Working Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

FERNALD PLANT SITE PROFILE ISSUES MATRIX – 

DRAFT PRELIMINARY SC&A ASSESSMENT

Contract No. 211-2014-58081 

SCA-SP-IM2013-0045, Revision 5 

Prepared by 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300

Arlington, Virginia 22201 

August 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 & Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

Fernald Plant Site Profile Issues Matrix – Draft Preliminary SC&A 

Assessment

DOCUMENT NUMBER/

DESCRIPTION:

SCA-SP-IM2013-0045

REVISION NO.: 5 (Draft)

SUPERSEDES: 4

EFFECTIVE DATE: August 9, 2017

TASK MANAGER: Bob Barton, CHP [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) 10/15/2013 Initial issue of a complete issues matrix incorporating information from 

previous versions, white paper issue reviews, memorandums, Work Group 

meetings, etc.

1 4/13/2014 Revision to incorporate NIOSH responses to Rev. 0 and SC&A responses to 

NIOSH responses.

2 9/01/2014 Revision to incorporate additional SC&A responses to NIOSH responses 

based on focused review of 2014 TBD revisions. An attachment has also 

been added.

3 11/25/2014 Revision to update matrix based on 9/03/2014 Work Group Discussions.

4 05/18/2016 Revision to update matrix based on 12/4/2014 Work Group Discussions.

5 8/9/2017 Revision to update matrix based on 7/28/2017 Work Group Discussions.
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

Ac actinium

AEC Atomic Energy Commission

Am americium

BZ breathing zone 

CATI computer-assisted telephone interview

Ci curie

CL censoring level

DAC derived air concentration

DOE U.S. Department of Energy 

DR dose reconstruction 

DWE daily weighted exposure 

EE energy employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act

ER evaluation report 

FEMP Fernald Environmental Management Project 

FMPC Feed Materials Production Center

GA general air 

INL Idaho National Laboratory

IREP Interactive RadioEpidemiological Program

K potassium 

LOD limit of detection

MDA minimum detectable activity

mrad/hr millirad per hour

mrem millirem

mrem/yr millirem per year

nCi nanocurie 

NIOSH National Institute for Occupational Safety and Health

NLO National Lead of Ohio 

Np neptunium 

OPOS one person one sample 
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Pb lead

PFG photofluorography 

PRSC Procedures Review Subcommittee

Pu plutonium 

QA quality assurance

Ra radium 

RAC Radiological Assessments Corporation

RU recycled uranium 

SEC Special Exposure Cohort 

SOP Standard Operating Procedure 

SRDB Site Research Data Base

SRS Savannah River Site 

TBD technical basis document

Tc technetium 

Th thorium 

TLD thermoluminescent dosimeter

TWOPOS time-weighted one-person-one-statistic

U uranium 

UF6 uranium hexafluoride 

WG Work Group 

WMCO Westinghouse Materials Company of Ohio 
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INTRODUCTION

The attached updated Fernald Plant Site Profile Issues Matrix – Draft Preliminary SC&A 

Assessment, Revision 5, is the current matrix for use by the Fernald Work Group; it was 

originally provided in both Microsoft Word® and Excel® formats (Revision 0) in October 2013.

Revision 1 incorporated the National Institute for Occupational Safety and Health’s (NIOSH’s)

responses to Revision 0 (column 6) and SC&A’s responses to NIOSH’s responses. Revision 2, 

dated September 1, 2014, incorporated additional SC&A responses based on our focused review 

of new technical basis document (TBD) revisions provided in 2014. SC&A notes that while a 

great deal of information and guidance is provided in the 2014 TBD revisions, we have not 

reviewed any of the TBD revisions beyond the level needed to close our findings from the 2006 

review. Revision 3 of this matrix presented an update based on discussions during the 

September 2014 Fernald Work Group meeting and associated changes in the status of several 

findings. Revisions 2 and 3 also included an attachment with responses for those findings 

requiring a detailed description; this attachment is also included in this updated matrix for 

reference.

In developing Revision 2 to the matrix, SC&A reviewed the transcripts from 16 successive Work 

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

memorandum reports related to the 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. These findings 

are labelled as TBD-1 through TBD-33 in this document. It also considers issues that emerged 

from Work Group discussions of SC&A’s review of the SEC-00046 evaluation report (ER), 

which was delivered to the Advisory Board in June 2007. SC&A’s SEC ER review identified 30 

original findings, which were eventually merged into six general categories as a result of Work 

Group deliberations. One additional finding concerning the performance standards of external 

dosimetry was added to the six general categories. These SEC-related findings are labelled 

SEC P-1 through SEC 4.5-1 in this document.

Before the release of Revision 2 to the Fernald issues matrix, a Work Group teleconference 

meeting was held on April 15, 2014, at which time 5 of the original 33 site profile findings were 

recommended to be closed. After the release of Revision 2, the Fernald Work Group met on 

September 3, 2014, to discuss the status and actions required to close out the remaining site 

profile findings. During that meeting, the Work Group recommended closing an additional 15 

findings. The final Work Group meeting in 2014 took place on December 4, during which 

another seven findings were recommended to be closed, as reflected in Revision 4 to the matrix.

This current version of the issues matrix (Revision 5) reflects the discussions and 

recommendations of the July 28, 2017, Work Group meeting and provides an updated status on 

the remaining site profile and SEC issues not currently recommended for closure. In addition to 

the site profile and SEC issues, this matrix revision includes issues related to the thorium and 

uranium coworker models (NIOSH 2014a and 2015, respectively). These findings and 

observations are described in detail in SC&A 2014b (thorium coworker model review) and 

SC&A 2016 (uranium coworker model review). In this matrix update, the coworker-specific

findings are labelled as Th-1 through Th-Obs7 (for thorium) and U-1 through U-Obs6 (for 
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uranium). It is SC&A’s hope that this update will assist the Work Group and provide a roadmap 

to effectively resolve the remaining issues at Fernald.
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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

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 ORAUTTBKS-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. [Cell continued on next page.]

10/15/2013: 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 post1978 coworker model, which is based on 

bioassay data. SC&A’s Completeness and 

Adequacy of Thorium In-Vivo Records (1979–

1989), November 2012, states: 

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.

4/15/2014: WG recommends closure 

(ABRWH 2014a, p. 71).

Agreed. Closed
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Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

Status

TBD 1 

cont.

[Cell continued from 

previous page; no 

content on this page.]

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.

[Cell continued from previous page; no content 

on this page.]

[Cell continued from 

previous page; no content on 

this page.]

[Cell 

continued 

from 

previous 

page; no 

content on 

this page.]

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.

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.

10/15/2013: SC&A suggests closing this 

finding because the NIOSH coworker model 

for 1979–1988 does not employ air 

concentration data.

4/15/2014: WG recommends closure

(ABRWH 2014a, pp. 71–72).

Agreed. Closed
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Doc No Finding Text History SC&A Comments NIOSH Response to 

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Status

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 pre1986 period and for 

those workers 

without lapel air 

sampling in the post1986 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 non-operating 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.

10/15/2013: SC&A suggests closing this 

finding because the NIOSH coworker model 

for 1979–1988 does not employ air 

concentration data.

4/15/2014: WG recommends closure

(ABRWH 2014a, p. 72). 

Agreed. Closed
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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. 

