file at his desk. 

Originally, workers were allowed to eat, drink, and smoke in the immediate vicinity of 

radioactive material. For example, maintenance workers drank beverages at their machines. 

They could eat a sandwich while they were machining. There were also drinking fountains in 

the operating areas. Now workers cannot drink or eat in the shop. This has been in effect for a 

while now. 

X-RAY MACHINES 

The interviewees, collectively, provided their understanding of how x-ray machines were used 

and controlled at the laboratory, as follows. 

LBNL had three types of x-ray machines—medical, industrial, and analytical. They are 

addressed separately in ANSI standards. There was a group of individuals who designed x-ray 

machines at the laboratory. The lab had two industrial units used for irradiation and/or nondestructive testing, which were totally enclosed in heavily shielded vaults. These were 250 kVp 
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Picker teletherapy units. [Analytical x-ray units included x-ray diffraction and x-ray 

fluorescence.] The x-ray diffraction (XRD) units were originally open beam, which was normal 

for the time. X-ray fluorescence (XRF) and cabinet units were fully enclosed. 

From 1979 forward, all the x-ray machines on the hill were enclosed. LBNL was the first 

national lab to enclose all analytical x-ray machines. LLNL was second, and others finally 

followed more than a decade later. Other national labs still use open beam XRD units. 

Enclosures were installed, so that body parts could not be put inadvertently into a beam. X-ray 

Safety had been trying to put forth a full enclosure and area monitor agenda for years, and he 

used the [1977 x-ray exposure] accident to put forth this agenda. Even with [the accident], it 

took more than a decade to get his access control agenda through. Area alarming monitors were 

placed on the units and key card activation was required. It took more than a decade to get the 

lab to spring for card key activation. 

Health Physics X-ray Safety was notified of any alarms. They rewired the units, such that they 

had a failsafe interlock change and an “x-ray on” light by the power switch. Machines were 

allowed to have only one button to start the machine. In 1985, they also adopted ANL’s idea for 

placing a form of alarming area dosimeter on the case. The routine users could not override the 

interlocks on their own, but only those with override authority could override the interlocks. 

They could override the interlocks only with a special key, and later, only if their card key access 

allowed override. This limited beam access to only a small percentage of the user population 

and only the most senior and experienced users. They were called “system operators.” There 

was an audible alarm if/when the interlocks were overridden. The authorized users were trained 

by x-ray safety personnel, and they, in turn, trained the routine users. This corrected a lot of the 

problems associated with the analytical x-ray units. 

EXTERNAL MONITORING 

The interviewees, collectively, provided their characterization of how external monitoring was 

performed historically at LBNL, as follows. 

Prior to 1980, all personnel were assigned dosimeters (film badge or TLD). Many laboratory 

personnel were assigned dosimetry badges who most likely would not receive an exposure. 

After 1980, dosimetry was assigned to Radiation Workers based on need. Workers wore their 

whole-body dosimeter at their chest. The film over-responded to lower energy photons. 

Electron accelerators produce muons, but there is no special monitoring for this. Radiation 

Monitors received some of the highest doses at LBNL as they assisted with the work. 

Early in the 1980s, the site switched to TLDs that were capable of detecting some neutrons. The 

CR-39 was implemented in the 1990s for the detection of high-energy neutrons (4–5 MeV). In 

the last 10 years, neutron energies were moderated with shielding. 

There was an error in the neutron dose discovered in 1979 or 1980. The dosimetry technicians 

relied on a chart to translate the number of tracks into dose. For readings of 1 or 2 tracks, the 

chart was off by a factor of 10. For example: 
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1 track = 40 mrem (should have been 4 mrem) 

2 track = 80 mrem (should have been 8 mrem) 

3 track = 12 [mrem] 

4 track = 16 [mrem] 

This misinterpretation occurred from ~1970 to roughly 1980 and resulted in an overestimate of 

neutron doses. The badge readings with 1 or 2 tracks were misinterpreted, but readings of 3 or 4 

tracks were correctly interpreted. 

When the neutron dosimetry errors were discovered, they were not corrected and workers were 

not notified. This problem was discovered by an interviewee who notified dosimetry of the 

problem. Where these errors are should be very obvious and numerous in the record. Real 

exposures that high were very rare and only within a very small group of workers. These errors 

will appear as chronic exposures, and LBNL just did not have any such chronic exposures. 

Typically, there were no non-uniform radiation fields. There were a handful of projects with 

extremity dosimetry, and electronic dosimeters were used in some situations. The researchers 

working in areas where an extreme exposure can occur (for example, working in junior caves, 

time limit entry) wore hand dosimetry. After palm films, there were finger rings. Target 

handlers at the 88” Cyclotron used multiple dosimeters. 

The XRD users were not required to wear extremity dosimetry. The users could not do their 

work with them on. The beams were collimated. As a precaution, the area monitor would go off 

if the beam was not collimated. They didn’t think the extremity dosimeter would catch the 

beam. Enclosures, area monitors, and access controls were imposed and designed to prevent 

exposure as best they could. Prevention seemed more prudent than monitoring, as stated in a 

paper at the Denver X-ray Users Conference (about 1985). 

Dosimetry investigations were done for unexpected results. The film would show suspicious 

results (i.e., running through airport x-rays, etc.). They would have to interview the person to 

determine the cause. 

INTERNAL MONITORING 

The interviewees, collectively, provided their characterization of how internal monitoring was 

performed historically at LBNL, as follows. 

