INL Issues Matrix – March 2016 Version 1 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

Table 1. INL SEC 0219: Compilation of SC&A Review Issues, Comments, and Recommendations

No. Description References Notes & Additional Comments

Issue A: Test Area North (TAN) – Scope of Review: (1) Applicability of ORAUT-OTIB-0054 (OTIB-0054 or ORAUT 2013) and Tables 5-22 and 

5-23 of the site profile internal dosimetry technical basis document (TBD) to the performance of internal dose reconstruction for facilities 

that handled and stored spent and irradiated fuel; (2) unique circumstances associated with the Aircraft Nuclear Propulsion (ANP) program; 

(3) completeness of the external dosimetry data at the various TAN facilities.

A-1 “...we do not believe we can consistently assign the external 

dosimetry monitoring data to the different work areas, operations, 

and campaigns within TAN, at least given the data we reviewed. The 

implications are that NIOSH might not be able to build coworker 

models for many of the different subdivisions at TAN. This could be 

an important SEC [Special Exposure Cohort] issue for TAN, because 

the types of activities at TAN were so diverse that different coworker 

models might be required.”

Review of NIOSH Strategy for 

Reconstructing Internal Doses to 

Workers at Test Area North, SC&A 

Report SCA-TR-2015-SEC0074A, 

Revision 0, draft, September 28, 2015. 

Executive Summary.

Resolution might require 

additional data capture.

SC&A comment: At the November 

11, 2015, Work Group (WG) 

meeting, NIOSH indicated that 

they only sampled the dosimetry 

data for TAN and that much more 

remains (pp. 170 & 176 of 

November 11, 2015, WG 

transcript).

The only area that they made a

concerted effort to try and get all 

of the dosimetry was associated

with the Chemical Processing Plant 

(CPP), and that was just between 

1963 and 1974.

They also indicated that they do 

not intend to develop an external 

coworker model for the Idaho 

National Laboratory (INL) (p. 173

of November 11, 2015, WG 

transcript). 

The WG agreed that this is a lower 

priority issue compared to some of 

the other areas of concern (p. 177

of November 11, 2015, WG 

transcript).
INL Issues Matrix – March 2016 Version 2 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

A-2 “For neutron dosimeters, the data appear to be spotty. If it can be 

assumed that neutron dosimeters were only assigned to individuals 

whom the radiation protection staff deemed at risk of neutron 

exposure, then the temporal gaps seen in the available neutron 

dosimetry data might indicate that there was no need for neutron 

monitoring because there was no source of neutron exposure 

potential. Investigation into the types of activities and experiments 

conducted during the periods of time for which no neutron 

dosimeters were found might be needed to determine if neutron 

exposure was or was not likely.”

Ibid. (A1), Section 5.2. Ibid. (A1).
INL Issues Matrix – March 2016 Version 3 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

A-3 “Given the unique features of the aircraft nuclear propulsion 

systems [ANPs] tested at INEL [Idaho National Engineering 

Laboratory] and their equally unique mixtures of radionuclides that 

were released, SC&A believes that ‘conventional’ reactors and their 

modeled values may not be appropriate for deriving internal dose 

estimates to INEL workers.” Therefore, for spent nuclear fuel 

associated with ANP, use of ORAUT-OTIB-0054 is inappropriate for 

the following reasons:

Ibid. (A1), Section 4.0. –

• “...highly enriched uranium fuel (enrichments in excess of 90%) 

would contain very little Pu-239 and other actinides related to 

U-238 neutron interactions. Hence, it is unlikely that a substantial 

portion of TAN irradiated fuel would contain mixes of actinides 

that resemble the default mixes employed in Tables 5-22 and 

5-23 of the internal dosimetry TBD. We confirmed these concerns 

by performing a series of simplified ORIGEN runs. Hence, we 

believe that these matters could represent potential SEC issues.”

