Working Draft 

FERNALD PLANT SITE PROFILE ISSUES MATRIX –

DRAFT PRELIMINARY SC&A ASSESSMENT 

Contract 200-2009-28555 

SCA-SP-IM2013-0045, Revision 0 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

October 2013 

Disclaimer 

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

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

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

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

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

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

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

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Page No.

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and redacted accordingly. Future versions of this issues matrix will not be freely distributed until further reviews for 

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Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/16/2013 Initial issue of a complete issues matrix incorporating information from previous 

versions, white paper issue reviews, memorandums, Work Group meetings, etc.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

3 of 26

NOTICE: This October 16, 2013, Issues Matrix has been reviewed for potential Privacy Act-protected information 

and redacted accordingly. Future versions of this issues matrix will not be freely distributed until further reviews for 

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INTRODUCTION

The attached “Fernald Plant Site Profile Issues Matrix – Draft Preliminary SC&A Assessment” 

is a rebaselined issues matrix for use by the Work Group; it is provided in both Microsoft 

Word® and Excel® formats. It summarizes those issues that SC&A believes are still open 

following the addition of two classes of workers to the Special Exposure Cohort (SEC) at the 

July 2013 Advisory Board meeting in Idaho Falls, Idaho.

In developing the matrix, SC&A reviewed the transcripts from 16 successive Work Group 

meetings held from August 2007 to July 2013, as well as numerous white papers and 

memorandum reports related to SEC deliberations of the Work Group during that period. The 

matrix incorporates several unresolved findings from SC&A’s site profile review, delivered to 

the Advisory Board in November 2006; that report identified 33 original findings. It also 

considers issues that emerged from Work Group discussions of our review of the SEC-00046 

Evaluation Report (ER), which was delivered to the Advisory Board in June 2007. Our SEC ER 

review identified 30 original findings, which were eventually merged into six general categories 

as a result of Work Group deliberations.

Because Fernald issues were some of the most difficult encountered under the EEOICPA and the 

issues resolution process spanned such a long period, we believe that the Work Group would be 

best informed by a full accounting of the original issues and how SC&A determined their current 

status. To that end, we have also provided to the Work Group the Excel file titled, “Fernald 

Issues Matrix - 131015 FINAL.xlsx.” This “full matrix” captures the results of the site profile 

and SEC findings resolution process that SC&A used to determine the current open issues. It is 

our hope that the Work Group finds this helpful in charting a path forward on resolving the 

remaining Fernald issues.
Effective Date:

Updated October 16, 2013

Revision No.

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Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

TBD

1

The list of facilities in

which thorium-232 was 

processed, the time 

periods of thorium 

processing, and the 

thorium production data 

shown in the TBD have 

significant gaps. Entire 

periods of processing and 

plants in which the work 

was done have been 

missed. These gaps may 

affect the feasibility of 

dose reconstruction for 

workers for certain time 

periods and in certain 

plants.

This is identical to SEC Issue 4.3-5. NIOSH responded as 

follows: Additional thorium production documents have been 

located and interviews have been conducted with people 

knowledgeable of the thorium processes at FMPC. The 

knowledge gaps have largely been eliminated in the draft 

revision of ORAUT-TBKS-0017-5. The current default 

thorium intake recommendations are applicable to any 

location and time after 1954 in which thorium exposure is 

deemed reasonable... Knowledge of the process and locations 

of processes is now comprehensive, based on interviews, 

documents, and additional research... See the Thorium 

Timeline with AA 2-29-07.doc in the following directory 

O:\Document Review\AB Document Review\Fernald.

All plants for 1955 and 1966 and plant 6 for 1960 were 

identified by the work group as the buildings and the time 

periods that will be used to create the database and 

demonstrate its completeness and reliability for performing 

dose reconstructions. The work group agreed that it was not 

necessary to create such a compendium of data and analyses 

for all buildings and work years, given the magnitude of the 

effort, and that the selected years should provide the evidence 

that such a coworker model can, in fact, be developed and 

implemented.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of th-232 with sufficient 

accuracy from DWE data.

SC&A suggests closing this 

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air 

concentration data.

This finding pertained mainly to 

the availability of air sampling 

data pre-1968.

The NIOSH coworker model for 

thorium-232 intakes based on 

activity measurements of the

gamma–emitting progeny Pb-212 

and Ac-228 is under discussion 

by the Fernald WG, last 

discussed at the July 1, 2013, 

WG meeting.

This issue is no longer relevant 

to the post-1978 coworker 

model, which is based on 

bioassay data. SC&A’s

Completeness and Adequacy of 

Thorium In-Vivo Records 

(1979–1989), November 2012:

It is clear from the 

completeness analysis that 

there are no significant 

temporal gaps in the in-vivo 

data reported in nCi Ac-227 

and Pb-212 that might 

preclude its use in a 

coworker model.
Effective Date:

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

TBD

2

Air concentration data for 

thorium in the TBD are 

sparse and incomplete, 

though considerably more 

data are available in the 

NIOSH Site Research 

Database. The TBD 

contains no thorium-232 

bioassay or in-vivo data.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

SC&A suggests closing this 

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air 

concentration data.