LBNL was responsible for their own bioassay analysis until recently [~2006]. The bioassay 

program was part of the medical program for a period of time. Health Physics was responsible 

for determining who was monitored. Health Protection also issued work restrictions at 

established levels for bioassays. The bioassay laboratory was separated out after about the mid1990s. Presently, LBNL contracts with the Savannah River Site to analyze their samples. 

There was a routine urine sampling periodically for those working with radionuclides. If an 

individual worked with radioactive material, they submitted bioassay samples once per year, or 

more frequently, in some cases. Nuclear Chemists were on an isotope-specific bioassay 

program. For example, at Building 51, bioassay was collected for a little bit of everything. 
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Weekly tritium bioassay samples were collected at NTLF. Tritium was measured in urine in 

terms of μCi/liter. There was no routine fecal sampling program. One interviewee recalled 

collection of a pre- and post-job sample during a job at Building 70A. Urine and fecal samples 

were collected after an incident. Some blood samples may have been taken at one time. 

Many of the samples were 24-hour samples (collected over a 24-hour period), with some spot 

samples. Bioassay samples were collected at the lab and home. Early bioassay data are usually 

recorded as gross alpha or gross beta, with some exceptions. This reporting practice continued 

into the 1990s. 

Internal dose monitoring is presently based on the requirements specified in the LBNL Internal 

Dosimetry Technical Basis Document. Bioassay requirements are communicated through 

Radiological Authorization documents by the project. These documents also prescribe PPE and 

other requirements. There is a pre-qualification bioassay collected before an individual works 

with materials. There are about 15–20 bioassays per year combined for americium, plutonium, 

uranium, curium, neptunium, tritium, I-123, I-125, and I-131. Iodine bioassay is done for those 

involved in the Medical Research program. 

There was a whole-body counter in the basement of the Donner Laboratory (Building 1) used to 

count some workers. Thyroid monitoring was done at LBNL for individuals who worked with 

iodine. In the clinics, they had thyroid monitors. The results of this monitoring would be in the 

medical records. Now there is a contract in place with LLNL for whole-body counting services. 

The NTLF had the largest potential for uptakes (i.e., tritium), and then the animal house area. 

There were no workers with consistent detectable body burdens. 

There were no audits that identified deficiencies in the internal dosimetry program. Gaps in 

bioassay data would occur when certain individuals didn’t turn in their urine sample on a timely 

basis. 

INCIDENTS 

The interviewees, collectively, provided their recollection and understanding of what incidents 

occurred at the laboratory and how they were handled, as follows. 

In 1977, a severe radiation accident occurred involving an individual who inserted his hands into 

the beam of a cabinet x-ray machine without realizing that it was on. The old mechanical relays 

on the machine were noisy, and when one of them caught fire, it was replaced it with a solid state 

relay (SSR). The old mechanical relay interrupted both legs of the 220 v. When the SSR was 

put in, one leg was shorted through and the SSR only interrupted one leg. Furthermore, there 

was no snubber network placed across the triac on the SSR, as was recommended for triacs firing 

into inductive loads. The failure was highly predictable. 

The warning light could not be wired across the primary of the high tension transformer, since 

the voltage was varied over a wide range, and the light would go from extremely dim to short 

burnout bright. So the light was wired across the control winding of the SSR. The beam stayed 

on, but the current was varying, so the light went on and off. However, there was a large and 
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easily seen working mA meter in place at eye level, right above the cabinet door (next to the 

light), which was giving a very clear mid-scale reading that there was current going through the 

x-ray tube and, thus, that x-rays were being produced. In haste, the technique used by the 

individual to turn on the machine was to reach up and actuate the ON switch as he was walking 

and facing away from both the meter and the light. Evidently, he paid no attention to the meter 

as he opened the door. The ozone smell was strong [another indicator of x-ray production]. The 

accident resulted in permanent injury. 

Other Incidents 

A file was compiled of the various incidents. During the high production era, there were more 

spills. An RM was required to be there when there were high-risk tasks. When the researchers 

were handling radioactive samples, there was a potential for contamination. There were a few 

cases were contamination was tracked into non-controlled areas; these would be documented in 

incident reports in EH&S archives. 

Occasionally, there was some skin contamination. Initially, the researchers were on the honor 

system to report to the RMs if something happened. The RM would survey the individual, 

perform the initial decontamination, and send the individual to Medical. In the later years, an 

RM monitored the process and individuals were referred to Medical for decontamination. 

Medical saw several individuals that were contaminated mostly at low contamination levels. 

There were some suspect wound contaminations, but no uptakes through absorption. There were 

no other acute radiation effects, except the x-ray exposure incident. Several individuals were 

chelated once with Ca-DTPA via aerosol chelation. They had activity in the nose and mouth, 

and were chelated because of a potential exposure to Am-241. The urine did not show an uptake 

as a result of the accident. LBNL had to report the use of chelation to Oak Ridge, who should 

have further information. 

In 1959, there was an incident at HILAC involving Cm-244. Curium was sputtered onto a foil. 

The foil had to be kept cool. The pressure was turned on before the exhaust, and the plated 

particles became atomized and drifted out. There were particles floating around. There was a 

Cm-244 release inside Building 71, which was blown outside by the ventilation. The RM 

evacuated the buildings. The staff in the area received bioassay sampling as a result of the 

incident. Although there was not much of an uptake, there was a large decontamination effort 

for several days, because the particles dispersed throughout the building. The contamination was 

loose and could become airborne, requiring the decontamination workers to be suited up and 

wear respirators. Air sampling was done during and after the clean-up. 