6/24/2014: NIOSH releases the white paper 

Fernald Dose Reconstruction Methodology for 

the Post Special Exposure Cohort (SEC) 

Period, 1979–2006. 

11/26/2014: SC&A completes its review of the 

proposed thorium dose reconstruction 

methodology covering thorium redrumming 

operations to be discussed at the Fernald Work 

Group meeting (12/4/2014).

10/15/2013: 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 do not 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.

4/10/2014: The proposed method for 1990–

1994 is new.

According to ORAUT-TKBS-0017-2, Rev. 01, 

the site production mission has been terminated 

and the site underwent remediation and cleanup 

from 1989 to 2006. 

Table 2-2 indicates that thorium repackaging 

was going on 1990–1993. 

SC&A will need to review the implications for 

thorium DR during remediation and cleanup 

and report back at a later WG meeting. 

4/15/2014: WG recommends keeping this 

finding open (ABRWH 2014a, pp. 72–73). 

8/25/2014: SC&A recommends keeping this 

finding open pending our formal review of the 

NIOSH white paper on post-SEC thorium 

methodology (mid-late October 2014).

11/26/2014: SC&A has completed its review of 

the NIOSH white paper and recommends the 

finding be designated “in progress” pending 

WG discussions on 12/4/2014.

12/4/2014: The WG recommended closure of 

this issue (ABRWH 2014c, p. 125).

For the 1979–1994 

timeframe, if in vivo results 

exist, then they will be used 

to reconstruct thorium dose. 

For 1979–1989, if there are 

no in vivo results, then 

coworker doses will be 

assigned. (A coworker 

thorium study is in 

development.) 

For 1990–1994, if there are 

no in vivo results, thorium 

doses can be assigned based 

on an intake of 10% of the 

derived air concentration 

(DAC) for the year, as 

appropriate. 

Closed
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Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

Status

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 2007a, p. 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.

6/24/2014: NIOSH releases the white paper, 

Fernald Dose Reconstruction Methodology for 

the Post Special Exposure Cohort (SEC) 

Period, 1979–2006. 

11/26/2014: SC&A completes its review of the 

proposed thorium dose reconstruction 

methodology covering thorium redrumming 

operations to be discussed at the Fernald Work 

Group meeting (12/4/2014).

10/15/2013: SC&A suggests closing this 

finding because the NIOSH coworker model 

for 1979–1988 does not employ air 

concentration data.

4/10/2014: Preliminary review of ORAUTTKBS-0017-02 Rev. 01 indicates possible 

relevance for 1990–1994 thorium redrumming 

operations. See response to Item 4. 

4/15/2014: WG recommends keeping this 

finding open (ABRWH 2014a, p. 73). 

8/25/2014: SC&A recommends keeping this 

finding open pending our formal review of the 

NIOSH white paper on post-SEC thorium 

methodology (mid-late October 2014).

11/26/2014: SC&A has completed its review of 

the NIOSH white paper and recommends the 

finding be designated “in progress” pending 

WG discussions on 12/4/2014.

12/4/2014: The WG recommended closure of 

this issue (ABRWH 2014c, p. 128).

Agreed. Closed
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Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

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.

10/15/2013: SC&A suggests closing this 

finding because the NIOSH coworker model 

for 1979–1988 does not employ air 

concentration data.

4/15/2014: WG recommends closure

(ABRWH 2014a, pp. 73–74).

Agreed. Closed
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Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

Status

TBD 7 The TBD does not 

specify a method for 

estimating doses in 

the raffinate streams, 

which are uraniumpoor, from ore 

processing in 

Plant 2/3. These 

doses may be very 

difficult to calculate, 

especially for highgrade ores, notably 

pitchblende ore from 

Congo. 

This also 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 

Th-230.” 

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 ORAUTRPRT-0052 (ORAUT 2011b). RPRT-0052, 

pp. 24–25: Transfer of drummed K65 raffinate 

to Silos 1 and 2 late 1952–June 1953; 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 provides 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 ratioing 

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.

10/15/2013: SEC recommends this issue be 

changed to “in abeyance” pending revised 

TBD.

4/10/2014: New revision of ORAUT-TKBS0017-5 not yet available. October 2013 

recommendation holds. 

8/25/2014: October 2013 recommendation

holds. 

11/18/2014: SC&A believes this issue is far too 

complex to be put in abeyance without a formal 

review. SC&A recommends that it be changed 

to “open” until we have an opportunity to 

review the revised internal dose portion of the 

Fernald site profile.

12/4/2014: This issue was discussed during 

work group deliberations and it was 

recommended this finding be put “in progress” 

while NIOSH develops methods for assessing 

dose to raffinates. (ABRWH 2014c, p. 149) 

7/28/2017: This issue was discussed during 

Work Group deliberations. NIOSH’s 

position is that there is no exposure potential 

to uranium and radium-poor raffinates due 

to the nature of process equipment and 

physical form of the material. NIOSH is to 

provide an official written position on 

uranium and radium-poor raffinates 

exposure potential. SC&A recommends that 

the issue remain In Progress pending release 

of formal NIOSH position.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

provides a method for 

estimating raffinate streams, 

which will be incorporated 

into ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald 

Environmental Management 

Project (FEMP) – 

Occupational Internal Dose,” 

and ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revisions. 

ORAUT-OTIB-25, 

“Estimation of Radium-226 

Activity in the Body from 

Breath Radon-222 

Measurements,” which is 

included in ORAUT-RPRT0052, provides a method for 

reconstructing doses from 

radon breath analyses results 

from 1952–1954 and this 

methodology will be included 

into the internal TBD 

revision. 

In 

Progress
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Doc No Finding Text History SC&A Comments NIOSH Response to 

Revision 0

Status

TBD 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. 10/15/2013: See response to Finding 7.

11/18/2014: SC&A believes this issue is far too 

complex to be put in abeyance without a formal 

review. SC&A recommends that it be changed 

to “open” until we have an opportunity to 

review the revised Internal Dose portion of the 

Fernald site profile.

12/4/2014: This issue was discussed during 

Work Group deliberations and it was 

recommended this finding be put “in progress” 

while NIOSH develops methods for assessing 

dose to raffinates. (ABRWH 2014c, p. 149)

7/28/2017: This issue remains In Progress 

(see status details under Finding 7).

See NIOSH response 7. In 

Progress
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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.

10/15/2013: SC&A recommends finding be 

changed to “in abeyance” pending revised 

TBD. 

4/10/2014: New revision of ORAUT-TKBS0017-5 not yet available. October 2013 

recommendation holds. 

ORAUT-RPRT-0052 (July 2011), Section 4.5, 

Table 18 does not reflect agreed-upon 

constituent levels from WG discussions on 

February 9, 2012 [See SC&A white paper titled 

SC&A’s Response to NIOSH’s Subgroup 10A 

Impact Analysis Dated November 1, 2011 

(SC&A 2012a)]. 

Need to verify that what was agreed upon in 

WG meetings is, in fact, incorporated into 

ORAUT-TKBS-0017-5 and any related 

guidance documents.

8/25/2014: SC&A recommends that this 

finding be kept in abeyance pending revision of 

ORAUT-TKBS-0017-5.

11/18/2014: August 2014 recommendation 

holds. 

