Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A’S EVALUATION OF RESOLUTION OF PANTEX SITE 

PROFILE ISSUES IN REVISION 03 TO PANTEX EXTERNAL 

DOSE TECHNICAL BASE DOCUMENT

Contract No. 211-2014-58081 

SCA-TR-2017-SP002, Revision 0 

Prepared by

Ron Buchanan, PhD, CHP 

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

January 2017 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues. 

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.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

SC&A’s Evaluation of Resolution of Pantex Site Profile Issues in 

Revision 03 to Pantex External Dose Technical Base Document

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-SP002 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: January 30, 2017

TASK MANAGER: Joe Fitzgerald [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S): John Stiver, MS, CHP [signature on file] 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 1/30/2017 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 4

1.0 Introduction and Background ............................................................................................. 5

2.0 SC&A Evaluation ............................................................................................................... 5

3.0 Summary and Conclusions ................................................................................................. 7

4.0 References........................................................................................................................... 7

Attachment 1: Pantex Site Profile Matrix (May 2016) ................................................................... 8
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ABBREVIATIONS AND ACRONYMS

MDA minimum detectible activity

NIOSH National Institute for Occupational Safety and Health

NTA neutron track emulsion, Type A (film)

ORAUT Oak Ridge Associated Universities Team

TBD technical basis document 

SEC Special Exposure Cohort 

WG Work Group 
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1.0 INTRODUCTION AND BACKGROUND 

The National Institute for Occupational Safety and Health (NIOSH) has issued four revisions of 

the Pantex Plant external dose site profile technical basis document (TBD), ORAUT-TKBS0013-6 (hereafter “TBD-6”). These are as follows:

1. Revision 00 on July 27, 2006 

2. Revision 01 on June 22, 2007 

3. Revision 02 on November 24, 2015 

4. Revision 03 on November 29, 2016 

SC&A, Inc. evaluated the latest, Revision 03, of TBD-6 to determine if the revised TBD 

resolved the Pantex site profile external dose issues as listed in the issues matrix for Pantex 

(SC&A 2016a) and discussed during the Pantex Work Group (WG) meetings (the latest on 

August 4, 2016). The May 2016 Pantex issues matrix is enclosed as Attachment 1 to this report. 

SC&A did not evaluate the technical aspects of the entire revised TBD, as that is outside the 

scope of this task; only the sections relevant to resolving the TBD issues were evaluated.

2.0 SC&A EVALUATION

The following four issues were to be resolved by NIOSH making changes in the Pantex TBDs: 

• Site Profile Issue 1: Interpretation of external dosimetry data. NIOSH was to provide 

clarification of “zero” entries in the electronic database beyond 1976. (In addition, 

NIOSH was to clarify the use of the year 1988 instead of 1989 as the year all personnel 

were monitored for exposures in its response in the Pantex issues matrix [NIOSH 

2016a].) 

Current Status: NIOSH provided clarification of this issue during the August 4, 2016, 

Pantex WG meeting (NIOSH 2016b, pages 7–10, 13). NIOSH clarified the issue by 

verifying that zeros were recorded only if a person was monitored and the results were 

read and found to be zero or the readings were less than the lower limits of detection. In 

addition, NIOSH stated that the use of 1988 as the year all personnel at Pantex were 

monitored for external exposures was incorrect in the issues matrix and that the year 1989 

is correct, as used in TBD-6. SC&A verified that 1989 was the year used in the revised 

TBD (e.g., pages 13, 39, etc.). However, SC&A would like to point out that the text on 

page 5 of ORAUT-OTIB-0086, Pantex External Coworker Model, uses the incorrect 

wording “In such cases for years before 1988...” The phrase “before 1988” should be 

changed to “before 1989” to refer to a period when all personnel were not monitored for 

external exposure.

SC&A’s Evaluation: SC&A found the issue resolved as per the August 4, 2016, Pantex 

WG meeting (NIOSH 2016b, pages 7–10, 13). Note that this was an issue identified in 

SC&A’s review of ORAUT-OTIB-0086 (SC&A 2015); it did not originate in TBD-6 but 

was included in the Pantex matrix. SC&A recommends closure in the Pantex site profile 
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matrix, and that the use of the year 1988 be changed to 1989 in the next revision of 

ORAUT-OTIB-0086. 