On one occasion, a researcher who had been working with americium and plutonium at LBNL 

transferred to another DOE site. His pre-employment body count at discovered americium, and 

as a result, LBNL had to do some research and determine if [an uptake/release] had occurred. 

In the early days, when they were injured, a band-aid was put on the wound and they just 

returned to work. 
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The DOE activated the Radiation Assistance Team (RAT) from LBNL. Those involved worked 

with the local emergency response agencies. During the response to one incident, the workers 

were contaminated with thorium oxide. 

[LBNL had situations where individuals were exposed on purpose.] Astronauts from NASA 

reported they had seen flashes in their eyes as a result of activation of the fluid in their eyes. To 

determine the cause, LBNL staff placed their heads in the beam of the 184” Cyclotron to see if 

they could reproduce the flash of light. There were personnel who injected themselves with 

radioactive material to evaluate biological effects (e.g., chromosomal abnormalities), or to 

determine the effectiveness of personnel monitoring techniques. There were also a few 

individuals who took radioactive material home. 

MEDICAL 

The interviewees, collectively, provided their characterization of how medical monitoring was 

performed historically at LBNL and how radiological records were maintained, as follows. 

Medical was known as Medical Services and Health Services. Medical Services created an 

annual report, which was distributed to the superiors. This report included the number of exams 

completed, the number of bioassay samples collected, the number of laboratory samples 

collected, and participation in the Employee Assistance Program (EAP). EAP eventually went to 

the campus. 

At first, there were no health services at LBNL; just a first aid station. They then introduced preemployment exams, and finally regular physical exams with a chest x-ray. All the exam 

requirements were determined by the AEC and ERDA. Occupational medical requirements can 

be found in DOE Order 5440. Routine exam frequencies were based on age. One interviewee 

stated that the frequency of x-rays taken with the exams was annually, then biannually, then 

every 5 years, and finally discontinued for most people. Some individuals were required to have 

periodic x-rays because of the Be, Pb, asbestos, and silicosis standards. There was a preemployment exam with x-rays (up to about 1990). At pre-employment exams, posterior-anterior 

and lateral chest x-rays were taken. 

Initially, workers had to be taken offsite to get x-rays, because there wasn’t an x-ray facility 

onsite at first aid. Offsite x-rays stopped by 1964, if not sooner. LBNL had a Picker x-ray unit 

that was put into Building 26 about the time it was built. Health Physics did surveys on the 

diagnostic x-ray units with a phantom using their techniques. The vendor did the maintenance—

regular servicing—on the x-ray units. 

X-ray retakes were less than 10%. LBNL never did lumbar spine x-rays. There were no 

photofluorography x-rays found in the medical files. Most of the films in the records are the 

standard size of x-rays (14” x 17”). The nursing staff was cross trained to serve as x-ray 

technicians. Part of the training of the x-ray technicians was done by an outside agent who 

supported LBNL. 
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[Medical had] a Co-60 teletherapy source for a while, which was used as a research tool for 

primarily animal studies. In the 1930s, they had the electroscopes. They did do some blood tests 

to check for decreases in white blood cell count. 

RADIOLOGICAL RECORDS 

The current dosimetry database, REM, contains data from 1981 or 1982 forward. There was a 

predecessor database. The bioassay data back to the 1960s was put into an Access database. 

The ORAU Team was provided with a copy of this database. Now there is so little data to store, 

it is maintained in hardcopy. A copy of the bioassay results would be put into the medical file, 

but a duplicate was maintained by the Radiation Protection department. This was because all 

medical data had to be included in the individual’s patient file. 

Historically, some workers reported receiving dose reports quarterly. They recall positive 

results. Health Physics switched the monitoring frequency to annual. Now workers typically get 

zero dose. 

ENVIRONMENTAL MONITORING 

The interviewees, collectively, provided their characterization of how environmental monitoring 

was performed historically at LBNL, as follows. 

Environmental work fell under Health Physics and Health Chemistry Department. Health 

Chemistry was responsible for stack emissions. Health Physics was responsible for doing 

penetrating radiation monitoring. There was a separate group responsible for Radiation 

Emissions. These functions [eventually came under] the Environmental Protection Department. 

The environmental monitoring program has consisted of collected stack air, ambient air, surface 

water, ground water, vegetation, soil and sediment, and even goat urine and milk samples. The 

goats are brought onsite during the summer months to clear grasses and weeds as part of the 

lab’s wildland fire management program. 

Historically, LBNL monitored all 120 stacks that had the potential for release of radionuclides. 

Currently, they monitor 12 stacks. The details are provided in the Annual Radionuclide Air 

Emission Reports. In 1995, there was a budget cut and thus a reduction in the environmental 

monitoring activities. The number of monitoring points had built up before this because of the 

Tiger Team Assessment. Currently, LBNL routinely analyzes the stack air samples for gross 

alpha and gross beta, H-3, C-14, and I-125. Positron emissions are monitored at the 88” 

Cyclotron stack and the Building 56 Cyclotron stack. 