12/4/2014: August 2014 recommendation 

holds. (ABRWH 2014c, p. 153) 

7/28/2017: This issue was discussed during 

the Fernald WG meeting. NIOSH has 

revised its position on recycled uranium 

contaminant ratios for the period 1961–

1972. NIOSH is to provide an official written 

position on the revised ratios. Issue to 

change from “In Abeyance” to “In 

Progress.”

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents, 

which will be incorporated 

into ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald 

Environmental Management 

Project (FEMP) – 

Occupational Internal Dose,” 

and ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revisions.

In 

Progress
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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.

10/15/2013: SC&A notes that while NIOSH 

has provided a method for bounding intakes 

from Pu, Np-237, 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.

4/10/2014: New revision of ORAUT-TKBS0017-5 not yet available. ORAUT-RPRT-0052 

does not address these other constituents, nor 

have they been discussed in the WG setting. 

October 2013 recommendation holds.

8/25/2014: SC&A recommends keeping this 

finding open pending upcoming revision to 

ORAUT-TKBS-0017-5. 

11/26/2014: SC&A recommendation from 

8/25/2014 holds.

12/4/2014: The issue of potential Am-241 in 

recycled uranium was discussed with the Work 

Group. NIOSH has agreed to specifically 

address whether significant Am-241 exposure 

is feasible at Fernald and, if so, how to account 

for it. The Work Group placed this issue “In 

Progress.” (ABRWH 2014c, pp. 154–167) 

7/28/2017: The issue of Am-241 was 

discussed during the WG meeting. The 

revised TBD discusses Am-241 exposures 

and provides information/methods that are 

consistent with the assumption of RU as 

Hanford 6% weapons-grade material. The 

WG recommends closure.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents 

and has revised ratios for 

recycled uranium constituents 

that will be incorporated into 

ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald 

Environmental Management 

Project (FEMP) – 

Occupational Internal Dose,” 

and ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revisions.

Closed
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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 the 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.

10/15/2013: SC&A recommends finding be 

changed to “in abeyance” until agreed upon 

method is incorporated into the TBD.

8/25/2014: SC&A recommends keeping this 

finding in abeyance pending upcoming revision 

to ORAUT-TKBS-0017-5.

11/26/2014: SC&A recommendation from 

8/25/2014 holds.

12/4/2014: This item was not discussed at the 

Work Group meeting. Recommendation from 

8/25/2014 holds.

7/28/2017: Issue to change from “In 

Abeyance” to “In Progress” (see status 

details under Finding 9).

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents 

for all workers, which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,”

revisions.

In 

Progress
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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 

periods and batches 

when uranium of 

higher enrichments 

were processed. 

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 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 

 (SRDB Ref. ID 41661); 9/11/07 

interview with (SRDB Ref. ID 38132); 

8/30/07 interview with 

(SRDB Ref. ID 38124). 

10/28/08 (ABRWH 2008, 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 accepts the 2% position and closed 

the finding.

10/15/2013: WG closed10/28/08 (ABRWH 

2008, pp. 200–217). 

4/15/2014: WG agrees with WG 10/28/08 

closure recommendation (ABRWH 2014a, 

p. 74). 

Agreed. Closed
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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. 

[This cell is continued on the next page.]

10/15/2013: Closed

4/15/2014: WG decided to put in abeyance 

pending review of TBD revision (ABRWH 

2014a, pp. 74–78). Virtually identical to 

Finding 21.

8/29/2014: This finding predated the internal 

dose coworker models now in use for 

unmonitored workers – SC&A recommends 

closure.

Note that NIOSH’s response to this finding 

actually pertains to Finding 21, which 

addresses the external dose to unmonitored 

female employees.

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 133–137).

Agreed.

ORAUT-OTIB-0073, 

“External Coworker 

Dosimetry Data for the 

Fernald Environmental 

Management Project,” will be 

incorporated into ORAUTTKBS-0017-6, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project – 

Occupational External Dose,” 

and will be used for 

unmonitored workers. 

Due to changed project 

approaches towards 

unmonitored worker dose 

assignment, missed dose is no 

longer used to assign 

unmonitored doses and the 

500 mrem upper bound dose 

methodology will be removed 

during the TBD revision 

process since the coworker 

model will bound 

unmonitored workers.

Closed
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TBD 13 

cont.

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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.

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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.

10/15/2013: SC&A recommends that this 

finding be closed.

4/15/2014: WG recommends closure 

(ABRWH 2014a, p. 79).

Agreed. Closed
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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 [Morris 2009] 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, Th232, and the radionuclides associated with 

raffinates and RU, ingestion intakes and 

doses would be calculated using OCASTIB-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 for 

1954–1978 and U doses cannot be 

reconstructed for subcontractors for 1951–

1983. The thorium coworker model post-1978 

relies on chest count data, and ingestion 

modeling is still an issue for discussion.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Findings associated with OCASTIB-009, Estimation of Ingestion Intakes, have 

been closed by the Procedures Review 

Subcommittee (PRSC). SC&A agreed that the 

NIOSH method is scientifically defensible and 

claimant favorable.

8/25/2014: SC&A recommends keeping this 

issue in abeyance pending ORAUT-TKBS0017-5 revision.

11/26/2014: SC&A recommendation from 

8/25/2014 holds.

12/4/2014: This item was not discussed at the 

Work Group meeting. Recommendation from 

8/25/2014 holds.

7/28/2017: This item was discussed during 

the WG meeting. The updated internal dose 

TBD includes references to TIB-009 and the 

application of ingestion doses related to the 

use of air concentration data to reconstruct 

thorium doses for 1990–2006. The WG 

recommends closure.

OCAS-TIB-009, “Estimation 

of Ingestion Intakes,” 

provides an approach toward 

thorium ingestion doses and 

will be included in the 

ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald 

Environmental Management 

Project (FEMP) – 

Occupational Internal Dose,” 

revision. 

Closed
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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.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion. 

4/10/2014: SC&A agrees that ORAUT-OTIB0017, Interpretation of Dosimetry Data for 

Assignment of Shallow Dose, largely puts this 

finding to rest. However, we have not yet 

reviewed ORAUT-TKBS-0017-6 to verify that 

the revision adequately addresses our concerns. 

Recommend keeping open until we can verify.

8/25/2014: SC&A recommends closure (see 

attachment for detailed description).

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 138–140).

ORAUT-OTIB-0017, 

“Interpretation of Dosimetry 

Data for Assignment of 

Shallow Dose,” is referenced 

in the ORAUT-TKBS-0017-

6, “Technical Basis 

Document for the Fernald 

Environmental Management 

Project – Occupational 

External Dose,” revision and 

provides the protocols for 

reconstructing shallow 

external dose. ORAUTOTIB-0017 was not available 

when ORAUT-TKBS-0017-

6, “Fernald Site – 

Occupational External Dose” 

(04/20/2004), was approved. 

Closed
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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 until 

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.

[This cell is continued on the next page.]

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: SC&A notes that 5 of 6 findings 

associated with DCAS-TIB-0013 (DCAS 

2010) have been closed under the PRSC. 

However, we have not yet reviewed ORAUTTKBS-0017-6 to verify that the revision 

adequately addresses our concerns. 

Recommend keeping this finding open until we 

can verify.

8/25/2014: SC&A recommends that this issue 

remain open pending related investigations at

INL (see attachment for detailed description).