• Site Profile Issue 2: Data do not support assumption that 95th percentile neutron-tophoton ratio is bounding for all exposure scenarios. From reviewing the revised 

ORAUT-TKBS-0013-6 and the related document ORAUT-OTIB-86, SC&A found that 

instead of using the neutron-to-photon method, NIOSH recommends using the recorded 

neutron dose, with the neutron track emulsion, Type A (NTA) film results adjusted for 

energy response, angular response, and track fading. As previously summarized and 

detailed in SC&A’s review of ORAUT-OTIB-86 (SC&A 2015), SC&A does not find the 

neutron adjustment factors to be claimant favorable for Pantex workers. 

Current Status: SC&A performed a study and comparison of the various correction 

factors and reached the consensus, in view of the information currently available, that an 

overall modification factor of 2.9 for NTA film is reasonable for the Pantex site. SC&A 

released a memo with this information to the Pantex WG on October 19, 2016 

(SC&A 2016b). 

SC&A’s Evaluation: SC&A finds the issue resolved and recommends closure. 

• Site Profile Issue 3: Completeness and interpretation of historic radiological 

exposure sources.

Current Status: SC&A had previously found that sections had been added in 2015 in 

ORAUT-TKBS-0013-5, Revision 04 (the occupational internal dose TBD), and ORAUTTKBS-0013-6, Revision 02, with information concerning Pantex’s history and workers at 

other U.S. Atomic Energy Commission/Department of Energy facilities that resolves this 

issue and recommended closure.

• Site Profile Issue 4: Exposure from tritium.

– SC&A found that Revision 04 to ORAUT-TKBS-0013-5 (mainly Table 5-3) provides 

for tritium dose assignments based on recorded minimum detectible activity (MDA) 

values and also simplifies tritium dose assignment for the dose reconstructor and 

allows for consistency in dose assignments. SC&A considers this part of the issue 

resolved. 

– SC&A found the explanation (change in MDA values) reasonable for using the period 

1956–1990 instead of 1956–1991 and considers this part of the issue resolved. 

– The remaining issue can be addressed by a change in the statement in the footnote to 

Table 5-3 of ORAUT-TKBS-0013-5 concerning the maximum intake and dose. 

Current Status: This is an internal dose issue to be resolved by rewording the footnote 

to Table 5-3 of ORAUT-TKBS-0013-5. This issue does not apply to TBD-6, or this 

report but was mentioned here because it was listed in the Pantex issues matrix.
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3.0 SUMMARY AND CONCLUSIONS

SC&A’s reviewed the revised Pantex TBD-6 and found that all the site profile external dose 

issues have been resolved and recommends closure. 

4.0 REFERENCES

NIOSH 2016a. DCAS Responses to SCA Pantex Review 5-24-2016, National Institute for 

Occupational Safety and Health, Division of Compensation Analysis and Support, Cincinnati, Ohio. 

May 24, 2016. 

NIOSH 2016b. Transcript of the teleconference meeting of the Advisory Board on Radiation and 

Worker Health, Pantex Plant Work Group. August 4, 2016. 

ORAUT-OTIB-0086. 2015. Pantex External Coworker Model, Revision 00, Oak Ridge 

Associated Universities Team, Oak Ridge, Tennessee. August 7, 2015. 

ORAUT-TKBS-0013-5. 2015. Technical Basis Document for the Pantex Plant – Occupational 

Internal Dose, Revision 04, Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 1, 

2015. 

ORAUT-TKBS-0013-6. 2006. Technical Basis Document for the Pantex Plant – Occupational 

External Dose, Revision 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. July 27, 

2006. 

ORAUT-TKBS-0013-6. 2007. Technical Basis Document for the Pantex Plant – Occupational 

External Dose, Revision 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

June 22, 2007. 