There were [air] releases from the 88” Cyclotron irradiation vault, the NTLF, and Building 64, 

where they produced medical radioisotopes (e.g., C-11, F-18, all Positron Emission Tomography 

isotopes). Tritium releases occurred while the NTLF was in operation between 10 to 30 years 

ago. The last major tritium release occurred about 10 years ago. Building 64 had very tall stacks 

with a poor stack monitoring system. The detectors were not stable instruments. Part of the 

problem with measuring the effluent from the stack is that the air passes the sampler too fast. 
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Up until the closure of NTLF, there was also tritium analysis of ambient air samples. The lab 

monitored tritium using critical orifices and sampling 10 cubic centimeters per minute. Tritiated 

water (HTO) and elemental tritium (HT) were considered in the environmental reports. The 

elemental tritium was analyzed by direct counting, or was converted to water vapor and analyzed 

by liquid scintillation. The program for monitoring tritium in ambient air fluctuated. 

There was a study conducted on the retrospective releases of tritium from LBNL. Scientists 

analyzed the tritium content in eucalyptus tree cores, because there was a grove of eucalyptus 

trees around the tritium stack. This study may provide some information on early tritium work. 

The ambient air sampling stations are three perimeter monitoring stations on the east end, west 

end, and near the Hazardous Waste Handling Facility. There were more stations in the past. The 

annual reports provide the location of the stations. Ambient air samples are analyzed for gross 

alpha and gross beta. 

The external ambient monitoring has been done with TLDs or real-time gamma/neutron 

monitors. Initially, external environmental radiation levels were monitored at the perimeter 

using GM tubes (1 foot long by 1 inch diameter) for photon measurements. Levels were 

continuously integrated and were recorded and stored in 10-minute groups so nothing was 

missed. The GM tube was more rugged, constant, and environmentally more stable than ion 

chamber or scintillator instruments of comparable sensitivity. There is known to be a seasonal 

variation in background radiation. These GM units are sensitive enough to detect that variation 

consistently year after year. In fact, they were also sensitive and stable enough to detect a 

decrease in terrestrial radiation, due to shielding from soil saturation during rainfall. Personnel 

looked for this kind of sensitivity as it indicated that the units were sensitive and stable enough 

for use as environmental monitors. Previously used instrumentation could not detect these slight 

variations. 

Environmental Monitoring deployed jugs of water and TLDs to measure environmental neutron 

dose. Neutron exposures are measured in rads or rem. There was also a photon badge on the jug 

as well. These were placed around the radiation sources, especially in line with concentrations 

of unmonitored personnel (employees and general public) and in public areas of greatest 

concentration of unmonitored personnel. The “in close” monitors would alert them as to when 

they might most probably find some indication on the monitors in populated areas, since they 

[the “in close” monitors] were statistically better indications. Then they could pay closer 

attention for the possibility of a smaller (statistically less significant) indication on the population 

monitors. 

There was a study of the maximum depth of penetration. There was some neutron dose off the 

back of the 88” Cyclotron when it was running light ions. They had recording instruments to 

make continuously integrated measurements, with the integrals recorded in 10-minute groups. 

There were no problems with the other accelerators. 

There are currently eight dosimetry stations and three gamma/neutron stations, although this has 

changed over the years. There was an equipment upgrade in the early 1990s. Penetrating 

radiation (gamma/neutron) monitoring locations are at the west end of the site, around ALS, and 

offsite (across the valley). 
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Never was anything attributable to lab operations detected at the “Panoramic station,” the one 

across the valley. There were no detectable levels during routine operations of the ALS at the 

fence-line monitoring station. Under a very rare fault condition, a difference could be detected at 

the boundary when the ALS unit was on or off. A measurement of 6 microRem/hr was obtained 

off the ALS for this very rare fault condition when it was continuously in injection/fill mode for 

almost a week. This could only be detected when the ALS was stuck in injection over a long 

time. This is absolutely the worst case condition the ALS could be in. This measurement had a 

confidence level of 17 standard deviations. In a conversation some time later, it was suggested 

that this was probably one of the smallest neutron dose levels ever measured. 

Ground water underwent analysis for gross alpha, gross beta, gross gamma, tritium, and Cm-244. 

They have analyzed for plutonium isotopes in sewer water. They perform gamma spectroscopy 

on soil and sediment samples. There is a ground-water tritium plume that extends south from the 

area of the former NTLF. Soil near the former NTLF is also contaminated with tritium. Low 

levels of Cm-244 are present in the soil near Building 71. In 1985, radioactive contamination 

was detected in the soil near Building 5. The contaminated material was removed. 

All of the drinking water for the site is supplied by the East Bay Municipal Utility District, and 

not from onsite wells. 

There was an incinerator at LBNL, but it was not used. No burning activities occurred. 

Annual environmental reports for 1995 to the present are available at the web site. The lab has 

hardcopies of these annual reports going back even further. The annual environmental reports 

contain information on routine and incidental releases. The environmental monitoring stations 

are described in an old paper by the original designer, and two additional papers were written 

after instrumentation and telemetry upgrades. All three papers were presented at various HPS 

meetings. 

[Environmental Services] has done some isotopic characterization for a few of the D&D projects, 

and plans to do more in the future. The Environmental Restoration Program has prepared a 

summary of radionuclide investigation reports for the investigations they have conducted. 

The state of California is not involved in environmental regulatory issues, including monitoring, 

although there is some involvement in waste management activities. The EPA has some 

authority at the site under the radionuclide NESHAPs regulation. There was a 1988 DOE 

environmental survey summary report. There were no aerial gamma surveys done at LBNL. 

In the Tiger Team review, the main environmental issues raised were lack of formality and 

documentation in the program. The assessments resulted in a better management commitment 

and more resources.