9/3/2014: Discussed (ABRWH 2014b, pp. 

141–151). 

11/26/2014: 8/25/14 recommendation holds.

12/4/2014: This item was not discussed at the 

Work Group meeting. Recommendation from 

8/25/2014 holds.

7/28/2017: This item was discussed during 

the WG meeting, in which it was determined 

that the treatment of extremity doses is a 

program-wide issue currently under review 

by the PRSC. SC&A is to provide a memo to 

the PRSC detailing concerns with beta dose 

to extremities. This finding is to be 

transferred to the PRSC as part of the 

review of OTIB-0013. The finding is closed 

as it relates to the Fernald TBD review.

The ORAUT-TKBS-0017-6, 

“Fernald Site – Occupational 

External Dose,” revision 

references DCAS-TIB-0013, 

“Selected Geometric 

Exposure Scenario 

Considerations for External 

Dose Reconstruction at 

Uranium Facilities,” and 

provides geometry factors for 

uranium dose and 

adjustments for wrist to hand, 

so that extremity doses are 

not underestimated. DCASTIB-0013 was not available 

when ORAUT-TKBS-0017-

6, “Fernald Site – 

Occupational External Dose,” 

(04/20/2004) was approved.

Transferred
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TBD 17 

cont.

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10/28/08: SC&A acknowledges that this is not 

an SEC issue, because extremity cancers are 

uncommon. Until the 1980s, 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.

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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.

[This cell continues on next page of matrix.]

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion. 

Contact beta dose is currently under review in 

the PRSC.

4/10/2014: SC&A’s position summary on 

localized skin exposure, SC&A Position 

Regarding Skin Exposures Associated with the 

Direct Deposition of Fine Particles and Flakes 

of Uranium Oxide onto Skin and Clothing,

January 2014, has been discussed under the 

PRSC and is slated for discussion at the 

4/16/2014 PRSC meeting. Recommend 

keeping this finding open until PRSC 

discussions are completed.

8/25/2014: SC&A recommends closure – 

virtually identical to Finding 16. 

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 138–140).

The majority of these issues 

are global issues which are 

being addressed through the 

Procedures Review 

Subcommittee.

For known skin 

contaminations, VARSKIN is 

used. Unknown skin 

contaminations cannot be 

addressed.

Closed
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TBD 18 

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3/18/08: See the 1958 radiation survey on 

clothing reported in SRDB Ref. ID 4136. 

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. SRDB Ref. ID 4330, 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 (ABRWH 2008, pp. 356–365):

SC&A will review the procedures NIOSH 

placed on O Drive (NLO document, several 

SOPs and SRDB Ref. IDs 3173, 33975).

Issue was not discussed after this meeting.

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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. 10/15/2013: 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. 

8/29/2014: SC&A recommends that this issue 

remain open.

There are basically two issues with applying 

DCAS-TIB-0013 to Fernald: 

1. First, NIOSH has agreed that the correction 

factors apply to photons but not to electrons 

(betas), which are a significant source of 

exposure at Fernald. Consequently, the betadose correction to the film badge readings 

needs to be re-evaluated. Also see response 

to Finding 17.

2. Notwithstanding the above comment, TIB13 is “in progress.” The last revision posted 

on the DCAS Web site is dated 2010. There 

have been several reviews, discussions, and 

correspondence from that date until February 

2013, when the last NIOSH response was 

received. However, nothing has been done 

since then.

Consequently, it is probably inappropriate to 

cite TIB-13 as a methodology for DR at 

Fernald when it has not been accepted by 

SC&A or by the ABRWH Subcommittee on 

Procedures Review.

9/3/2014: 8/25/14 recommendation holds.

12/4/2014: This item was not discussed at the 

work group meeting. Recommendation from 

8/25/2014 holds.

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The revision to ORAUTTKBS-0017-6, “Fernald Site 

– Occupational External 

Dose” references DCAS-TIB0013, “Selected Geometric 

Exposure Scenario 

Considerations for External 

Dose Reconstruction at 

Uranium Facilities.”

Since the factor was 

determined by an analysis of 

photon fluence (not dose 

computation), the 

recommendations of the TIB 

would apply to workers 

exposed to thorium as well.

Transferred
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7/28/2017: This item was discussed during 

the WG meeting, in which it was determined 

that the treatment of extremity doses is a 

program-wide issue currently under review 

by the PRSC. SC&A is to provide a memo to 

the PRSC detailing concerns with beta dose 

to extremities. This finding is to be 

transferred to the PRSC as part of the 

review of OTIB-0013. The finding is closed 

as it relates the Fernald TBD review.

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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 2007a, 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 issues matrix 

indicates:

A “Status Report - NLO Health Physics 

Appraisal” dated 7-10-84 (to Thiessen 

from Adams) [FEMP 1998] has been found 

indicating that changes to recorded doses 

may have made. Interviews are continuing 

to discover if additional corrections were 

applied. (SC&A 2008a) 

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: SC&A will need to check the cited 

references and TBD revision to verify. October 

2013 recommendation holds – keep open.

8/29/14: SC&A has reviewed the process and 

believes the methodology is not without error; 

however, it is consistent with other NIOSH 

assumptions that have been accepted (e.g., 

LOD/2 for external dose and MDA/2 for 

internal dose).

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 152–158).

The appropriate TLD 

correction factors (based on 

the Gesell algorithm) were 

retroactively applied to 

dosimetry records from the 

beginning of TLD 

implementation (i.e., the 

period 1983–1985) as 

described in “Feed Materials 

Production Center, Final 

Phase-In Report, Volume 4 of 

15, Environment, Safety, and 

Health” (SRDB 3247) and 

“Status Report - NLO Health 

Physics Appraisal, July 10, 

1984” (SRDB 12405).1

1 Note that the document at SRDB Ref. ID 3247 has a different title, Fernald Litigation Depositions (1985–1994). Note that in SRDB Ref. ID 12405 we find a letter headed “Status 

Report – NLO Health Physics Appraisal – 1983” and stamped July 10, 1984. The document at SRDB Ref. ID 12405 is a duplicate of the document at SRDB Ref. ID 4330, 

referenced as FEMP 1998 elsewhere in this report.

Both references describe the 

deficiencies found in the 

original TLD algorithm 

developed by Plato, and the 

studies, comparisons, and 

field work undertaken to 

develop a more precise 

algorithm (the Gesell 

algorithm).

The deficiencies of the Plato 

algorithm affected the 

precision of electron dose 

measurements and resulted in 

overestimates of electron 

dose. 

Closed

 
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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. 

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10/15/2013: SC&A recommends finding be 

changed to “in abeyance” until agreed-upon 

method is incorporated into the TBD

4/10/2014: October 2013 recommendation 

holds – keep in abeyance pending review of 

ORAUT-TKBS-0017-6 to verify that the 

revision adequately addresses our concerns.

4/15/2014: WG decided to put #13 and #21 

(internal and external dose aspects, 

respectively) in abeyance (ABRWH 2014a, pp. 

74–78). 

