National Institute for Occupational Safety and Health

Update on Lawrence Berkeley National Laboratory 

Site Profile Review

Megan Lobaugh, PhD, CHP

Research Health Physicist

132nd Meeting of the Advisory Board on Radiation and Worker Health

Oakland, CA

December 11, 2019
Overview

 Overview of the LBNL Site

 Summary of LBNL Site Profile Issues

– Review of “In Progress” Site Profile Issues

 Overview of Current NIOSH Work Underway

 Current Responses to SC&A Review of the NIOSH White Paper: “Method 

to Assess Internal Dose Using Gross Alpha, Beta, and Gamma Bioassay 

and Air Sampling at the Lawrence Berkeley National Laboratory”
Lawrence Berkeley National Laboratory

 Founded by E.O. Lawrence in 1931 as the Radiation Laboratory

– EEOICPA Covered Period: August 13, 1942 through present

 Multiprogram Science Lab

– 88-inch Cyclotron, ALS

– Molecular Foundry

– Biosciences and Biomedical Isotope Facility

– DOE Joint Genome Institute

– Energy, Environment

 13 Nobel Prizes
LBNL and EEOICPA Part B

 Special Exposure Cohort Class:

– All employees working from August 13, 1942 

through December 31, 1961 

– Due to infeasibilities with: 

• External Dose prior to 1948 

• Internal Dose prior to 1962

 Dose Reconstruction Claims:

– 217 Completed (43 ≥ 50% PoC; 174 < 50% PoC)

– 8 Active

– 36 Pulled 
Summary of LBNL Site Profile Issues

 13 Findings

• 3 Closed

• 2 Addressed in Finding

• 8 In Progress

Next we will review the “In Progress” Issues

 8 Observations

• 2 Closed

• 3 Addressed in Finding

• 3 In Progress
Finding 1: Inadequate documentation of historical 

operations and sources of radiological exposures

 Facility Information

 Related Issue

– Observation 5: Lack of information on isotopes, facilities, and handling 

methods (additional facility information)

 Action Items

– NIOSH update Site Profile with additional information that has been 

captured since the last revision
Finding 2: Insufficient Information for Internal Dose 

Reconstruction, especially during the Early Years

 Internal Dose

 Related Issues

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

Verified

– Finding 11: Inadequacy of Bioassay Analyses Presentation

 Action Items

– NIOSH respond to the SC&A February 2014 Memo with specific 

references to where we have provided this information in the past, as 

well as how the recent Internal Dose Methodology would affect 

answers to the questions put forward in the memo.

• Interviews and data capture
Finding 5: Insufficient Justification for Selection of 

IREP Energy Range Fractions for Photon Exposures

 External Dose

 Related Issue

– Observation 8: Overuse of Generalizations and Assumptions (IREP 

photon energy fractions)

 Action Items

– NIOSH update Table 6-5 for all years and all major accelerator 

operations

• Interviews and data capture
Finding 6: Insufficiency of Neutron Dosimetry 

Treatment

 External Dose

 Related Issue

– Observation 8: Overuse of Generalizations and Assumptions (neutronto-gamma dose ratios)

 Action Items

– NIOSH revise the external dose discussion to direct use of the N:P 

ratio, determine if NTA correction factors (energy response, angular 

dependence, and fading) are required, clarify low energy NTA 

correction factor discussion, and clarify the uncertainties listed in 

Table 6-11

• Interviews and data capture
Finding 7: Failure to Justify the Shallow Dose to Deep 

Dose Assumption

 External Dose

 Related Issues

– Observation 5: Lack of Information on Isotopes, Facilities, and 

Handling Methods (additional information specific to shallow and 

extremity doses)

– Observation 6: Extremity Dosimetry needs Revisiting

– Observation 8: Overuse of Generalizations and Assumptions (shallowto-deep dose ratios)
Finding 7: Failure to Justify the Shallow Dose to Deep 

Dose Assumption (continued)