TBD

3

Thorium intakes due to 

fugitive emissions and 

resuspension in 

production areas may 

have been significant for 

some locations and 

periods. The TBD does 

not address the issue of 

fugitive emissions in 

production areas. 

Furthermore, the TBD 

does not provide a method 

to estimate resuspension 

intakes in the pre-1986 

period and for those 

workers without lapel air 

sampling in the post-1986 

period.

This is identical to SEC Issue 4.3-8. NIOSH responded as 

follows: Many thorium air samples, including GA samples 

from inside the plants, are available. These GA samples from 

operating areas are sure to bound the concentrations in nonoperating areas. A series of contemporary time and motion 

studies are being considered. These studies characterize 

intakes for people in clerical areas inside the operating 

facilities. The Battelle model based on air sample data is also 

available. Dose reconstruction is possible, the best method is 

still being considered... An approach to thorium dose 

reconstruction has been devised using newly available 

thorium exposure assessments. See the DWE Reports white 

paper in the following directory: O:\Document Review\AB 

Document Review\Fernald.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

SC&A suggests closing this 

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air 

concentration data.
Effective Date:

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

TBD

4

The guidance in the TBD 

regarding exposures from 

redrumming thorium is 

not well founded and is 

not claimant favorable.

This is identical to SEC finding 4.3-7. NIOSH responded as 

follows: See comments in response to Finding 4.3-1 and 4.3-

6 above... Guidance will be claimant favorable and in the 

TBD.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of th-232 with sufficient 

accuracy from DWE data 

SC&A suggests categorizing 

this finding as "in abeyance." 

Redrumming was still an issue 

for the post-1978 period. We 

discuss redrumming in 

SC&A’s Completeness and 

Adequacy of Thorium In-Vivo 

Records (1979–1989). 

Basically, we don't know who 

performed redrumming, which 

is why the coworker model 

must be applied to all 

potentially exposed workers at 

the 95th percentile. NIOSH has 

agreed to do this, but we have 

yet to see the formal 

implementation.

TBD

5

The TBD has not 

evaluated exposures due 

to thorium fires. The 

TBD has also not 

evaluated other thorium 

incidents or failures of 

industrial hygiene.

(ABRWH 2007, pg. 220) And it’s well documented, and it’s 

also accepted by NIOSH that small fires, spills, explosions 

were commonplace. And yet it is unlikely that most of the air 

sampling data that you’re compiling will necessarily reflect 

them, those radiological incidents. 

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

SC&A suggests closing this 

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air 

concentration data.
Effective Date:

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Finding Text History SC&A NIOSH Response Status

TBD

6

The approach suggested 

for estimating thorium 

intakes does not reflect 

the history of production 

or the available thorium 

air concentration data. It 

is likely to result in 

significant underestimates 

of internal dose from 

thorium.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

.July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

SC&A suggests closing this 

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air 

concentration data.
Effective Date:

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Finding Text History SC&A NIOSH Response Status

TBD

7

The TBD does not specify 

a method for estimating 

doses in the raffinate 

streams, which are 

uranium-poor, from ore 

processing in Plant 2/3. 

These doses may be very 

difficult to calculate, 

especially for high-grade 

ores, notably pitchblende 

ore from Congo.

This pertains to SEC finding 4.2-2 and Primary SEC Issue 

#4: “Review of radon breath data for adequacy for 

reconstructing doses due to the inhalation of Ra-226 and Th230.”

October 14, 2008 – NIOSH responded: NIOSH has radon 

breath analyses for raffinate transfer operations and air 

sample data in the Plant 2/3 raffinate handling area sufficient 

to bound possible intakes and allow claimant-favorable dose 

reconstructions of sufficient accuracy. The NIOSH approach 

is contained in ORAUT-RPRT-0052 (ORAUT 2011). Report 

52, pp. 24–25: Transfer of drummed K-65 raffinate to Silos 1 

and 2 late 1952–June 53; radon breath data available. Q-11 

transfer 1954-1957; subsumed in SEC. 

The concern for the raffinate streams can be bounded by the 

extensive “radon breath analyses-to-radium deposition” 

performed during the K-65 raffinate drum disposal operation. 

In addition, confirmatory air monitoring data in Plant 2/3 

specific to the raffinate operations provide assurance that 

exposures are adequately bounded. The raffinates were wet 

(minimizing air contamination production) and enclosed in 

process piping.

Other uranium daughters in addition to Ra-226 intake can be 

adequately bounded by rationing to Ra-226, using the isotopic 

analyses of the silo contents.

A detailed discussion of SEC Issue 4 took place at the April 

19, 2011, WG meeting (ABRWH 2011), where SC&A agreed 

that NIOSH's methods were bounding and sufficiently 

accurate.