SITE PROFILE COMMENTS 

RadCon staff indicated the material in the site profile is correct, and that NIOSH captured the 

dosimetry program well. Information related to x-ray equipment is also correct. 
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MISCELLANEOUS COMMENTS 

• The laboratory learned from their experience on the 184” Cyclotron and applied this to 

building the calutrons in Oak Ridge. After WWII, they didn’t use calutrons, because they 

were not as cheap as the gaseous diffusion process. Centrifuges, developed later, are also 

cheap. 

• A Class Action lawsuit was filed against LBNL because of unauthorized testing of 

minority employees for pregnancy, syphilis, and sickle cell anemia. Even though the 

lawsuit was resolved in 1999, the workers were never told why these tests were 

performed, where their personal/private information was, and who has/had access to it. 

An article about the lawsuit states, “The newspaper’s series prompted Energy Secretary 

Hazel O’Leary to open up government files that disclosed a pattern of federally 

sponsored radiation experiments on human subjects.” 

• There were two copy centers on site—Building 50 and Building 90. They were used to 

complete large copying projects. Administrative workers would change toner cartridges 

and clear jams that were inside these large copy machines, as well as cartridges from 

copy and fax machines in the daily work area. The workers often got toner on hands, 

arms, and clothing. If [the hazard had been communicated], these workers would have 

changed these cartridges with more caution. 

• Administrative offices in Building 80 had broilers for heaters. The broiler pipes were 

wrapped with material containing asbestos. An interviewee was told that as long as no 

one touched the material, there would not be any problem. This material was not 

removed or altered in any way before, during, or after the group moved into this building. 

The administrative staff had no access to windows and no sound buffers from the 

[construction] work that was being done down below on the first floor. There were very 

loud noises and smells. At times, there were [disturbing] odors coming up from the 

bottom floor. 

• The Advanced Light Source (ALS) began its initial phase in Building 46. Down from the 

administrative working area, there was a shop that at times did small welding jobs. Every 

so often there would be a burning smell coming from this area. The smell was putrid and 

it lingered. The building was not ventilated well and did not have air conditioning. 

• There are a number of confounders for cancer. For example, sugar has been 

demonstrated as a confounder for Non-Hodgkins Lymphoma. 
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ATTACHMENT 3: ISSUE RESOLUTION MATRIX FOR SC&A 

FINDINGS ON THE LBNL SITE PROFILE REVIEW, ORAUT-TKBS-0049 

Issue 1: Inadequate Documentation of Historical Operations and Sources of Radiological Exposures 

SC&A Finding: This review found that the site profile provides an inadequate overview of LBNL historical 

operations and the primary radiological exposure sources and conditions. The document lacks sufficient detail and 

analysis to provide comprehensive guidance to dose reconstructors. The period covered is large, as it is for several 

of the other DOE sites; however, the TBD failed to fully address the exposure implications of radiation sources to 

the degree necessary to allow a comprehensive assignment of historical doses, including missed doses. Specific 

operations and facilities are not discussed in sufficient detail. Examples of the lack of significant detail and 

information are the lack of coverage of the National Tritium Labeling Facility (NTLF) and the accelerator program 

at LBNL. 

NIOSH Response: 

SC&A Reply: 

Work Group Actions:

Board Action: 
Effective Date: 

January 22, 2010 

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Issue 2: Insufficient Information for Internal Dose Reconstruction, Especially during the Early Years 

SC&A Finding: There is insufficient information on bioassay monitoring before 1961, and the information on air 

sampling and building activities is not sufficient to calculate the workers’ dose due to internal exposures. Workers 

were potentially exposed to a diversity of radionuclides at LBNL, and the TBD is incomplete in relation to the 

periods of time and quantities of radionuclides that were handled in the different areas. 

Table 5-4 of the TBD lists minimum detectable activities (MDAs) for in-vitro measurements, but is incomplete with 

regard to the totality of radionuclides that were handled at LBNL and their MDAs. The information on MDAs on 

the various periods is incomplete, posing a problem with the calculation of missed doses. 

Gross alpha, beta, and gamma analyses are reported as being used for the entire site operation, including the present 

time. The TBD does not discuss the fact that many radionuclides present at LBNL would not have been detected by 

gross measurements, or at least detected with low recoveries and resulting high minimum detectable concentrations 

(MDCs). In addition, the use of gross measurements results in an indeterminate MDC for a specific radionuclide. 

NIOSH Response: 

SC&A Reply: 

 

Work Group Actions:

Board Action: 

 
Effective Date: 

January 22, 2010 

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Issue 3: Special Forms of Tritium and Plutonium not Addressed by NIOSH 

SC&A Finding: NIOSH fails to identify in the site profile that metal tritides and organically bound tritium (OBT) 

are included in the materials used at the site and that tritium was used extensively at LBNL, in particular at the 

NTLF, Building 75. There is very little discussion about tritium exposures in the internal dose section (Section 5.0) 

of the site profile. 

During the interviews, health physicists stated that it was possible that highly oxidized/high-fired forms of actinides 

were handled at the site. They stated that the most likely source of exposure to these forms would have been related 

to the production of sealed sources and targets that were made for use at LBNL and other national laboratories. It is 

possible that NIOSH is addressing this issue for plutonium exposures at LBNL; however, the site profile does not 

address high-fired forms of other actinides (thorium, uranium, etc.). 