8/29/2014: SC&A has reviewed pertinent 

sections of ORAUT-TKBS-0017-6, Rev. 01 

and Attachment A and confirmed NIOSH’s 

statements that missed dose is no longer used 

to assign unmonitored external doses and the 

500 mrem upper bound dose methodology has 

been removed. Further, Section 6.6.2 of the 

TBD revision refers to ORAUT-OTIB-0017, 

Technical Information Bulletin: Interpretation 

of Dosimetry Data for Assignment of Shallow 

Dose (10/11/2005). The section titled “NonUniform Exposure of the Skin” has been 

further clarified at numerous Work Group 

meetings. See SC&A response to Finding 16 in 

the attachment for additional detail.

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 158–159).

See NIOSH Response 13. Closed
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TBD 21 

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Discussed at the November 13, 2007, meeting. 

Decided this was an issue isolated to a few 

individuals and should be evaluated on a caseby-case basis in DR.

April 22, 3009, meeting: Issue closed. Decided 

three methods suggested are sufficient.

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TBD 22 The source term for 

atmospheric uranium 

emissions from 

Fernald is 

significantly 

underestimated.

This was discussed briefly in the November 

24, 2007, meeting (ABRWH 2007b, p. 247), 

but was not discussed further.

10/15/2013: SC&A recommends that this 

finding remain “open” as a topic for WG 

discussion.

4/10/2014: October 2013 recommendation 

holds – keep open. SC&A will need to review 

ORAUT-TKBS-0017-4, Rev. 02 to determine 

whether our concerns are adequately addressed.

8/25/2014: SC&A recommends closure (see 

attachment for detailed description).

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 160–165).

From October 24, 2007, 

meeting, NIOSH believes that 

stacks were functional and 

that the majority of source 

material was released from 

here, by design, therefore; the 

emissions are not 

underestimated.

The stack emission data was 

used in the ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose” 

revision for the operational 

period. 

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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 (ABRWH 2007a, p. 38). 

NIOSH used RAC Report Number CDC-5 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).

10/15/2013: SC&A recommends that this 

finding remain “open” as a topic for WG 

discussion.

4/10/2014: October 2013 recommendation 

holds – keep open. SC&A will need to review 

ORAUT-TKBS-0017-4, Rev. 02 to determine 

whether our concerns are adequately addressed.

8/25/2014: SC&A recommends closure (see 

attachment for detailed description).

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 168–171).

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revision uses a 

standard annualized Gaussian 

model including assumptions 

regarding atmospheric 

stability that are claimant 

favorable.

Short-term episodic releases 

are modeled using the “Puff” 

model instead of the 

continuous release model. A 

factor to account for 

respirable fraction of particles 

is included.

Closed

TBD 24 Diffuse emissions of 

uranium and thorium 

may have produced 

significant internal 

exposures for some 

personnel. 

This topic has not previously been discussed. 10/15/2013: SC&A recommends that this 

finding remain “open” as a topic for WG 

discussion.

4/10/2014: October 2013 recommendation 

holds – keep open. SC&A will need to review 

ORAUT-TKBS-0017-4 revision to determine 

whether our concerns are adequately addressed.

8/25/2014: SC&A recommends keeping this 

issue open for discussion (see attachment for 

detailed description). 

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 171–177).

See NIOSH response to #22. 

In addition to stack effluent 

for the operational period, 

NIOSH has identified 

releases of thorium and 

uranium that emerged from 

building exhaust, waste pits, 

UF6 release from storage 

containers and six 

specifically identified offnormal events. NIOSH is 

unaware of any additional 

significant sources.

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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. 10/15/2013: SC&A suggests this finding be 

subsumed into SEC Primary Issue 5 (moved to 

TBD issues April 2011).

4/10/2014: Recommend that this issue remains 

open. SC&A will need to review ORAUTTKBS-0017-4, Rev. 02 to determine whether 

our concerns are adequately addressed.

8/29/2014: See response to SEC Issue 5.

9/3/2014: WG recommends issue remain open 

(ABRWH 2014b, pp. 178–218). NIOSH to 

prepare a response for the next WG meeting.

12/4/2014: The issue was discussed during the 

Work Group meeting and it was determined 

that NIOSH would apply the 95th percentile of 

the modeled doses in the RAC report. The 

work group recommends closure (ABRWH 

2014c, pp 185–245)

7/28/2017: Officially closed by the WG.

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision incorporates 

radon intake modeling which 

has been included in 

Gaussian dispersion 

calculations. 100% of radon 

and progeny are assumed to 

respirable. 

An assumption regarding the 

equilibrium between radon 

and progeny has been made 

that is favorable to the 

claimant and likely to exist 

only indoors under stagnant 

air flow conditions.

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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 Q11 silos was identified in the Pinney Report (O 

drive). 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 Penny 

of University of Cincinnati took into 

consideration in addition to the K-65 silos 

other potential source terms of radon. Those 

included some of those specific bins outside of 

the refinery, in which the Q-11 ore was 

contained. 

10/28/08 (ABRWH 2008, p. 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.

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10/15/2013: SC&A suggests this finding be 

subsumed into SEC Primary Issue 5 (moved to 

TBD issues April 2011).

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review ORAUTTKBS-0017-4, Rev. 02 to determine whether 

our concerns are adequately addressed.

8/29/2014: See responses to Finding 25 and 

SEC Issue 5.

9/3/2014: WG recommends issue remain open 

(ABRWH 2014b, pp. 178–223). NIOSH to 

prepare a response for the next WG meeting. 

12/4/2014: WG recommends closure (ABRWH 

2014c, pp 185–245). 

7/28/2017: Officially closed by the WG.

The ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revision includes 

effluent from Q11 silos.

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TBD 26 

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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.

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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. 10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue remains 

open. SC&A will need to review ORAUTTKBS-0017-4, Rev. 02 to determine whether 

our concerns are adequately addressed.

8/25/2014: SC&A recommends closure (see 

attachment for detailed description).

11/26/2014: This issue was discussed at the 

9/3/2014 WG meeting. The WG agreed that the 

main issue could be closed, with the proviso 

that specific language be added to the TBD 

regarding direct deposition on the skin. 

Specifically, that the procedures present in 

OTIB-0017 be directly referenced and 

implemented in the Fernald TBD. NIOSH did 

not foresee any issues with this stipulation. 

Therefore, SC&A recommends changing this 

status to “in abeyance” pending the 

modification of the site profile (ABRWH 

2014b, pp. 223–229).

12/4/2014: This item was not discussed at the 

Work Group meeting. Recommendation from 

11/26/2014 holds.

7/28/2017: Issue was discussed during the 

WG meeting. The current version of the 

environmental TBD contains specific 

language referencing OTIB-0017 methods to 

be used for localized “direct deposition” 

exposures. The WG recommends closure.

The “Exposure Areas” 

concept is also applied to 

external dose consistent with 

the NIOSH position on 

Item 22 for the ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose”

revision.

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TBD 28 External 

environmental dose 

for workers near the 

K-65 silos needs to 

be better evaluated.

Finding 28 is discussed in Section 5.9.2 of 

SC&A’s 2006 review of the Fernald site 

profile. The full text of this issue is relatively 

brief and is repeated here:

The TBD is silent on how external doses to 

workers from the silos were derived for 

persons that may have spent time in the 

area of Fernald containing the silos (i.e., 

EA-6). This is of particular concern for the 

early years before additional shielding was 

provided for the silos. It is also of concern 

for those unmonitored workers who may 

have taken breaks near the silos. For 

instance, it may especially affect female 

employees during the years when they were 

not monitored.