SEC recommends this issue be 

changed to "in abeyance" 

pending revised TBD.
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Finding Text History SC&A NIOSH Response Status

TB

D

8

Workers who may have 

worked with raffinates 

may be missed by the 

protocol specified in Vol. 

5 of the TBD. The 

guidelines for determining 

which workers were 

exposed to raffinate dusts 

are too restrictive and 

place far too great a 

reliance on completeness 

of records for job 

assignments, or in the 

alternative, place the 

burden of proof on the 

claimant. They have not 

been adequately justified 

by measurements and are 

not claimant favorable.

See response to Finding #7. See response to Finding #7.

TBD

9

The data on trace 

contaminants in RU in the 

Fernald TBD are 

incomplete and appear to 

be incorrect. Different 

official documents have 

very different values for 

various aspects of RU 

data, including production 

and contamination. The 

contradictions have not 

been sorted out in the 

TBD.

This finding is the same as SEC finding No. 4.1-6. NIOSH 

responded as follows:

Some production data are admittedly conflicting. 

Since dose reconstruction does not depend directly on 

production data, sufficient data are available to 

enable a bounding estimate based on the ratio of RU 

contaminates to the uranium intake determined from 

the uranium urinalyses. Recommended defaults have 

been chosen that adequately bound all of the 

operational data. The shipment(s) from Paducah 

Gaseous Diffusion Plant were of short duration, the 

increased hazards were recognized and adequately 

controlled, and recognized as doubling the total 

inventory of RU contaminants at FMPC, which in turn 

was factored into the default assumptions.

After many white paper exchanges and deliberations, 

NIOSH demonstrated that they could place a plausible 

upper bound on intakes from three principal RU 

constituents.

SC&A recommends finding be 

changed to " in abeyance" 

pending revised TBD. 
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Finding Text History SC&A NIOSH Response Status

TBD

10

The radionuclide list for 

RU in the TBD is 

incomplete. Furthermore, 

the concentrations of trace 

radionuclides in the 

raffinates, which are much 

higher than those in the 

feed material, are not 

adequately discussed.

This finding is the same as SEC finding No. 4.1-5 and SEC 

Primary Issue 3. NIOSH responded as follows:

Adequate material flow information is available to 

perform bounding analyses – with the recommended 

defaults being at least an order of magnitude higher 

than the average observed contaminant concentration 

in the processed materials...

...Any external dose associated with U-232 and decay 

products would be adequately monitored by the 

external dosimetry device.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from three principal RU constituents.

Subsumed into SEC pre-1979. Coworker model applicable 

1979–1986 when WMCO took over M&O from NLO and for 

non-SEC claimants.

SC&A notes that while NIOSH 

has provided a method for

bounding intakes from Pu, Np237, and Tc-99, other nuclides 

such as Am-241 and thorium 

isotopes are not included in the 

model and were not discussed 

in WG meetings. SC&A 

recommends finding remain 

open and that WG discuss 

incorporating these other RU 

constituents into the coworker 

model.

TBD

11

The suggested approach 

for RU dose estimation in 

the TBD is claimant 

favorable for many RU 

workers, but not claimant 

favorable for others and 

for some periods; it is not 

based on an evaluation of 

the available data.

This is similar to SEC Primary Issue #3.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from RU constituents. 

Subsumed into SEC pre-1979. Coworker model applicable 

1979–1986 when WMCO took over M&O from NLO and for 

non-SEC claimants.

SC&A recommends finding be 

changed to “in abeyance" until 

agreed upon method is 

incorporated into the TBD.

TBD

12

The TBD notes that 

uranium batches with 

enrichment greater than 

2% were processed at 

Fernald. NIOSH’s 

assumption of 2% 

enriched uranium is 

claimant favorable most 

of the time, but not for 

This relates to SEC finding 4.1-4. NIOSH responded as 

follows:

The dose conversion factor for U-234 is applied to all 

uranium intakes. This results in a bias that is 

favorable to the claimant. The operational 

descriptions in the TBD are correct.

11/11/07 – SC&A to review sample case along with 

Closed.
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Finding Text History SC&A NIOSH Response Status

periods and batches when 

uranium of higher 

enrichments were 

processed.

default approaches (1% prior to 1964 and 2% after 1964). 

NIOSH to provide documentation to support the statement 

that most of the ‘enriched’ material was very slightly 

enriched (slightly greater than 0.71% U-235).

3/18/08 – The following documents were provided to 

substantiate the assumptions: 8/7/2007 interview [redact] 

and [redact] (ORAUT 2007a); 9-11-07 interview with 

[redact] and [redact] (ORAUT 2007c); 8-30-07 interview 

with [redact] and [redact] (ORAUT 2007b).

10/28/08 (pp. 200–217) – SC&A found documentation 

indicating enrichments of 3%–10%. NIOSH 

acknowledges that there were exceptions to normal work. 