NIOSH Response: 

SC&A Reply: 

Work Group Meeting:

Board Action: 
Effective Date: 

January 22, 2010 

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Issue 4: Bioassay Data Completeness and Adequacy have not been Verified 

SC&A Finding: During the site visit by SC&A, it was determined that the bioassay database does not contain all 

bioassay data for all workers; therefore, it appears that the database may be incomplete. In addition, bioassay 

submittals were delinquent by at least 1 year in some file records. This delay could increase the minimum 

detectable doses significantly, especially for soluble and short-effective half-life nuclides. 

 

In Tables 5-1 through 5-5 of the TBD, NIOSH listed many in-vitro and in-vivo bioassay methods, along with 

information on frequency of sampling. Given the great number of radionuclides that could have resulted in internal 

exposures at LBNL, it is apparent that many of these are short-lived, relative to the bioassay frequency. 

During the site interviews, it appeared that work conducted at the Donner Laboratory and other laboratories at the 

University of California – Berkeley campus was not monitored and/or controlled as stringently as at other LBNL 

facilities. NIOSH should investigate the possibility that internal dose information (bioassay and air sampling data) 

for the work at these laboratories is adequate to reconstruct doses at these locations. 

NIOSH Response: 

SC&A Reply: 

Work Group Action: 

Board Action: 

 
Effective Date: 

January 22, 2010 

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Issue 5: Insufficient Justification for Selection of IREP Energy Range Fractions for Photon Exposures 

SC&A Finding: In Table 6-2 of the TBD, beta and photon doses are assigned to energy ranges according to the 

radioactive materials used in individual buildings at LBNL. For Buildings 51 and 71, a single photon energy 

distribution is given, and 10% of the measured dose is assigned to the 30–250 keV range and 90% assigned to 

>250 keV. It appears that this photon energy distribution is being applied to the entire history of accelerator use at 

LBNL. It is questionable that this energy distribution is appropriate in all situations and timeframes. In the early 

years, it is much more likely that technicians and others would be exposed to low-energy emitters shortly after a 

machine was powered off, or even during operation. This was presumably less likely as energies and risks grew 

larger and commensurate standards and protective practices evolved. 

Regardless of the precise fraction that should be assigned, the choice of less than 100% to the 30–250 keV category 

should only be made where there is supporting evidence. As it stands, the selection of a 10% fraction is not claimant 

favorable and not buttressed by the inclusion of supporting evidence. Although the other buildings have been 

assigned factors greater than 10% for the more claimant-favorable 30–250 keV photon energy range, the fact that 

the accelerator buildings have been assigned a single low factor creates doubt on the validity and process by which 

the other factors were determined for the remainder of the site. 

NIOSH Response: 

SC&A Reply: 

Work Group Actions:

Board Action: 
Effective Date: 

January 22, 2010 

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

Issue 6: Insufficiency of Neutron Dosimetry Treatment 

NTA Film Energy Threshold Determination: As has been the case in a number of site profiles prepared by 

NIOSH, there is an inconsistent approach to the energy cut-off for the NTA neutron dosimeter. Callout “c.” in 

Table 6.5 references NIOSH 2002 as listing the NTA lower energy threshold at 500 keV. Yet attribution number 47 

discusses 800 keV as the threshold, and this is used as the basis for this TBD. Other sources list 1,000 keV as the 

threshold for NTA response. The assumption that NTA film responds down to 500 keV is not justified by the 

technical data and is not claimant favorable. 

Failure to Adjust Recorded Doses to Correct for Lack of Response of NTA and CR-39 in the Intermediate and 

Thermal Neutron Energy Range: Table 6.6 of the TBD, “Adjustments to Recorded Dose,” defines the corrections 

for photon and neutron dosimeters to adjust the measured quantity. However, no adjustment is indicated for the 

failure of NTA film to respond to intermediate energy neutrons. As presented, a significant part of the spectrum is 

inappropriately monitored and uncorrected. 

There is virtually no discussion of the potential for neutron fields throughout this historical facility. Given that LBNL 

was a world leader in accelerator development, and given the leading-edge high energies developed by the machines, 

it is likely that there was the potential for unanticipated radiation fields and possible neutron exposures across a range 

of energies, especially in the early decades. 

There is a remarkable silence as to thermal or slow neutron exposure in the site profile document. A search of the 

“O” drive revealed only a single document that mentioned slow or thermal neutrons. Clearly, there was the potential 

for exposure to slow neutrons, as slow neutron electroscopes were in use in 1956 and readings were documented for 

several individuals. 

It is unclear from the TBD how and when albedo TLD data were merged with CR-39 results. The gap in neutron 

response from above the cadmium cutoff to the lower energy threshold for CR-39 (also not mentioned, but assumed 

to be around 150 keV) is not discussed. NIOSH should evaluate the neutron program and determine how missed 

intermediate energy neutron dose should be determined for this period, as well as intermediate and thermal energy 

neutrons for the NTA and pre-NTA years. 

Selection of Minimum Detectable Dose for CR-39 Dosimeters: Table 6-1 of the TBD shows that the MDL for 

CR-39 is 10 mrem, with no attribution provided. The Los Alamos TBD shows an MDL for CR-39 of 20 mrem. The 

current commercial service available from Landauer, Inc., also shows an MDL of 20 mrem. It is likely that the MDL 

for CR-39 is higher than 10, and more likely around 20 mrem. This number is important and it is likely to be 

amplified to take account of missed dose not only due to exposure below the detection limit (DL), but also to estimate 

dose due to lower energy neutrons that would have been missed entirely due to the inability of CR-39 to detect lowerenergy neutrons. 