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review ORAUTTKBS-0017-4, Rev. 02 to determine whether 

our concerns are adequately addressed.

8/29/2014: SC&A recommends closure (see 

attachment for detailed description).

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 229–240).

The external environmental 

dose for workers near the K--

65 silos is addressed in the 

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project – 

Occupational Environmental 

Dose,” revision. 

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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. Needs more research.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review ORAUTTKBS-0017-4, Rev. 02 to determine whether 

our concerns are adequately addressed.

8/29/2014: NIOSH’s recommendation that 

1953 radon exposure be added to the SEC 

would make this finding moot. However, 

SC&A has seen no description of the proposed 

class or mention of it other than in this issues 

matrix entry. We recommend keeping this 

finding open for discussion in the Work Group 

setting.

11/26/2014: This issue was discussed at the 

9/3/2014 WG meeting. It was agreed that 

estimation of radium body burdens has been 

addressed in prior discussions and that methods 

in RPRT-0052 will be employed in the site 

profile. 

Additional discussions regarding a different 

source term of Th-230 exposure (transfer of 

Th-230 bearing material from plant operations 

to Silo 3) that will need to be addressed. The 

WG recommended placing this finding “in 

abeyance” pending release of the new Fernald 

internal TBD.

These issues remain in abeyance until we can 

review the next revision of TBD-5 (ABRWH 

2014b, pp. 240–261).

12/4/2014: This item was not discussed at the 

work group meeting. Recommendation from 

11/26/2014 holds.

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Radon from the material 

stored in drums at Plant 1 is 

now a source term for 1951, 

1952, and 1953 before the 

material was moved into the 

K65 silo in the ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,”

revision. NIOSH has 

recommended that 1953 

radon exposure be added to 

the SEC.

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TBD 29 

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7/28/2017: This issue was discussed during 

the WG meeting. The current revision of the 

internal dose TBD contains acceptable dose 

reconstruction methods developed in RPRT0052. Note: NIOSH does not recommend 

that 1953 radon exposure be added to the 

SEC. The WG recommends closure.

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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.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review ORAUTTKBS-0017-3, Rev. 01 to determine whether 

our concerns are adequately addressed.

8/29/2014: See attachment for detailed 

response for Findings 30–32.

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 261–265).

No evidence of PFG has yet 

turned up for Fernald. This 

includes no evidence in claim 

files, no historical 

documentation of PFG 

equipment, and no evidence 

in several reviews of actual 

film folders of Fernald 

workers that have been 

performed over the years.

Closed

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. 10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue be held 

in abeyance until SC&A verifies the stated 

change to ORAUT-TKBS-0017-3, Rev. 01.

8/29/2014: See attachment for detailed 

response for Findings 30–32.

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 261–265).

The reference for this piece 

of information was not found 

in the historical information, 

and so it was removed from 

the revision of ORAUTTKBS-0017-3, “Fernald 

Environmental Management 

Project – Occupational 

Medical Dose.”

Closed
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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.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review ORAUTTKBS-0017-3, Rev. 01 to determine whether 

our concerns are adequately addressed.

8/29/2014: See attachment for detailed 

response for Findings 30–32. 

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 261–265).

The current version of the 

ORAUT-TKBS-0017-3, 

“Fernald Environmental 

Management Project – 

Occupational Medical Dose,” 

assumes poor collimation

prior to 1970.

Closed

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.

10/15/2013: SC&A recommends finding be 

classified “open” as a topic for WG discussion.

4/10/2014: Recommend that this issue remain 

open. SC&A will need to review the stated 

claim file records to determine whether our 

concerns are adequately addressed.

8/29/2014: SC&A has also reviewed more than 

30 cases focusing on Laborers and other trades 

workers whose job duties might include heavy 

lifting and came to the same conclusion as 

NIOSH. Any sort of lumbar or spinal x-ray was 

designated as “dispensary.” Pre-employment 

physicals only ever included a chest x-ray. The 

pre-employment questionnaire and medical 

evaluation (present in some reviewed claims) 

contains a section on x-rays with only a 

checkbox for “chest.” 

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 261–265). 

It is very clear that the few 

lumbar spine x-rays in claim 

file records (

 are indicated 

as having been performed for 

“dispensary” and not 

“annual,” “pre,” or “term”; 

very strongly suggesting that 

lumbar spine x-rays were 

performed for back pain (a

common ailment), or for 

workplace injuries, not for 

screening. 

31 claims out of 1,790 work 

periods/claims were reviewed 

and there were 0 nondispensary lumbar spines in 

this random sample.

Closed
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P

1 Concerns regarding

the completeness and 

adequacy of the 

uranium bioassay 

data available for 

dose reconstruction 

and supporting the 

Fernald internal 

dosimetry coworker 

model (OTIB-0078)

An SEC class was recommended for

subcontractors from 1951 to 1983 based on 

lack of data for subcontractors before the mid1980s and the fact that the coworker model 

could not be shown to be bounding for that 

class of workers (SEC 3). However, NIOSH 

was able to demonstrate that enough data were

available for 1984–1985 to construct a separate 

subcontractor coworker model for those 2 

years.

— — Closed

SEC 

P

2a Complete the 

validation of the 

accuracy with which 

hardcopy dosimetry 

data were converted 

into electronic data 

for the HIS-20 

database

On December 3, 2010, NIOSH delivered a 

complete validation study that resolved all of 

SC&A’s concerns.

— — Closed

SEC 

P

2b Concerns regarding 

the integrity of the 

hardcopy bioassay 

data, as raised by the 

petitioner.

SC&A’s report describes strategies for 

investigating data integrity issues that could 

adversely affect the ability to reconstruct 

internal doses (SC&A 2010d).

The Work Group agreed that any such 

investigations would require considerable time 

and costs and will likely be inconclusive – no 

further actions tasked.

— — No 

Further 

Actions 

Tasked
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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.

10/15/2013: SC&A recommends issue be 

placed “in abeyance” until implemented in site 

profile.

4/10/2014: Recommend that related site profile 

issues be placed in abeyance. SC&A will need 

to review relevant TBD revisions to determine 

whether our concerns are adequately addressed. 

See response to Finding 9.

8/25/2014: SC&A recommends that this 

finding be kept in abeyance pending revision of 

ORAUT-TKBS-0017-5.

11/26/2014: August 2014 recommendation 

holds. However, note that only the three 

primary contaminants have been addressed and 

other radionuclides may be relevant to dose 

reconstruction (for example, Am-241 from 

Finding 10).

12/4/2014: Based on discussions occurring 

during the Work Group meeting, it was 

recommended this finding be changed from “in 

abeyance” to “in progress” pending NIOSH 

investigations into potential exposures to Am241 in recycled uranium. See also update to 

Finding 10. (ABRWH 2014c, pp 154–167).

7/28/2017: This item was discussed during 

the WG meeting. The issue of RU 

contaminant ratios is no longer an SEC 

issue. However, NIOSH has altered its 

approach to assignment of RU contaminants 

and is to provide an official written response 

on the issue. The WG recommends the issue 

remain “In Progress” pending development 

and discussion of NIOSH’s new position (see 

TBD Findings 9 and 11). The portion of this 

finding related to Am-241 has been 

recommended for closure (see TBD 

Finding 10).