 Action Items

– NIOSH review NOCTS claim data to determine if it supports the 

shallow to deep dose ratios and extremity dose ratios

– NIOSH compile list of pure beta emitters in use

– NIOSH research whether there is area monitoring available for pure 

beta emitters in use

– NIOSH determine if unmonitored approach is needed for pure beta 

emitters

– NIOSH review extremity dose ratio and provide specific response to 

SC&A comment of 3 vs 5 times

– Interviews and data capture
Finding 8: Uncertainty in Beta-Gamma Dosimeter 

Response to Radiation Types and Energies

 External Dose

 Action Items

– NIOSH update external dose discussion in Site Profile with specific 

direction regarding not using the electroscope data after 1948 

because there is film and other dosimetry data available

– NIOSH review Attachment A of Site Profile and provide summary of 

what is included to address the specific information requested in 

SC&A review
Finding 12: Failure to Provide Sufficient Guidance for 

Unmonitored Workers

 Internal Dose

 Action Items

– NIOSH respond to the SC&A February 2014 Memo with specific 

references to where we have provided this information in the past, as 

well as how the recent Internal Dose Methodology would affect 

answers to the questions put forward in the memo.

• Interviews and data capture
Finding 13: Inadequate Coverage of Occupational 

Environmental Dose

 Environmental Dose

 Action Items

– NIOSH add information to Site Profile about the Co-60 accelerator, 

flesh out accelerator background (environmental) exposures, and 

change guidance for radionuclide assignment for internal dose from 

beta contributors
Observation 3: Lack of Discussion of Radiological 

Incidents

 Radiological Incidents

 Action Items

– NIOSH will identify and research major radiological incidents at LBNL, 

then revise the Site Profile to incorporate a summary of these 

incidents
Observation 4: Need to provide information on 

Metallurgical Laboratory [dosimetry services]

 External Dose

 Action Items

– NIOSH will perform additional research for information on the MetLab

Dosimetry services and include any additional information in the Site 

Profile
Observation 7: Lack of Sufficient Information for 

External Dose Evaluation

 External Dose

 Action Items

– NIOSH commits to improving the discussion of the post-1947 External 

Dosimetry program, including historical dosimeter information
Overview of Current NIOSH Work 

Underway
Interviews and Data Capture Timeline

 June 11, 2019- NIOSH sent Data Request (LBNL-FY19-001)

 July 2, 2019- NIOSH requested interviews through LBNL Point of Contact

 August 15, 2019- NIOSH began reaching out to potential interviewees

 September 3, 2019- Interview #1 (SRDB Ref ID 178601)

– Interviewee provided several additional names

– Sent 4 requests for additional interviews

 September 6, 2019- Interview #2 (SRDB Ref ID 178602)

 November 15, 2019- LBNL provided NIOSH with selected UCRL and 

numbered technical documents

 January 13, 2020- Data Capture Tentatively Scheduled
Data Request (LBNL-FY19-001): 

Information Specific to Site Profile Issues

Data Requested Applicable Issues

Whole Body Counter peak searches and 

calibration Findings 2, 4, and 11

Neutron and other radiation energy spectra 

from cyclotrons/accelerators Findings 1, 5, 6, and 8

Extremity dosimetry Finding 7; 

Observations 5, 6, and 8

Neutron exposures measured by NTA film Findings 6 and Observation 8

Shallow/Beta Dose Finding 7; 