SC&A agrees dose can be reconstructed if the enrichment 

handled is known, but questions if those workers can be 

identified. NIOSH proposed assigning everyone 2% 

unless there is documentation indicating otherwise. After 

lengthy discussion, the Board accepted the 2% position 

and closed the finding.
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Finding Text History SC&A NIOSH Response Status

TBD

13

Female employees were 

not monitored for long 

periods at Fernald, even 

though at least some of 

them were at some risk of 

internal intakes of 

radionuclides.

This is similar to SEC finding 4.5-5. NIOSH responded as 

follows:

The doses to those female workers who were not 

monitored during two operating periods can be 

reconstructed by at least three methods. They are: 

(1) If the worker in question is doing the same or very 

similar job during periods when she is monitored, that 

dose could be used to adjust the missing dose when 

she wasn’t monitored; (2) Workers who were doing 

the same job and were monitored at the time the 

female wasn’t, could have an equivalent dose assigned 

to the unmonitored worker, and (3) Assignment of the 

missed dose as stated in the TBD-Vol 6 of 500 

mrem/yr for the missing time periods, which is known 

to be extremely claimant favorable.

Discussed at 8/8/07 meeting – SC&A raised the concern that 

women who worked in the laundry were not monitored but in 

some cases handled highly contaminated laundry. NIOSH 

stated assigning them a 500 mrem dose exceeds recorded 

doses by operators which is claimant favorable. SC&A states 

default dose does not address the following: (1) the shallow 

dose to the skin, (2) the extremity dose to the forearm/hands, 

and (3) potential internal exposure from airborne 

contamination created by handling contaminated items.

Suggested linking the internal component to SEC Finding 4.1-

3.

Discussed at 11/13/07 meeting. Decided this was an issue 

isolated to a few individuals and should be evaluated on a 

case-by-case basis in DR.

4/22/09 meeting: Issue closed. Decided three methods 

suggested are sufficient.

Closed
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Finding Text History SC&A NIOSH Response Status

TBD

14

The TBD does not address 

the extremely high 

uranium dust 

concentrations, which 

were present at Fernald 

under a variety of 

circumstances, and their 

effect on dose 

reconstruction. Particle 

size and solubility 

assumptions for workers 

who experienced chip 

fires should be examined.

Related to Primary SEC Findings 1, 2a, 2b, which have been 

closed.

This finding was logged at a time when NIOSH had proposed 

using alpha air concentration data to reconstruct uranium 

intakes and before a U bioassay coworker model had been 

developed and the source data examined for completeness and 

adequacy.

This finding is no longer relevant, because the uranium 

coworker model, which has been accepted by the Board (for 

prime contractor employees and subcontractors post-1983) is 

based on bioassay data, not air concentration measurements.

SC&A recommends that this 

finding be closed.

TBD

15

Ingestion doses are not 

considered in the TBD.

Thorium ingestion is covered in SEC finding 4.3-9. NIOSH 

responded as follows:

 

Use of the intake model based on thorium air concentrations 

(the Battelle model) addresses this problem. Consequently, it 

is no longer an SEC issue. ...An approach to thorium dose 

reconstruction has been devised using newly available 

thorium exposure assessments. See the DWE Reports white 

paper in the following directory O:\Document Review\AB 

Document Review\Fernald.

3/26/2008 – Once a reliable estimate is made of the 

inhalation rate of uranium, Th-232, and the radionuclides 

associated with raffinates and RU, ingestion intakes and 

doses would be calculated using OCAS-TIB-009 Rev. 0 

(OCAS 2004). Hence, once the inhalation issues are 

resolved, the matter of ingestion exposures effectively 

becomes a review of TIB-009.

This issue was partially resolved by the three SEC classes for 

which it was determined that thorium intakes cannot be 

reconstructed from 1954–1978 and U doses cannot be 

reconstructed for subcontractors from 1951–1983. The 

thorium coworker model post-1978 relies on chest count data, 

and ingestion modeling is still an issue for discussion.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.
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Finding Text History SC&A NIOSH Response Status

TBD

16

Protocols for 

reconstructing shallow 

external dose during the 

operations at FEMP need 

to be further developed.

This relates to SEC finding 4.5-3, yet is not entirely covered 

by it. See TBD finding 18. SC&A last tasked to look at 

several procedures.

 

From SC&A TBD review, Section 5.6.1, External Dose 

Reconstruction Protocols (SC&A 2006):

As a prefatory remark to external dose findings, 

SC&A notes that Findings #16 through #20 are

largely concerned with skin/shallow dose. The 

findings are made as technical arguments, but

their impacts on potential claims may be modest. 

For example, while skin dose to the palm of the hand 

is likely to be underestimated, there may be few, if 

any, claims of skin cancer located in that area. 

However, since the procedure in the TBD is not 

adequate for estimating such doses, in case there are 

any claims, SC&A concluded that a technical review 

of the matter was necessary as part of this TBD 

review.

SC&A recommends finding be 

classified "open" as a topic for 

WG discussion
Effective Date:

Updated October 16, 2013

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Finding Text History SC&A NIOSH Response Status

TBD

17

Extremity doses appear to 

be underestimated.

This is similar to SEC finding 4.5-2. NIOSH responded as 

follows:

Extremity doses were measured using “wrist dosimeters and a 

wrist to extremity ratio.” This ratio varied with changes in 

the dosimeter; it decreased with the introduction of TLDs. 

However, previous extremity dose records were not adjusted 

downward to account for the new lower ratio. Consequently, 

extremity doses are deemed to be sufficiently accurate for 

dose reconstruction or are biased to produce a result that is 

favorable to the claimant.

10/24/07 – SC&A will review data in HIS-20 to consider 

whether sufficient information is available to estimate 

extremity doses for individuals who did not have extremity 

data and who may have had significant extremity exposures.

11/12/07 – Extremity dosimeter not used till 1970. SC&A 

will review data in HIS-20 to consider whether sufficient 

information is available to estimate extremity doses for 

individuals who did not have extremity data and who may 

have had significant extremity exposures. And then 

additionally, SC&A will consider whether this should be 

considered in their review of data completeness.

10/28/08 – SC&A acknowledges that this is not an SEC issue, 

because extremity cancers are uncommon. Until the 1980s, 

energy employees (EEs) were not monitored for extremity 

dose. Extremity monitoring was extremely limited in early 

years; however, those that were monitored had substantial 

exposures. SC&A proposes ratio in write-up to apply to chest 

badge beta readings. NIOSH did not comment on adding this 

ratio to TBD.

This issue was not discussed after this meeting.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.
Effective Date:

Updated October 16, 2013

Revision No.

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Doc

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Finding Text History SC&A NIOSH Response Status

TBD

18

Beta dose to the rest of the 

body would also be 

underestimated, based on 

the TBD guidance.

This is similar to SEC finding 4.5-3. NIOSH responded as 

follows: It is true that only contamination in close proximity 

to the dosimetry device will be recorded, because the dose 

rate associated with surface contamination is small—

probably much less than 1 mrem/hour. In this case, the 

underlying physics limits the dose rate. The beta dose rate on 

contact with an unshielded infinitely thick slab of uranium 

metal is 233 mrem per hour. Knowing this fact, it is feasible 

to bound the dose from surface contamination. Thus, the 

finding assertion, “given the complex processes and the many 

different tasks performed at FMPC, it is inconceivable that 

credible 'ball-park' and bounding estimates can be derived" 

can only be viewed as an error or exaggeration.

Any amount of uranium contamination capable of producing 

a dose rate in excess of a negligible level is likely to be easily 

visible and be removed during the frequent showers and 

clothing changes taken by those workers who may be subject 

to conditions leading to possible contamination, thereby 

limiting the dose.

10/24/07 – NIOSH will examine whether an adjustment is 

necessary to account for this potential unmonitored dose.

3/18/08 – See the 1958 radiation survey on clothing reported 

in NLO 1959. These data are interpreted to be mrad per hour 

for clothing that was in use. Except for exposed skin, clothing 

is assumed to attenuate dose to skin and will lower the actual 

dose... All clothing dose rates are in mrad/hr and most 

measurements of attenuation yield values between 15% and 

20% reduction by the clothing. FEMP 1998, pp. 177–204, 

provides insight to extremity doses and includes a statement 

that measured workplace values should be reduced by some 

14%.

10/28/08 (pp. 356–365) – SC&A will review the procedures 

NIOSH placed on O Drive (NLO 1952; NLO 1965).

Issue was not discussed after this meeting.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion. Contact beta 

dose is currently under review 

in the PRSC.
Effective Date:

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Doc

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Finding Text History SC&A NIOSH Response Status

TBD

19

The TBD does not 

analyze the special 

problems associated with 

geometry of the source 

relative to the exposed 

organ and dosimeter in 

thorium handling and 

production.

This topic has not previously been discussed. SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

Dosimeter geometry has been 

discussed at length in other 

WGs that may serve to inform 

this finding. 

TBD

20

Correction factors used 

during an initial period of 

use of thermoluminescent

dosimeters (TLDs) at 

Fernald are not 

scientifically appropriate.

It was discussed specifically during the August 8, 2007, 

meeting (ABRWH 2007, pp. 321–331). Action Item: NIOSH 

will follow up on the doses assigned during beginning years 

with the use of TLD from 1983 to 1985.

It was not discussed in meetings afterwards.

A note in the October 2008 draft matrix indicates: A "Status 

Report - NLO Health Physics Appraisal" dated 7-10-84 (to 

Thiessen from Adams) has been found indicating that changes 

to recorded doses may have (sic) made. Interviews are 

continuing to discover if additional corrections were applied. 

(SC&A 2008)

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

Open
Effective Date:

Updated October 16, 2013

Revision No.

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Document No.

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Doc

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Finding Text History SC&A NIOSH Response Status

TBD

21

The method for estimating 

external dose to 

unmonitored female 

employees is incomplete 

and its claimant 

favorability has not been 

appropriately 

demonstrated.

This is similar to SEC finding 4.5-5. NIOSH responded as 

follows:

The doses to those female workers who were not 

monitored during two operating periods can be 

reconstructed by at least three methods. They are: 

(1) If the worker in question is doing the same or very 

similar job during periods when she is monitored, that 

dose could be used to adjust the missing dose when 

she wasn’t monitored; (2) Workers who were doing 

the same job and were monitored at the time the 

female wasn’t, could have an equivalent dose assigned 

to the unmonitored worker, and (3) Assignment of the 

missed dose as stated in the TBD-Vol 6 of 500 

mrem/yr for the missing time periods, which is known 

to be extremely claimant favorable.

Discussed at the August 8, 2007, meeting – SC&A raised the 

concern that women who worked in the laundry were not 

monitored, but in some cases handled highly contaminated 

laundry. NIOSH stated assigning them a 500 mrem dose 

exceeds recorded doses by operators, which is claimant 

favorable. SC&A states default dose does not address the 

following: (1) the shallow dose to the skin, (2) the extremity 

dose to the forearm/hands, and (3) potential internal exposure 

from airborne contamination created by handling 

contaminated items.

Suggested linking the internal component to SEC Finding 4.1-

3.

Discussed at the November 13, 2007, meeting. Decided this 

was an issue isolated to a few individuals and should be 

evaluated on a case-by-case basis in DR.

April 22, 3009, meeting: Issue closed. Decided three 

methods suggested are sufficient.

SC&A recommends finding be 

changed to " in abeyance" until 

agreed upon method is 

incorporated into the TBD
Effective Date:

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Revision No.

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Doc

No

Finding Text History SC&A NIOSH Response Status

TBD

22

The source term for 

atmospheric uranium 

emissions from Fernald is 

significantly 

underestimated.

This was discussed briefly in the November 24, 2007, meeting 

(pg. 247), but was not discussed further.

SC&A recommends that this 

finding remain “open” as a 

topic for WG discussion.

TBD

23

The TBD has not 

adequately considered 

various aspects of internal 

environmental dose, 

including the applicability 

of the Gaussian model, 

episodic releases, and 

particle size.

Episodic releases were discussed at the August 8, 2007, 

meeting (pg. 38). NIOSH used RAC Report Number CDC-5

(RAC 1995) to establish the source term. The new model 

incorporates evaluations for episodic releases that occurred. 

NIOSH indicates that assuming a chronic exposure based on 

positive bioassays is more claimant favorable than 

reconstructing individual acute intakes.

It does not appear that Gaussian model and particle size have 

been discussed outside the K-65 radon issue (Primary SEC 

Issue 5).

SC&A recommends that this 

finding remain “open” as a 

topic for WG discussion.

TBD

24

Diffuse emissions of 

uranium and thorium may 

have produced significant 

internal exposures for 

some personnel.

This topic has not previously been discussed. SC&A recommends that this 

finding remain “open” as a 

topic for WG discussion.

TBD

25

NIOSH’s modeling of 

radon dose is not claimant 

favorable and does not 

take actual working 

conditions into account.

This topic has not previously been discussed. SC&A suggests this finding be 

subsumed into SEC Primary 

Issue #5 (moved to TBD issues 

April 2011).
Effective Date:

Updated October 16, 2013

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Doc

No

Finding Text History SC&A NIOSH Response Status

TBD

26

NIOSH has not 

considered a major source 

of radon dose—the 

storage source of 

pitchblende ore onsite 

near Plant 1.

This was discussed at the August 8, 2007, meeting. 

Pitchblende ore storage from the Q-11 silos was identified in 

the Pinney Report (Pinney et al. 2008). They were added to 

the radon source term. It appears that the bins were located 

on the south side of Plant 1.

10/24/07 – Research compiled by Susan Pinney of U of C 

took into consideration, in addition to the K-65 silos, other 

potential source terms of radon. And those included some of 

those specific bins outside of the refinery, in which the Q-11 

ore was contained.

10/28/08 (pg. 258) – Discussion again on how the Pinney 

Report included Q-11 silos as a contributor to radon 

exposures.

4/22/09 – Discussions on Q-11 became blended with 

discussions on SEC Issue 4.2-1. NIOSH indicated that they 

are already updating the TBD to include the Pinney report, 

which includes the Q-11. It was debated changing 4.2-1 to a 

TBD issue, but no decision was reached.

1/29/10 – The Q-11 source term is separate from the K-65 

source term in the Pinney report and should be discussed 

separately when modeling dose. Q-11 appears to be the 

dominate source term in the beginning years. SC&A will 

look at the report NIOSH prepared.

11/09/10 – More discussions on the pulmonary and skin 

implications in a DR of Q-11. SC&A to produce white paper 

on disagreements in source term and if SC&A can buy off on 

the NIOSH suggested approach.

2/8/11 – Anigstein states our opinion is that NIOSH has not 

demonstrated that the ranges can be bounded, though SC&A 

thinks they can be. But to do that they have to have a model 

that is validated and scientifically robust. Board decides this 

should be considered a TBD issue and was no longer 

discussed.

SC&A suggests this finding be 

subsumed into SEC Primary 

Issue #5 (moved to TBD issues 

April 2011).
Effective Date:

Updated October 16, 2013

Revision No.

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Doc

No

Finding Text History SC&A NIOSH Response Status

TBD

27

The TBD does not 

consider outdoor diffuse 

emissions in production 

areas as a source of 

external environmental 

dose.

This topic has not previously been discussed. SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

TBD

28

External environmental 

dose for workers near the 

K-65 silos needs to be 

better evaluated.

This relates to SEC Primary Finding #5 which is still 

unresolved as a site profile issue.

2/9/2011 – NIOSH to consider rescinding its technical 

guidance regarding the K-65 silos based on what SC&A 

believes is a flawed source term and atmospheric dispersion 

model and its conclusions regarding the validity of their 

model based on the Pinney report.

NIOSH to identify which cases might be impacted by 

SC&A’s findings regarding the applicability of the 

atmospheric dispersion model and the veracity of the source 

term.

SC&A suggests this finding be 

subsumed into SEC Primary 

Issue #5 (moved to TBD issues 

April 2011).

TBD

29

Occupational internal 

exposure to radon is 

estimated based on just 

two radon data points 

from 1953. This is an 

inadequate basis to 

reconstruct occupational 

radon dose.

This issue is not related to radon emanating from the silos, but 

to the radon and radon progeny inhaled during drum 

unloading when Silos 1 and 2 were being filled. It is not clear 

whether this issue was discussed and/or resolved in the WG. 

Need more research.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

TBD

30

The possible use of 

photofluorography (PFG) 

at Fernald in the early 

years was ruled out in the 

TBD without adequate 

documentation. This is 

contrary to NIOSH 

general guidance and is 

not claimant favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

TBD

31

The assumption that there 

was a 15% retake rate for 

x-rays is not adequately 

documented or analyzed.

This topic has not previously been discussed. SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.
Effective Date:

Updated October 16, 2013

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Doc

No

Finding Text History SC&A NIOSH Response Status

TBD

32

The assumption that there 

was collimation is not 

technically justifiable 

based on the evidence 

provided in the TBD and 

is not claimant favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

TBD

33

NIOSH has prematurely 

concluded that lumbar 

spine x-rays for laborers 

and construction workers 

were not conditions of 

employment. Based on 

the evidence provided, 

this assumption is not 

sufficiently documented 

and is not claimant 

favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

SEC P

3

Default concentrations (on 

U mass basis) of Pu-239, 

Np-237, and other 

isotopes associated with 

RU at Fernald may not be 

bounding for some classes 

of worker activities, 

buildings, and time 

periods.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from the three principal RU constituents.

SC&A recommends issue be 

placed “in abeyance” until 

implemented in Site Profile.

SEC P

4

Use of radon breath data 

for reconstructing doses 

from inhalation of Ra-226 

and Th-230.

SC&A agrees – radon breath analysis is a scientifically valid 

method for reconstructing the intake of Ra-226 and Th-230 

when the intake ratios of the two radionuclides are known and 

the impacted worker population can be identified.

April 15, 2011: NIOSH posted a response [in ORAUTRPRT-0052 (ORAUT 2011)] to SC&A’s white paper, Review 

of the NIOSH “White Paper on Fernald Th-230 and Other 

Associated Radionuclides – Rev. 7,” (SC&A 2010) that 

summarizes their position.

SC&A recommends issue be 

placed “in abeyance” until 

implemented in Site Profile.
Effective Date:

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Finding Text History SC&A NIOSH Response Status

SEC P

5

Radon release rate from 

the K-65 silos as 

estimated by NIOSH 

substantially 

underestimated. Method 

to derive the atmospheric 

dispersion factors, given 

the source term, is 

scientifically flawed, but 

results in an overestimate 

of the atmospheric 

dispersion factors at 

receptor locations (still 

does not compensate for 

underestimated source 

term).

Numerous white papers have been exchanged; Both sides 

‘agree to disagree.’

NIOSH to consider rescinding its technical guidance 

regarding the K-65 silos based on what SC&A believes is a

flawed source term and atmospheric dispersion model and its 

conclusions regarding the validity of their model based on the 

Pinney reports.

April 19, 2011 – Board agrees to remove from SEC issues to 

TBD Issues.

Open site profile issue.

SEC P

6b

Use of chest counts to 

reconstruct Th-232 

exposures (1968–1988).

1968–1978 – Reported in milligrams thorium. SEC voted 

April 2012 based on inadequacy of the activity to mass 

conversion algorithm (now SEC class).