Ibid. (A1), Executive Summary. –

• “Wafer-thin ribbons of UO2 and absence of cladding ensured high 

release fraction by recoil and/or diffusion of many FPs [fission 

products]. Most notably are volatile radionuclides (iodine, 

cesium, etc.).”

J. Mauro PowerPoint presentation at 

November 10, 2015, INL Work Group 

Meeting, showing results of report 

SCA-TR-2015-SEC0074A.

–

• “Release and depletion of FPs from fuel elements must further be 

assumed by the fact that for some IETs [Initial Engine Tests], 

intentional fuel failure (and unintentional fuel failure) resulted 

from temperatures exceeding 3,200°F.”

Ibid. –
INL Issues Matrix – March 2016 Version 4 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

A-4 “Independent analyses of airborne emissions associated with the 

major IETs, as performed by SC&A under contract to CDC, revealed 

that the DOE [Department of Energy] significantly underestimated 

the airborne emissions for the IETs with the largest airborne 

emission.” “Outdoor exposures associated with releases from the 

ANP need to consider the results of CDC’s investigations into these 

source terms.” 

Ibid. SC&A comment: At the November 

11, 2015, WG meeting, NIOSH was 

tasked to prepare a white paper 

on IET #10.

NIOSH indicated that they will not 

be prepared to discuss IET #10 at 

the March 1, 2016, WG meeting, 

as it has been delayed due to 

other priorities. 

Issue B: Central Facilities Area (CFA) – Scope of Review: Evaluate available survey data for the CFA, both during operations and prior to 

demolition and dismantlement, to determine the actinide-to-Sr-90 and actinide-to-Cs-137 ratios and compare these ratios to the values in 

Tables 5-22 and 5-23 of the internal dosimetry TBD (ORAUT-TKBS-0007-5).

B-1 “Analyses of the smear data and soil sample results...indicates at 

least general agreement in the magnitude of the maximum 

contamination ratios for uranium and plutonium given in Tables 5-22 

and 5-23 of ORAUT-TKBS-0007-5.... However, there are several 

limitations in the data used.” 

1. The CFA-669 Hot Laundry operated from 1950 until 1981. The 

survey data found were very limited and from 1954–1956, the 

period of early operations.

2. The survey data are written given in units of counts per minute 

(cpm). While assumptions regarding the equipment and 

detection efficiencies can be made based on the time period 

and equipment used at that time, it may be more beneficial to 

use more recent and well-documented survey information. 

3. The soil samples were collected during decontamination and 

decommissioning (D&D) operations from a trench and berm 

formed during the excavation of the 8-inch contaminated 

sanitary sewer line on the north side of CFA-669. It may be more 

useful to use more sample results, particularly those obtained 

during the characterization survey, prior to D&D.

Evaluation of Available Survey Data for 

the Central Facilities Area at Idaho 

National Laboratory, SCA-SEC-2015-

0074-B, Revision 0, draft, September 

28, 2015. Section 4.0. 

SC&A comment: Data capture in 

January 2016 sought relevant 

information. The items recovered 

for the Site Research Data Base 

(SRDB) may provide some insight

when available. — We still have 

the Seattle and return INL data 

captures coming up later in 2016. 
INL Issues Matrix – March 2016 Version 5 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

Issue C: Test Reactor Area (TRA) – Scope of Review: Does the methodology of ORAUT-OTIB-0054 (Fission and Activation Product Assignment 

for Internal Dose-Related Gross Beta and Gross Gamms Analysis) adequately model the reactor characteristics and operations of the Test 

Reactor Area (TRA)?

C-1 “The MTR [Materials Test Reactor]...ran for a period of time with 

plutonium rather than uranium fuel.... It is not clear which, if any, of 

the nine OTIB-0054 cases...would adequately envelope this 

situation.” 

“The issue of whether OTIB-0054 adequately envelopes the MTR 

when fueled with plutonium merits further investigation and 

discussion.”