Observations 5, 6, and 8
Data Request (LBNL-FY19-001): Information Specific to 

Internal Dose Methodology Issues

Note: Internal Dose Methodology was written in response to Site Profile 

Findings 2, 4, 11, and 12 & Observation 2

Data Requested Applicable Issues

Gross alpha, gross beta, gross gamma bioassay 

in-house detector systems Finding 2

Breathing zone alpha and beta/gamma inhouse detector systems Finding 2

Air sampling policies, procedures, and 

practices including specific information about 

Breathing Zone samples

Finding 1
Responses to SC&A Review of the NIOSH 

White Paper: “Method to Assess Internal 

Dose Using Gross Alpha, Beta, and Gamma 

Bioassay and Air Sampling at the Lawrence 

Berkeley National Laboratory”
Summary of Issues from Method to Assess Internal 

Dose Using Gross Alpha, Beta, and Gamma Bioassay 

and Air Sampling at Lawrence Berkeley National 

Laboratory

 2 Findings

• 2 In Progress

 3 Observations

• 1 Closed

• 1 In Abeyance

• 1 In Progress
Finding 1: Air Samples May Not Represent 

Concentrations Breathed by Workers

 October 2018: Initial response provided information as to why NIOSH 

believes, given current day standards for breathing zone (BZ) samples and 

the LBNL policies and documentation available, that the samples used in 

the Methodology are BZ samples and therefore representative of the air 

concentrations breathed by the worker

 April 2019: WG discussed the issue and requested additional information 

such as air flow studies, pictures documenting the placement of air 

samplers, and information relating to implementation of policies

 Interviews (SRDB Ref ID 178601 and 178602) and data capture request 

regarding additional air sampling program policies and procedures
Finding 2: Technical Issues and Uncertainties with 

Gross Counting Data Conversion to 

Concentration/Intake for Use in Dose Reconstruction

 October 2018: NIOSH committed to researching and subsequently 

reviewing detector technical information (e.g., efficiency calibrations) to 

determine if specific radionuclides may be underestimated by the gross 

measurement methods

 Interviews (SRDB Ref ID 178601 and 178602) and data capture request for

specific information on in-house detector systems used to measure these 

samples
Observation 1: Potentially Missed Radionuclides

 Radioiodines- not included, measured on separate charcoal samples

 Erbium-165- not included, below short half-life cutoff

 Erbium-169- will be added in final DR Methodology Implementation

 Fermium-237

– Typo in SC&A Methodology Review, intent likely was Fm-257, which is 

in the Site Profile and not included in the Methodology 

– Fm-257 will be added in the final DR Methodology Implementation
Observation 1: Potentially Missed Radionuclides

(continued)

 Rhodium-102- will be added in final DR Methodology Implementation

 Scandium-93

– Typo carried over from the Site Environmental reports 

– Interviewees provided additional contacts who prepared the 

environmental reports, NIOSH continuing to investigate and will report 

back
Observation 2: Bioassays in Claimant DOE Files May 

Not Be Indicative of Exposure Potential

 2010 NIOSH began receiving the entire medical file

 NIOSH made a mass re-request of the complete medical file for LBNL 

claims received prior to 2010

 168 claims

– 53 no medical records

– 1 claim submitted that had a PoC over 50%

– 109 claims no new bioassay information

– 3 claims with new bioassay information from DOE, but NIOSH had 

information via other documents

– 2 claims with new bioassay information
Observation 2: Bioassays in Claimant DOE Files May 

Not Be Indicative of Exposure Potential (continued)

 5 claims with new bioassay information were reviewed for impact

# of 

Claims

Bioassay 

Results 

Available at 

Time of DR

New Bioassay Results 

Available after Mass 

Re-request

Potential Effect on 

the Application of 

Internal Dose 

Methodology

2 No Yes Yes

2 Yes Yes Yes

1 Yes No No
Observation 2: Bioassays in Claimant DOE Files May 

Not Be Indicative of Exposure Potential (continued)

Note: Unmonitored approach using air sampling results doesn’t necessarily rely on 

existence of bioassay data

 4 of the 168 claims (~2.4%) potentially affected by existence of bioassay

 Placed In Abeyance by the WG at 11/25/2019 Teleconference

– Awaiting NIOSH update to the Methodology including clear and 

explicit guidance on the application of the Methodology
Observation 3: Bioassays in Claimant DOE Files May 

Not Be Complete Compared to LBNL Documents

 2010 NIOSH began receiving the entire medical file

 NIOSH made a mass re-request of the complete medical file for LBNL 

claims received prior to 2010

– 2 claims (~1.2%) with new bioassay information

 Closed by the WG at 11/25/2019 Teleconference