1979–1988 – Reported in activity (nCi) Pb-212 and Ac-228.

Implementation of a coworker 

model is an ongoing site profile 

issue for 1979–1988.

SEC

4.5-1

Absence of Performance 

Standards/Quality 

Assurance for Personnel 

Dosimeters. This issue 

goes toward the 

availability of approved 

standardized procedures 

for performing external 

dosimetry and adequacy 

of the training and 

qualifications of personnel 

performing external 

dosimetry.

NIOSH responded:

The Oak Ridge film dosimeter, which was the dosimeter used 

at FMPC, was included in external dosimeter 

intercomparison studies and did compare with other AEC 

sites’ dosimeters very well. Discussions held with former 

FMPC employees involved with the early dosimetry program 

from startup through 1985 have revealed that written 

instructions did exist, but to date none could be identified. ... 

NIOSH will attempt to recover QA intercomparison studies or 

internal studies (Herb Parker report and other reports). 

NIOSH will also attempt to identify procedures and/or QA 

reports from the early time period (53–85).

11/13/2007 – The Parker report (Parker 1945) showed that the 

three dosimeters performed very well in the measurement of 

exposures to uranium. The OR dosimeter was used at FEMP 

for several years and modifications were made to it.

This issue is apparently open 

for WG deliberation.
Effective Date:

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Finding Text History SC&A NIOSH Response Status

3/26/08 – SC&A raises concerns about qualifications of badge 

technicians.

10/28/08 – NIOSH will attempt to make more information 

available on O drive from data capture.

It is not evident that this issue was closed by the WG.
Effective Date:

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References:

ABRWH 2007. Transcript: Working Group Meeting, Advisory Board on Radiation and Worker 

Health, Fernald, held in Cincinnati, Ohio, on August 8, 2007.

ABRWH 2011. Transcript: Advisory Board on Radiation and Worker Health, Work Group on 

Fernald, held in Cincinnati, Ohio, on April 11, 2011.

FEMP 1998. External Dosimetry Program Development History, Fernald Environmental 

Management Program, Cincinnati, Ohio. January 22, 1998. SRDB Ref ID 4330.

NLO 1952. Personnel Film Badge Data. National Lead of Ohio, Cincinnati, Ohio. 1952. 

SRDB Ref ID 3173.

NLO 1959. Internal memorandum: 1958 Annual Report, Radiation & Effluent Control Section. 

National Lead of Ohio, Cincinnati, Ohio. February 27, 1959. SRDB Ref ID 4136.

NLO 1965. Procedure Manual – Industrial Hygiene and Radiation Department, Health and 

Safety Division. Includes Standard Operating Procedure for Information Reports. National Lead 

of Ohio, Cincinnati, Ohio. September 28, 1965. SRDB Ref ID 33975.

OCAS 2004. Estimation of Ingestion Intakes, OCAS-TIB-009, Rev. 0. Office of Compensation 

Analysis and Support, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

April 13, 2004.

ORAUT 2007a. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. August 7, 2007. SRDB Ref ID 41661.

ORAUT 2007b. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. August 30, 2007. SRDB Ref ID 38124.

ORAUT 2007c. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. September 11, 2007. SRDB Ref ID 38132.

ORAUT 2011. Feed Materials Production Center Internal Dose Topics, ORAUT-RPRT-0052, 

Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. July 12, 2011.

Parker, H.M., 1945. Comparison of Film Badge Readings. Memo to file. (Document marked 

“Publicly Available”). December 7, 1945. SRDB Ref ID 439.

Pinney, S., R. Hornung, J. Lodwick, G. Killough, D. Brewer, and J. Nastua, 2008. “Estimation 

of radon exposure to workers at the Fernald Feed Materials Production Center,” Journal of 

Exposure Science and Environmental Epidemiology, 2008.
Effective Date:

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RAC 1995. The Fernald Dosimetry Reconstruction Project, Tasks 2 and 3 Radionuclide Source 

Terms and Uncertainties, RAC Report No. CDC-5. Radiological Assessments Corporation, 

Neeses, South Carolina, 1995.

SC&A 2006. Review of the NIOSH Site Profile for the Fernald Environmental Management Project 

(Feed Materials Production Center), SCA-TR-TASK1-0010, Rev. 0. SC&A, Inc., Vienna, Virginia,

and Saliant, Inc., Jefferson, Maryland. November 10, 2006.

SC&A 2008. Memo to the Fernald Work Group from J. Mauro (SC&A), Subj: Matrix for use at 

the Fernald Work Group Meeting Scheduled for October 28th, 2008. SC&A, Inc., Vienna, 

Virginia, and Saliant, Inc., Jefferson, Maryland. October 14, 2008.

SC&A 2010. Review of the NIOSH “White Paper on Fernald Th-230 and Other Associated 

Radionuclides – Rev. 7,” Rev. 0. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. May 2010.