Use of Neutron-Gamma Ratios for Situations Where Neutron Data are Lacking - Seeming Inconsistency 

Between the Environmental and External Dose Sections: Table 4.1 of the Environmental Occupational Dose 

section (Section 4.0) of the TBD contains estimates of annual environmental dose throughout the history of the 

facility. The values provided are totals of neutron and photon exposure. 

The Environmental Dose section utilizes a ≥70% factor and the External Dose section utilizes a 42% factor. This 

significant difference in the average site-wide neutron-to-photon ratio is surprising. It is possible that the 

environmental dose includes more sky shine and other factors; however, this issue needs to be addressed and the large 

difference explained. 

This section on the determination of missed and missing neutron exposure needs a thorough review. Both the source 

terms and the dosimeter response specifications need to be addressed. 

NIOSH Response: 

SC&A Reply: 
Effective Date: 

January 22, 2010 

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Issue 6: Insufficiency of Neutron Dosimetry Treatment 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

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0 (Draft) 

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

Issue 7: Failure to Justify the Shallow Dose: Deep Dose Assumption 

SC&A Finding: The TBD provides guidance on the dose to be assigned in the “early” years (pre-1979) for which 

there is no record of beta exposure. In the general case, there is an assumption that a factor of three for the ratio of 

shallow to deep dose is reasonable and claimant favorable. However, LBNL had a broad mandate.

In most cases, the site description does not provide sufficient detail as to the quantities, forms, and methods under 

which these materials were handled. What is known is that the levels of protection in the 1940s, 1950s, and 1960s 

were far from what would be considered good practice today. 

There is no mention of head and eye dose or non-uniform whole-body irradiation in the site profile. Typically, 

workers handling beta emitters and those performing maintenance inside accelerators can be exposed to significant 

non-uniform fields. Likewise, there is no mention in the TBD of potential skin and clothing contamination and 

resultant exposure. 

It is unclear from the TBD if workers were exposed to significant shallow dose, with possibly little deep dose to be 

used as an indicator. Possible activities that may have been conducted include fume hood operations, maintenance 

of accelerators, ventilation and plumbing systems, waste disposal operations, and spill cleanup. The lists of nuclides 

are extensive and include beta emitters, including some pure beta and low-energy x-ray emitters. For some 

personnel, the 3:1 ratio may not be claimant favorable. NIOSH should identify the workers who could have 

received exposure from these beta or low-energy x-ray emitters, or provide an alternative method of estimating the 

shallow dose in a claimant-favorable manner. 

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

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

Issue 8: Uncertainty in Beta-Gamma Dosimeter Response to Radiation Types and Energies 

The Use of Early Electroscope Data Needs Greater Definition: Page 39 of the TBD describes the use of 

electroscope data as follows: 

... Exposure data were recorded by film badges and thermoluminescent dosimeters (TLDs). Early 

exposure records also provided electroscope (or at times, electrometer or E was used) results, 

which supplemented the results measured by film. Dose reconstructors should use the 

electroscope results in a qualitative manner because no data were found on the calibration or 

energy response of these devices; they should use the film or TLD results to estimate the actual 

exposure or the electroscope reading if no corresponding dosimeter reading exists. 

A search of the “O” drive found that, anecdotally at least, there were significant problems with electroscopes. A 

study performed November 23, 1953, by Jim Bennett (Bennett 1953) showed that readings from the three 

electroscopes tested were widely divergent from the film that was exposed with them. Two gave a 10% response 

compared with the film, and the third was off scale. No details are provided as to the energy of the gamma source 

used for the exposure. However, the memo provides a cautionary statement as to using electroscope data, even in a 

qualitative manner. 

Dosimeter Response to Very High Energy Photons and Charged Particles: LBNL was a pioneer in the 

development of high energy physics (HEP) and in the search for exotic particles. The film and electroscopes in use 

in the early decades will likely not have been calibrated for energies above 1 or 2 MeV. NIOSH should evaluate the 

dosimetry and potential for exposure to radiation at energies above that commonly produced by radioisotopes. The 

detectors will have responded to some degree, but the correction factor size and sign are unknown and not 

mentioned in the TBD. The response of the detector element or film, for example, will depend greatly on the 

composition of the holder and filters. 

NIOSH Response: 

SC&A Reply: 

 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

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

Issue 9: X-ray Exposures are Uncertain 

SC&A Finding: Table 3-1 lists the entrance skin exposure (ESE) doses used for the posterior/anterior (PA) chest 

exam. It states that until 1975, all dose estimates are defaulted to those provided in ORAUT-OTIB-0006. There is 

no information identified as being available on x-ray equipment that was used prior to 1975. Depending on how one 

views this information, there is no indication that this default is claimant favorable for the years 1942 through 1975. 

NIOSH needs to better describe what measures were taken to determine what types of equipment were used. For 

example: 

• Where did workers get exams between the years 1942–1975? 

• Were medical records available and do they indicate if x-rays were taken? 

• Were workers sent to alternate locations for exams and were those records researched? 

• Did NIOSH research address the potential use of PFGs to screen workers up through 1960? 