ORAUT-TKBS-0013-6. 2015. Technical Basis Document for the Pantex Plant – Occupational 

External Dose, Revision 02, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

November 24, 2015. 

ORAUT-TKBS-0013-6. 2016. Technical Basis Document for the Pantex Plant – Occupational 

External Dose, Revision 03, Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

November 29, 2016. 

SC&A 2015. SC&A’s Evaluation of the Pantex External Coworker Model: ORAUT-OTIB-0086, 

Revision 0, SC&A, Inc., McLean, VA, and Saliant, Inc., Jefferson, MD. September 23, 2015. 

SC&A 2016a. SC&A’s Evaluation of Revisions to Pantex Technical Basis Documents Relevant 

to Site Profile and SEC Issues: Technical Basis Documents Issues Matrix, SC&A, Inc., McLean, 

VA, and Saliant, Inc., Jefferson, MD. June 16, 2016. 

SC&A 2016b. Pantex TBD and OTIB-0086 Neutron NTA Film Correction Factor Issues, SC&A, 

Inc., McLean, VA, and Saliant, Inc., Jefferson, MD. October 19, 2016. 
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ATTACHMENT 1: PANTEX SITE PROFILE MATRIX (MAY 2016)

SC&A’S EVALUATION OF REVISIONS TO PANTEX TECHNICAL BASIS DOCUMENTS RELEVANT TO SITE PROFILE AND SEC ISSUES: 

TECHNCIAL BASIS DOCUMENTS ISSUES MATRIX 

TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

6-1 1 Site Profile Issue # 1

Interpretation of external dosimetry 

data. SC&A could not find that NIOSH 

addressed the issue of recorded zeros (or 

other markings) in the records before 

1989 in the revised ORAUT-TKBS0013-6 (Revision 02). From reviewing 

OTIB-0086 (ORAUT 2015), SC&A 

recommends that the DR consider the 

worker’s job titles and dosimetry records 

in totality when evaluating recorded 

zeros (as well as blanks, dashes, and 

hash marks) for deciding whether to 

assign coworker, missed, or 

environmental external dose, because the 

electronic database may have inserted 

zeros for unmonitored workers after 

1976.

Based on NIOSH's research, beginning in 1988 

all personnel entering the controlled radiation 

areas were required to wear a personnel 

dosimeter. This was addressed with the 

publication of OTIB-0086 which specifies:

In such cases for years before 1988, NIOSH 

intends to apply (after consideration of the 

worker’s job title and the totality of the 

monitoring record), either: 1) Unmonitored 

dose based on external coworker data listed 

in OTIB-0086 and Tables A-1 through A-3 

of the Pantex External TBD, 2) Missed dose

or 3) Ambient dose.

For 1988 and later years, all personnel who 

entered the operational areas of the plant 

were required to wear a dosimeter as a 

condition for entry. The absence of a listed 

result, or the presence of a dash, slash, or 

hash mark for a given dosimeter exchange 

cycle in 1988 and later years, should be 

interpreted to mean that the worker was not 

monitored because he or she was not present 

in the operational areas. Therefore, ambient 

dose should be assigned for those exchange 

cycles.

5/2016

SC&A found that NIOSH’s response 

addressed the issue, except for: 

a) The fact the word “zero” was not 

specifically used when considering the 

worker’s monitoring records. This is 

important because the electronic database 

may have inserted zeros for unmonitored 

workers after 1976. 

b) , TBD-6, page 13 states that the 

year when all personnel entering a rad area 

were monitored was 1989. Which year, 

1988 or 1989, is correct?
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TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

6-2 2 2.0 Data do not support assumption 

that 95th percentile neutron-to-photon 

ratio is bounding for all exposure 

scenarios. From reviewing the revised 

ORAUT-TKBS0013-6 (Revision 02) and 

the related document, OTIB-0086 

(ORAUT 2015), SC&A found that 

instead of using the n/p method, NIOSH 

recommends using the recorded neutron 

dose, with the NTA film results adjusted 

for energy response, angular response, 

and track fading. As previously 

summarized, and detailed in SC&A’s 

review of OTIB-0086 (SC&A 2015), 

SC&A does not find the neutron 

adjustment factors to be claimant 

favorable for Pantex workers.