NIOSH SEC-00219 Test Reactor Area 

Modeling, SC&A Report SCA-SEC-2015-

0074-C, Revision 0, draft, September 

28, 2015. Section 3.2. 

SC&A comment: Discussed pp.

132–144, November 11, 2015, WG 

transcript. 

SC&A is tasked to develop a 

prioritized list of the 52 reactors at 

INL, to ascertain if OTIB-0054 

methods are bounding and 

sufficiently accurate. That report 

will be delivered in March 2016. 

Issue D: Chemical Processing Plant (CPP; 1963–1974) – Scope of Review: Evaluate if the revised SEC class definition may unintentionally 

exclude workers from the SEC class due to contemporaneous dosimetry requirements. 

D-1 “Observation 1: While the class definition provides the example of 

‘at least one film badge,’ SC&A has assumed that any evidence of 

monitoring during the latter SEC period (3/1/1970–12/31/1974) will 

satisfy the intended criteria.” [i.e., one badge, one area  one 

badge, multiple areas (3/1/1970)  one badge, one area (12/1974)]

Evaluation of the Revised SEC Class 

Definition for the Idaho National 

Laboratory Chemical Processing Plant 

(1963–1974), SCA-SEC-2015-D, 

Revision 0, draft, September 28, 2015. 

Section 2.1. 

SC&A comment: All 6 observations 

related to this issue were

discussed at the November 11, 

2015, and January 15, 2016, WG 

meetings. Review of the remaining 

18 cases in coordination with 

NIOSH is complete. Issue D was

the focal point of the March 1, 

2016, WG meeting.

D-2 “Observation 2: SC&A identified a single claim that contained in-vivo 

dosimetry related to CPP, but did not have related external 

dosimetry. It is recommended that this claim be included with the 

claims requiring additional data capture at INL.”

Ibid. Section 2.1. –
INL Issues Matrix – March 2016 Version 6 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

D-3 “Observation 3: Clarification is warranted to establish how 

‘temporary’ and/or ‘visitor badges’ are utilized in the 

implementation of the class definition during the latter SEC period 

(3/1/1970–12/31/1974).”

Ibid. Section 2.1. SC&A comment: NIOSH clarified at 

the November 11, 2015, WG 

meeting that temporary and 

visitor badges and location cards 

are adequate if the 250-day 

requirement is met. 

D-4 “Observation 4: Absent additional information to the contrary, 

dosimetry associated with ‘CADRE’ should be considered CPP for the 

purposes of determining SEC eligibility. Similar to the CPP dosimetry 

records, it is important to establish that ‘CADRE’ badging records 

have all been captured from INL.”

Ibid. Section 2.2. 

CADRE Evaluation (Area Code 71) for 

consideration as part of the Idaho 

Chemical Processing Plant Special 

Exposure Cohort. NIOSH. February 25, 

2016.

SC&A comment: NIOSH clarified at 

the November 11, 2015, WG 

meeting that it will reach out to 

site personnel to clarification.

NIOSH releases findings on 

‘CADRE’ issue in February 25, 

2016, memo.

Issue was discussed at March 1, 

2016, WG meeting and consensus 

was reached that ‘CADRE’ refers to 

Emergency Response Center 

personnel who were not likely at 

CPP during the SEC period. Issue 

was closed by WG.

Note: the issue of monitoring 

practices for other emergency 

response personnel that may have 

entered CPP (such as “firemen”) is 

pending NIOSH response.
INL Issues Matrix – March 2016 Version 7 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

D-5 “Observation 5: NIOSH should consider the additional claims 

identified by SC&A as candidates for upcoming data-capture efforts 

at INL to assure that all monitoring records are complete for these 

workers.” 

Ibid. Section 3.0. SC&A Comment: Supplemental 

dosimetry records were received 

from the site in December 2015. 

SC&A delivered the white paper: 

“Evaluation of Claims with 

Supplemental Dosimetry 

Requests.” This white paper was 

discussed at the January 2015 WG 

teleconference (see Sub Issue DD, 

below, for noted observations). 