The TBD should be expanded in its discussion of the medical dose to address the issues indicated in the above 

questions in order to be considered complete.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

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0 (Draft) 

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

Issue 10: Uncertainty of Calculating Doses Prior to 1961 

SC&A Finding: There is no information on how NIOSH is planning to reconstruct doses before 1961. In ORAUTTKBS-0049: 

• Table 5-1 lists the in-vitro types of bioassay, the periods, and the frequencies of monitoring. It does not 

contain any information that might be applicable to calculate doses for exposures before 1961. 

• Table 5-4 lists the MDAs for various analysis results. The only pre-1961 information available is the MDA 

for gross alpha, and gross beta is for 1957–1961. 

• Table 5.8 contains only one reference to exposures before 1961. 

• Looking at the files for LBNL in the NIOSH OCAS Claims Tracking System (NOCTS), 24 claimants 

received compensation. Those were probably the most exposed workers, and 18 of the 24 claimants started 

working before 1961. There is only one bioassay record before 1961; a uranium urinalysis done in 1958. 

• Looking at the 99 claimant files for LBNL who did not receive compensation, 31 started working before 

1961. There is only one bioassay record before 1961; a C-14 breath analysis performed after an incident in 

1959. 

There is insufficient information related to bioassay monitoring before 1961 in the TBD. 

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

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0 (Draft) 

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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. 

Issue 11: Inadequacy of Bioassay Analyses Presentation 

SC&A Finding: There was a diversity of radionuclides at LBNL. The Occupational Internal Dose section of 

ORAUT-TKBS-0049 specifies that, “from 1960 to 1996, both in vitro and in vivo monitoring records and associated 

interpretations exist.” In Table 5.4, MDAs are listed for gross alpha for isotopes of thorium, plutonium, curium, 

actinium, and neptunium. The same method and MDA are listed for Cf-252 from 1965–1995. There is a remark 

specifying that, “method descriptions note that uranium, radium, and polonium are not detected by this method 

(Author unknown, no date).” 

Table 5.8, “Radionuclides and fraction activity by facility,” is incomplete and difficult to use, in relation to 

discrimination between exposures during the various periods of time the rooms were used in the installation. 

Tables 5.1, 5.2, and 5.4 describing in-vitro bioassay programs, methods, and MDAs are incomplete and do not give 

enough information on internal dose calculations for LBNL employees. Table 5.8 is also incomplete and difficult to 

use, in relation to discrimination between exposures during the various periods of time and the rooms used in the

installation.

NIOSH Response: 

SC&A Reply: 

 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

Revision No. 

0 (Draft) 

Document No. 

SCA-TR-SP2010-0002 

Page No. 

82 of 83 

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. 

Issue 12: Failure to Provide Sufficient Guidance for Unmonitored Workers 

SC&A Finding: The TBD fails to provide guidance on how to calculate doses to workers without a complete 

description of the monitoring programs (Table 5.1), and on how to assign monitoring results to specific 

radionuclides and compounds. The TBD admits that, for many of the radionuclides, there is no specific information 

on the compounds with which they may have been associated. 

Insufficient guidance is provided on estimating internal doses for unmonitored workers. The information on 

bioassay programs is incomplete, as well as the list of radionuclides and compounds handled at the facility during 

the different time periods and in different locations. The TBD suggests that unmonitored workers should be 

assessed using coworker data and the tolerance levels, if there is evidence that they worked with uncontained 

radioactive materials; otherwise, environmental data should be used. This suggestion cannot be followed using the 

information available in the TBD. 

NIOSH should revise the site profile document to provide information sufficient for proper dose reconstruction, 

particularly for unmonitored workers.

NIOSH Response: 

 

SC&A Reply: 

 

Work Group Actions: 

Board Action: 
Effective Date: 

January 22, 2010 

Revision No. 

0 (Draft) 

Document No. 

SCA-TR-SP2010-0002 

Page No. 

83 of 83 

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. 

Issue 13: Inadequate Coverage of Occupational Environmental Dose 

SC&A Finding: Section 4.0 of ORAUT-TKBS-0049, Occupational Environmental Dose, is incomplete and should 

be revised to provide a more comprehensive description of the historical environmental dose to workers at LBNL. 

The deficiencies and omissions are such that inadequate guidance is provided for dose reconstructors. 

NIOSH assumes that the gamma and neutron environmental exposure is primarily from accelerators and, thus, using 

the maximum measured value from the onsite and fence-line monitors for a given year would be claimant favorable. 

NIOSH fails to discuss the possible exposure of unmonitored workers from irradiators. In particular, the Co-60 

irradiator housed in Building 74 may have been capable of higher doses at locations at distances less than those to 

the site perimeter or onsite monitoring locations (LBNL 1995a). 

Table 4-2, “Maximum site-wide annual median intakes (Bq/yr) via inhalation,” contains the NIOSH best estimates 

of annual intakes. Except for tritium and C-14, the values in the table are based on gross alpha and beta measured 

values from the site environmental program. 

While this may be a conservative assumption relative to the effective dose equivalent (EDE), this may not be 

claimant favorable for specific organ doses. For example, for exposure to I-131, where the committed dose 

equivalent per unit intake for the thyroid is almost two orders of magnitude greater than for Sr-90, the dose to the 

thyroid would be grossly underestimated. Given the wide range of radioisotopes used at LBNL, NIOSH should 

present a more claimant-favorable approach to dose reconstruction for radionuclides whose intakes were determined 

from gross alpha and beta measurements. 

NIOSH Response: 

 

SC&A Reply: 

 

Work Group Actions: 

Board Action: