INL Issues Matrix 1 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

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) (ORAUT-TKBS-0007-5) 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 [the National Institute for Occupational 

Safety and Health] 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 2 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

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)

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. –

A-3  “...highly enriched uranium fuel (enrichments in excess of 90%)

would contain very little Pu-239 [plutonium-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. –

A-3  “Wafer-thin ribbons of UO2 [uranium oxide] 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 SCATR-2015-SEC0074A. 

–

A-3  “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 3 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

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 [Centers for 

Disease Control and Prevention], 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 &

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

formed during the excavation of the 8-in 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, Rev. 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 Database 

may provide some insight when 

available. — We still have the 

Seattle and return INL data 

captures coming up later in 2016.
INL Issues Matrix 4 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

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 Gamma Analyses) 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 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 (March 1, 1970–December 31, 

1974) will satisfy the intended criteria.” [I.e., one badge, one area 

one badge, multiple areas (March 1, 1970)  one badge, one area 

(December 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 

will be 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. –

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. SC&A comment: NIOSH clarified at 

the November 11, 2015 Work 

Group meeting that temporary 

and visitor badges and location 
INL Issues Matrix 5 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

No. Description References Notes & Additional Comments

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. SC&A comment: NIOSH clarified 

at the November 11, 2015 Work 

Group meeting that it will reach 

out to site personnel for

clarification. To be discussed at 

the March 1, 2016 WG meeting.

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 

Work Group 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.

DD1

“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 

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 
INL Issues Matrix 6 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

No. Description References Notes & Additional Comments

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

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

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 Telecon, 

January 15, 2016, pp. 87–94)

DD2

“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: Subsequent to 

this report and prior to the 

January 2016 WG teleconference, 

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 

Telecon, January 15, 2016, p. 55)

DD3

“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: Subsequent to 

this report and prior to the 

January 2016 WG teleconference,

NIOSH obtained visitor badges at 

CPP for this individual which 

correspond to the internal 

monitoring result identified in 

Observation 3. (INL WG Telecon, 

January 15, 2016, pp. 85–86)

DD4

“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 
INL Issues Matrix 7 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

No. Description References Notes & Additional Comments

records at other INL areas where

the EE may have been monitored 

but not captured in the DOE 

response. (INL WG Telecon, 

January 15, 2016, pp. 111–116)

Issue E1: Fission and Activation Product (FAP) Bioassay Indicator Radionuclides – Scope of Review: Analyze FAP indicator ratios, 

actinide-to-FAP ratios, and special situations/bioassays.

E1-1 “FAP intakes assigned using NIOSH’s recommendations in ORAUTOTIB-0054...based on Sr-90 [strontium-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 off-site 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.

E1-2 “The Cs-137 [cesium-137]/Sr-90 intakes are not always 1:1 as 

assumed in ORAUT-OTIB-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 E1-1.
INL Issues Matrix 8 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

No. Description References Notes & Additional Comments

E1-3 “Actinide intakes assigned using NIOSH’s recommendation in ORAUTTKBS-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 E1-1.

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. 

SC&A comment: Issue E2 

discussed on pp. 221–244 of the 

November 11, 2015 WG meeting

transcript.

Tasking from November 11, 2015 

WG meeting: NIOSH will assess 

FAP coworker modeling 

requirements and feasibility for 

the applicable INL site areas and 

years. 
INL Issues Matrix 9 SC&A – February 23, 2016 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. However, this report is pre-decisional and has not 

been reviewed by the Advisory Board on Radiation and Worker Health for factual accuracy or applicability within the requirements of 42 CFR 82.

No. Description References Notes & Additional Comments

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 

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 

E2-1.