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

provides an upper bound on 

intakes from RU constituents 

for all workers, which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,”

revisions.

In 

Progress
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4 Review 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 

ORAUT-RPRT-0052 (ORAUT 2011b)] to 

SC&A’s white paper, Review of the NIOSH 

“White Paper on Fernald Th-230 and Other 

Associated Radionuclides – Rev. 7” (SC&A 

2010c), that summarizes their position. Moved 

to site profile at the April 19, 2011, WG 

meeting (ABRWH 2011).

10/15/2013: SC&A recommends issue be 

placed “in abeyance” until implemented in site 

profile.

4/10/2014: Recommend that related site profile 

issues be placed in abeyance. SC&A will need 

to review relevant TBD revisions when they 

become available to determine whether our 

concerns are adequately addressed.

8/29/2014: SC&A recommends that this 

finding be kept in abeyance pending revision of 

ORAUT-TKBS-0017-5.

11/26/2014: August 2014 recommendation 

holds. See response to TBD Finding 29.

12/4/2014: The Work Group recommends 

closure (ABRWH 2014c, pp. 249–252).

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides a method for use of 

radon breath data for 

reconstructing doses from 

inhalation of Ra-226 and Th230 which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose.” 

For ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revisions, intake rates 

for Ra-226 and Th-230 have 

been modeled based on a 

source term associated with 

the uranium stack effluent 

from Plant 2/3. This material 

may have included Ra-226 

and Th-230 impurities that 

were not removed in the ore 

milling process that occurred 

at different vendor facilities. 

Otherwise, radon breath 

analysis is not pertinent to 

environmental intake rates.

Closed
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5 Radon release rate 

from the K-65 silos 

as estimated by 

NIOSH is 

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.

10/15/2013: Open site profile issue.

4/10/2014: See response to Finding 28. Open 

issues will need to be taken up in a site profile 

context. – Topic for future WG deliberations. 

8/14/2014: Subsumes related site profile

findings (25, 26). These issues have not been 

discussed since April 2011. SC&A 

recommends that this issue and related site 

profile findings be resolved in the Work Group 

setting.

SC&A has prepared a series of white papers 

that have been discussed in several Work 

Group meetings. While we acknowledge that 

the number of affected claimants is likely 

small, given that the SEC for all workers 

extends from 1954 to 1978, we nonetheless 

stand by the positions articulated in those white 

papers (SC&A 2008b, SC&A 2010a, SC&A 

2010b, SC&A 2011).

9/3/2014: WG recommends issue remain open. 

NIOSH to prepare a response for the next WG 

meeting.

12/4/2014: The Work Group recommends 

closure (ABRWH 2014c, p. 252).

ORAUT-RPRP-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

presents what NIOSH 

believes is the best available 

analysis of annual radon 

effluent from the K-65 silos. 

The result of that analysis is 

70.4 Ci/year. In the interest of 

being claimant favorable, 

ORAUT-RPRT-0052 

recommends that the radon 

effluent values stated in 

ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald 

Environmental Management 

Project (FEMP) –

Occupational Internal Dose,” 

be used. 

This value of 5,000 to 6,000 

Ci/y is similar to the value of 

6,700 Ci recommended in the 

RAC report.

Closed
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6a Use of BZ and GA 

sampling data and 

associated daily 

weighted exposures 

(DWEs) to 

reconstruct Th-232 

intakes pre-1968 (see 

NIOSH 2009) 

NIOSH posted a response (in ORAUT-RPRT0052) to SC&A’s white paper, Focused Review 

of “Uncertainty and Variability in Historical 

Time-Weighted Average Exposure Data” 

(Davis and Strom 2008) and Its Application in 

Dose Reconstruction under EEOICPA, Rev. 1, 

that summarizes their November 2010 white 

paper (NIOSH 2010). 

- Assign the DWE for the job description 

with the highest DWE in the FMPC plant 

where thorium was handled for a specific 

year to every worker in that plant, with a 

GSD of 5. 

- Assign a high DWE from an adjacent year 

when neither DWE data nor air sampling 

data are available, or when they are judged 

to be inadequate or incomplete, with a GSD 

of 5. 

- Use the upper 95th percentile of the air 

sampling data for a facility when timeweighted average data are not available. 

- Recommends that the dose reconstructor 

search the SRDB for DWE data if the 

reconstructor has reason to believe that 

exposures may have taken place that are not 

identified in the existing data set.

July 2013: SEC voted for all workers 1954–

1967 based on inability to reconstruct intakes 

of Th-232 with sufficient accuracy from DWE 

data (now SEC).

— — Closed
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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.

10/15/2013: Implementation of a coworker 

model is an ongoing site profile issue for 1979–

1988.

4/10/2014: Ongoing – topic for future WG 

deliberations.

8/25/2014: This issue has been discussed 

extensively in Work Group meetings, and 

SC&A is in general agreement with NIOSH on 

their methodology for using the chest count 

data reported in activity (nCi) Pb-212 and 

Ac-228 for 1979–1988.

Nonetheless, SC&A recommends keeping this 

finding open pending our formal review of the 

NIOSH white paper on post-SEC thorium 

methodology (mid-late October 2014).

11/26/2014: SC&A has completed its review of 

the NIOSH white paper and recommends the 

finding be designated “open” pending WG 

discussions on 12/4/2014.

12/4/2014: Work Group recommends 

closure (ABRWH 2014c, p. 253).

A thorium coworker model is 

in development.

Closed
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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, H.M., 

1945, SRDB Ref. ID 439) 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.

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.

10/15/2013: This issue is apparently open for 

WG deliberation.

4/10/2014: Open – topic for future WG 

deliberations. SC&A will need to review the 

cited SRDB references.

8/25/2014: SC&A has carefully reviewed the 

referenced SRDB reports 2921, 4330, 4618, 

4204, 439, and 8599 provided by NIOSH and 

conclude these reports bear little relevance to 

Finding 4.5-1. 

Finding 4.5-1 specifically discussed several 

limitations identified in a document titled, 

Response to Dosimetry Assessment Fact Sheet, 

submitted by NLO, Inc. on September 11, 

1981, in response to a DOE inquiry. As stated 

in the summary of our original finding (SCASEC-TASK5-0056, Section 4.5, page 112), 

SC&A did not question the merits/use of the 

dosimetry data, but implies the need to 

consider the quality of these data in context 

with stated limitations. It is SC&A’s 

recommendation to account for these 

limitations by expanding the range of 

uncertainty that is normally afforded to 

personnel dosimeters that were used at the 

time.

9/3/2014: WG recommends closure 

(ABRWH 2014b, pp. 267–270).

SRDB Reference ID #2921, 

“Health Protection Program 

Review,” from November 

1962 concurs with the 

proposal to issue an FMPC

Nuclear Safety Guide. This 

Guide and the Industrial 

Hygiene and the Radiation 

Department Procedures 

Manual should provide 

sufficient criteria to permit 

operating groups to accept 

health and safety 

responsibility without 

excessive audit.

Several other references exist 

in the SRDB that support the 

adequacy of the external 

dosimetry program at 

Fernald, some of which 

include 4330, 4618, 4204, 

439, 8599.

Closed
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Thorium White Paper

Th-1 While it appears that 

the majority of the 

thorium exposure 

potential at Fernald in 

the post-SEC period 

was related to 

redrumming and 

repackaging 

activities, some 

evidence exists that 

small-scale handling 

and possibly 

production may have 

occurred after 1979.