NIOSH notes that the comments on the site 

profile document were similar in nature to those 

made during SC&A’s review of OTIB-0086 

(ORAUT 2015). NIOSH recently determined that 

the Pantex Plant ended its contract with Landauer 

for NTA film at the end of 1973, and likely 

transitioned to TLDs in 1974 for neutron 

monitoring. As a consequence of this recent 

determination, NIOSH intends to revise OTIB0086 and ORAUT-TKBS-0013-6 (Revision 02) 

to reflect the use of NTA film through 1973 and 

the use of TLDs for 1974 and subsequent years. 

NIOSH contends that the correction factors 

applied to the NTA film results to account for 

energy response, angular response, and track 

fading are favorable to claimants and are 

applicable through 1973. 

5/2016

SC&A will need to review the revised 

OTIB-0086 and TBD-6 to evaluate the 

changes made for the transition from NTA 

film to TLDs.

However, the NTA film correction factors 

recommended by NIOSH has not been 

justified and the issues raised by SC&A 

are still applicable.

5-6 3 Site Profile Issue #3 

Completeness and interpretation of 

historic radiological exposure sources. 

SC&A found that sections had been added 

to ORAUT-TKBS-0013-5, Revision 04 

(2015), and ORAUTTKBS-0013-6, 

Revision 02 (2015), with information 

concerning Pantex’s history and workers at 

other AEC/DOE facilities that resolves this 

issue.

No response necessary. SC&A deems the issue 

resolved. 

5/2016

SC&A recommends closure.
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TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

5-4 4 Site Profile Issue #4 (SEC Issue #15): 

Exposure from tritium. SC&A found that 

Revision 04 to ORAUT-TKBS0013-5 

(mainly Table 5-3) provides for tritium 

dose assignments based on recorded MDA 

values and also simplifies tritium dose 

assignment for the DR and allows for 

consistence in dose assignments. SC&A 

found this issue to be addressed, except for 

the statement in the footnote to Table 53 of 

ORAUT-TKBS-0013-5, Revision 04 

(2015), concerning the maximum intake 

and dose, and the reason for using the 

period 1956–1990 instead of 1956–1991.

Although the sentence “Note that these values 

exceed any recorded doses or intakes the site 

reported for any year of operation, including 1989 

when a major tritium released occurred.” is 

misleading, the listed maximum and mode annual 

intakes are greater than those listed in the 

ORAUT-TKBS0013-5, Revision 01 (2007). The 

footnote in the next revision of ORAUTTKBS0013-5 will be revised to read “Note that these 

values exceed any recorded intakes the site 

reported for any year of operation, including 1989 

when a major tritium released occurred.” 

All doses reflected in Table 5-3 of ORAUTTKBS-0013-5, Revision 04 (2015) are based on 

the current ICRP Publication 68 tritium dose 

coefficients. Moreover, the ORAUT-TKBS-0013-

5, Revision 04 (2015) Table 5-3 missed and/or 

unmonitored doses are only applied for those 

claimants with recorded zero results or reasonable 

expectation that they should have been monitored 

and were not. In cases where workers have 

recorded doses in excess of “zero” TEDE, then 

the dose reconstructor will assign tritium dose in 

accordance with the instructions listed in 

Attachment C, ORAUT-TKBS-0013-5, 

Revision 04 (2015). 

The rationale for assigning doses through 1990 

based on an MDA of 0.500 uCi/L is based on a 

review of claimant records which showed that 

value to be the highest through 1990. For 1991 

and all subsequent years, the highest listed MDA 

in claimant records listed was 0.135 uCi/L. The 

SEC dates were not considered for the time 

periods listed in Table 5-3.

5/2016

SC&A agrees that the changing in 

wording would clarify the maximum 1989 

dose and intake issue.

SC&A accepts the rational for using the 

period of 1956-1990, instead of 1991. 

This issue can be closed after the revision 

is made in the wording for the maximum 

intake.