D-6 “Observation 6: A review of the ten claimants NIOSH identified as 

requiring follow-up research and data capture at INL indicates a 

thorough search to identify potential workers who were exposed at 

the CPP for which the required dosimetry currently is not available. 

SC&A agrees with NIOSH’s assessment that these claimants warrant 

further investigation.”

Ibid. Section 4.0. See response to Item D-5 and Sub 

Issue DD. 

Sub Issue DD: Chemical Processing Plant (CPP; 1963–1974) – Evaluation of Claims with Supplemental Dosimetry Requests.

DD-1 “Observation 1: Five of the 18 claims contained a listing of a ‘box’

and ‘record number’ for the relevant claimant dosimetry records. In 

one of those five claims, it appears that an ‘area exposure report’ 

related to the claimant could not be located. It should be noted that 

NIOSH has undertaken a comparison of monthly Health Physics (HP) 

reports versus the available dosimetry printouts, and NIOSH 

concluded the records available (at least for CPP in the 1963–1970 

timeframe) are complete for the purposes of SEC administration.” 

Evaluation of Claims with Supplemental 

Dosimetry Records, SCA-2016-SEC0074F, Revision 0, draft, January 12, 

2016, Section 2.1.

SC&A Comment: NIOSH noted that 

the particular missing record was 

related to MTR and prior to the 

SEC period, this confirmed SC&A’s 

assertion stated in the white 

paper. On the issue of missing 

records in general, NIOSH 

reaffirmed that they feel they 

have a complete set of CPP 

dosimetry for the purposes of SEC 

implementation. (INL WG 

teleconference, January 15, 2016, 

pp. 87–94)
INL Issues Matrix – March 2016 Version 8 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

DD-2 “Observation 2: SC&A identified evidence (specifically an in-vivo 

record) of a claimant entering CPP in 1966 that did not have 

associated external dosimetry for CPP.” 

Ibid. Section 2.2. SC&A Comment: NIOSH identified 

a set of visitor badges associated 

with this claimant for MTR and the 

Special Power Excursion Reactor 

Test (SPERT) but no evidence of

monitoring at CPP. It is NIOSH’s 

position that this in vivo record at 

CPP is likely a typo. (INL WG 

teleconference, January 15, 2016, 

p. 55)

Issue also briefly discussed during 

March 1, 2016, WG meeting; no 

new information was provided. 

DD-3 “Observation 3: Case #3 provides an example where internal 

monitoring indicates CPP during the latter SEC period (1970); 

however, there is no external monitoring at INL after 1960.” 

Ibid. Section 2.3. SC&A Comment: NIOSH obtained 

visitor badges at CPP for this 

individual which correspond to the 

internal monitoring result 

identified in Observation 3. (INL 

WG teleconference, January 15, 

2016, pp. 85–86)

March 1, 2016, WG: NIOSH 

identified an INL policy, which was 

not to index some visitor cards 

that reported zero dose in the 

general timeframe of 1968–1974. 

NIOSH has captured all visitor 

cards for CPP during this time and 

is working to index visitor cards for 

the remaining site areas 

(projected to take 6–9 months).
INL Issues Matrix – March 2016 Version 9 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

DD-4 “Observation 6: The ‘annual dose summary’ report for Case #6 

indicates that the claimant was monitored from 1963 to 1966; 

however, individual dosimetry reports are not available to ascertain 

the exact work location during this time.”

Ibid. Section 2.6. SC&A Comment: NIOSH indicated 

that they have searched all 

available temporary and film 

badge reports at CPP for this 

individual and did not locate any 

records. However, NIOSH also 

stated they have not searched 

through temporary and/or visitor 

records at other INL areas where

the Energy Employee may have 

been monitored but not captured 

in the DOE response. (INL WG 

teleconference, January 15, 2016, 

pp. 111–116)

March 1, 2016, WG: This issue was 

not specifically discussed. 

Resolution pending capture and 

indexing of all visitor/temporary 

badge records for INL (projected 

6–9 months). 
INL Issues Matrix – March 2016 Version 10 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

Issue E1: Fission and Activation Product (FAP) Bioassay Indicator Radionuclides – Scope of Review: Analyze FAP indicator ratios, actinide-toFAP ratios, and special situations/bioassays.

E1-1 “FAP intakes assigned using NIOSH’s recommendations in ORAUTOTIB-0054...based on Sr-90 intake values are generally (but not 

always) equal to, or greater than, those derived from actual 

measured values.”

SC&A’s Evaluation of the NIOSH 

Evaluation Report Proposed Use of 

Fission-Activation Product Bioassay 

Indicator Radionuclides (in Conjunction 

with ORAUT-OTIB-0054 and ORAUTTKBS-0007-5) for Assessment of 

Fission-Activation Product and Actinide 

Intakes at Idaho National Laboratory, 

SCA-SEC-2015-0074-E1, Revision 0, 

draft, October 26, 2015. Executive 

Summary.

SC&A comment: It needs to be 

determined if records of analyses 

of dissolver contents are available, 

preferably for a variety of INL 

reactor fuel elements and also fuel 

elements from offsite reactors.

Data capture in January 2016 

sought relevant information. The 

items recovered for the SRDB may 

provide some insight when 

available. — We still have the 

Seattle and return INL data 

captures coming up later in 2016. 

SC&A tasked at the November 11, 

2015, WG meeting to update the 

Issue E1 report when the relevant 

data are obtained.

March 1, 2016: process of 

capturing relevant data still 

ongoing.

E1-2 “The Cs-137/Sr-90 intakes are not always 1:1 as assumed in ORAUTOTIB-0054...and ORAUT-TKBS-0017-5 ...; frequently, large variations 

in the ratio exist. This brings into question the validity of using an 

indicator radionuclide when deriving FAP and actinide intakes, 

because the assigned intakes/doses are dependent on the indicator 

radionuclide bioassayed at the time. This may be the most important 

result of this study because a Cs-137/Sr-90 value of approximately 

1:1 is one of the cornerstones for use of the ratio method at the 

INL.”

Ibid. SC&A comment: Further INL 

document research is needed to 

evaluate NIOSH’s recommended 

ratio values, especially for 

actinides and Cs-137/Sr-90.

See response to Item E1-1. 
INL Issues Matrix – March 2016 Version 11 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

E1-3 “Actinide intakes assigned using NIOSH’s recommendation in 

ORAUT-TKBS-0017-5..., Table 5-22 based on Sr-90 intake values, or 

Table 5-23 based on Cs-137 intake values, are sometimes 

significantly less than those derived from actual measured values.”

Ibid. SC&A comment: Resolution is 

contingent on revised Issue E1 

report.

E1-4 “It is difficult to evaluate when ‘special’ (situations where actinides 

were not tied to a fission product in a given ratio) bioassays were 

needed, if they were performed, and if they are indicated as such in 

the bioassay records.”

Ibid. SC&A comment: It needs to be 

determined if special or nonroutine bioassays were associated 

with special exposure events...or, 

if instead, the terms were applied 

to the priority of processing over 

“routine” bioassays.

Future data capture will seek to 

address these concerns.

See response to Item E1-1. 
INL Issues Matrix – March 2016 Version 12 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

Issue E2: Fission and Activation Product (FAP) Bioassay Worker Records – Scope of Review: Determine, through a semi-random sample of 

claimants, if sufficient workers records containing FAP bioassay (in-vitro and in-vivo) results are available to assign intakes and resulting 

doses from FAP.

E2-1 Observation 1: SC&A believes that coworker models should be 

developed for the period of 1967–1970 for each relevant area under 

consideration.

Evaluation of Internal Monitoring for 

Fission and Activation Products Among 

INR Claimants (1949-1970), SCA-SEC2015-0074-E2, Revision 0, draft, 

October 26, 2015. Executive Summary.

Response to Observations presented in 

“Evaluation of Internal Monitoring for 

Fission and Activation Products among 

INL Claimants (1949-1970),” SCA-SEC2015-0074-E2, Revision 0. NIOSH, 

February 25, 2016.

SC&A comment: Issue E2 

discussed pp. 221–244 of the 

November 11, 2015, WG meeting.

Tasking from the November 11, 

2015, WG meeting: NIOSH to 

evaluate the need for additional 

coworker analysis.

February 15, 2016: NIOSH releases 

white paper response to coworker 

requirements.

March 1, 2016: Issue E2 was 

briefly discussed at WG meeting. 

NIOSH agrees that further 

coworker models are required for 

the various facilities of INL.

E2-2 “Observation 2: Based on SC&A’s review of sampled claimants, it is 

not apparent that the lack of internal monitoring data is indicative of 

a lack of internal exposure potential. Given the uncertainty in 

establishing work areas, activities and ultimately exposure potential

for claimants (particularly in the early years), it is recommended that 

coworker models be evaluated and developed for workers who were 

unmonitored, but likely should have been monitored during all 

periods for which such exposures are possible.”

Ibid. SC&A comment: See response to 

Item E2-1.

E2-3 “...it appears there are credible situations where it would be 

appropriate and claimant favorable to assign coworker intakes of 

FAPs and actinides to account for unmonitored portions of the 

claimants’ work history. Many of these examples predate the period 

currently identified by NIOSH as requiring coworker evaluations 

(1967–1970).”

– SC&A comment: See response to 

Item E2-1. 
INL Issues Matrix – March 2016 Version 13 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

Table 2. INL SEC 0219: Items under Investigation by SC&A

No. Description References Notes & Additional Comments

Item 1: Burial Grounds (1952–1970)

1-1 Evaluation of the adequacy of the contamination control program at 

the burial grounds. Evidence exists that a “strict” contamination 

control program was not in place. The burial grounds may have lacked 

adequate smear counting capabilities.

Pending. Subject of site data captures and 

worker interviews:

– January 25–28, 2016

– February 16, 2016

– February 23–24, 2016

– March 15–16, 2016

1-2 Radioactive waste was not specifically identified/labelled for most 

drums, boxes, and other containers (particularly in the early years). 

This would limit the ability for health physics staff to take proper 

precautions specific to the waste being handled.

Pending. See additional comments for 

Item 1-1. 

1-3 Waste was received from offsite sources, such as commercial, 

university, Atomic Energy Commission/Energy Research and 

Development Administration and military sources, which may not 

have been adequately identified or characterized.

Pending. See additional comments for 

Item 1-1. 

1-4 Concerns over the lack of priority being given radiation protection at 

the Burial Grounds as evidenced by a lack of management support, as 

well as the apparent conflict of interest for health physics staff who 

had the dual role of radiological protection and oversight of the actual 

operation of the burial grounds. 

Pending. See additional comments for 

Item 1-1. 

1-5 Questionable characterization of the robust nature of the health 

physics program given evidence of shortcomings involving radiological 

controls and also internal monitoring protocol for burial ground 

workers.

Pending. See additional comments for 

Item 1-1. 
INL Issues Matrix – March 2016 Version 14 SC&A – March 13, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a 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.

No. Description References Notes & Additional Comments

Item 2: Chemical Processing Plant (Pre-1963)

2-1 Inadequate internal dosimetry program at CPP to allow for the direct 

assessment of potential intakes of transuranic/actinide contaminants.

Pending. Subject of site data captures and 

worker interviews:

– January 25–28, 2016

– February 16, 2016

– February 23–24, 2016

– March 15–16, 2016

2-2 Inadequate contamination control program to limit “hot areas” to the 

actual process cells (similarities to conditions found at CPP during the 

proposed SEC period 1963–1974).

Pending. See additional comments for 

Item 2-1.