Given that it is 

currently infeasible to 

identify which 

workers were 

involved in these 

operations and 

potentially exposed, 

and by extension 

whether those 

workers were 

properly monitored, 

NIOSH should assign 

unmonitored thorium 

intakes for all 

workers who may 

have entered 

radiological areas and 

been exposed to 

thorium materials.

This issue was first discussed during the 

December 2014 Work Group meeting, and it 

was agreed that unmonitored coworker intakes 

of thorium would be assigned to all claimants 

who could be considered radiological workers. 

Note: this finding is specific to the 1979–1989 

timeframe.

7/28/2017: This issue was discussed during

the Work Group meeting. The updated 

revision of the internal dose TBD contains 

instructions on assignment of unmonitored 

thorium intakes to all radiological workers. 

The WG recommends closure.

— Closed
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Thorium White Paper

Th-2 Given that the 

monitoring program 

does not appear to be 

directly focused on 

areas where thorium 

exposure potential 

existed, coupled with 

the inability to 

effectively identify 

which workers may 

have handled thorium 

materials, NIOSH 

should instruct the 

dose reconstructors to 

assign the 95th 

percentile coworker 

intake value to all 

unmonitored 

claimants who may 

have been directly 

involved in thorium 

operations. 

This issue was first discussed during the 

December 2014 Work Group meeting; 

however, no path forward was agreed upon at 

that time. 

7/28/2017: This issue was discussed during 

the Work Group meeting. The updated 

revision of the internal dose TBD (NIOSH 

2017) contains instructions on assignment of 

the 95th percentile to two specific groups of 

workers: 

1. Workers with thorium fecal baseline 

samples 

2. Workers employed by the IT 

Corporation 

The WG agreed with NIOSH that 

application of the geometric mean was 

appropriate and bounding to all other 

classes of radiological worker. The WG 

recommends closure.

— Closed
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Thorium White Paper

Th-3 Given the broad work 

locations and duties 

contained among 

worker job types not 

currently defined as a 

thorium worker in 

NIOSH 2014a, 

NIOSH should 

provide explicit 

instructions to the 

dose reconstructor

that thorium 

coworker intakes 

should be assigned 

unless sufficient 

evidence exists that 

the claimant did not 

enter radiological 

areas where thorium 

exposure potential 

may have existed.

This issue was first discussed during the 

December 2014 Work Group meeting, and it 

was agreed that unmonitored coworker intakes 

of thorium would be assigned to all claimants 

who could be considered radiological workers. 

Note: this finding is specific to the 1979–1989 

timeframe.

7/28/2017: This issue was discussed during 

the Work Group meeting. The updated 

revision of the internal dose TBD contains 

instructions on assignment of unmonitored 

thorium intakes to all radiological workers. 

The WG recommends closure.

— Closed

Thorium White Paper

Th-4 Unless sufficient 

evidence exists that 

thorium exposure 

potential at Fernald 

was restricted to 

solubility class “W,” 

NIOSH should 

consider using the 

more conservative 

and claimant 

favorable DAC value 

for solubility class 

“Y.”

This issue was first discussed during the 

December 2014 Work Group meeting; 

however, no path forward was agreed upon at 

that time.

7/28/2017: This issue was discussed at the 

WG meeting. NIOSH is to reconsider the 

assumed solubility class for application of 

10% DAC values used in unmonitored 

thorium dose reconstruction (1990–1994). 

NIOSH to provide official written position 

on issue. WG recommends finding be 

designated as In Progress. 

It is standard industry 

practice to utilize the more 

restrictive DAC value for the 

purposes of controlling 

airborne contamination.

Therefore, the lower class W 

DAC is appropriate.

In 

Progress
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Thorium White Paper

Th-5 NIOSH should not 

restrict the 

assignment of 

thorium intakes to 

workers who 

submitted preemployment fecal 

samples, but rather 

assign intakes based 

on the potential for 

radiological 

exposure. 

This issue was first discussed during the 

December 2014 Work Group meeting; 

however, no path forward was agreed upon at 

that time.

7/28/2017: This issue was discussed during 

the Work Group meeting. While the 

updated internal dose TBD does not contain 

specific instructions on unmonitored dose 

assignment during the 1990–1994 period, 

NIOSH verbally confirmed that 

unmonitored thorium dose will be assigned 

to all radiological workers. The existence of 

a fecal sample is no longer a prerequisite for 

coworker dose assignment. The WG 

recommends closure.

— Closed

Thorium White Paper

Th-6 The underlying 

assumptions 

employed to 

reconstruct doses to 

thoron appear to be 

arbitrary and are not 

well established or 

referenced. The 

assumptions 

concerning thorium 

source term 

inventory, release 

fraction, equilibrium 

factor, occupancy 

time, and specific 

activity of thoron 

should be more 

carefully defined 

based on credible 

documentation and 

site-specific records.

This issue was first discussed during the 

December 2014 Work Group meeting; 

however, no path forward was agreed upon at 

that time. Appendix B to the Fernald internal 

dose TBD contains a discussion of SC&A’s 

concerns.

7/28/2017: This issue was discussed at the 

WG meeting. NIOSH is to consider 

modeling Building 65 thoron doses 

specifically. In addition, NIOSH is to 

provide an official position on assumed 

occupancy factors for thoron exposure. The 

WG recommends that this finding be 

designated as In Progress.

— In 

Progress
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Th-7 It is necessary that 

NIOSH evaluate the 

thoron/thoron 

daughters’ exposures 

due to Ra-228. 

Independent of the 

time assumed after 

separation, it is 

necessary to evaluate 

whether workers 

could have worked in 

areas where Ra-228 

was handled or stored 

and consider the 

associated thoron 

exposures. Ra-228 

has a half–life long 

enough to permit its 

presence in the 

workplace for years 

independent of the 

original parent 

isotope (Th-232). 

This issue was first discussed during the 

December 2014 Work Group meeting. NIOSH 

agreed to revisit the issue of unsupported 

radium exposures, in particular, the removal of 

guidance specifying that unsupported radium 

would be assigned to all monitored workers 

based on in vivo measurements of Ac-228. 

7/28/2017: This issue was discussed at the 

WG meeting. The updated revision of the 

internal dose TBD contains instructions on 

assignment of unsupported radium only for 

cases in which the in vivo results for Ac-228 

are a factor of 1.5 (or more) higher than 

corresponding Pb-212 results. SC&A agrees 

with this method, and the WG recommends 

closure. 

— Closed

Thorium White Paper

ThObs1It appears that the 

monitoring program 

was focused towards 

job categories that 

had the highest 

exposure potential, as 

evidenced by the 

large proportion of in 

vivo results attributed 

to chemical 

operators. 

This observation was discussed at the 

December 2014 Work Group meeting. 

12/4/2014: This item was discussed at the WG 

meeting. No further action required. 

7/28/2017: Observation not discussed. 

Recommendation from December 2014 

meeting holds. 

— No Action 

Required
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ThObs2Workers who 

registered above 

MDA results for 

either Pb-212 or 

Ac-228 were 

resampled 

approximately 10 

times faster than 

workers who had 

results below the 

MDA.

This observation was discussed at the 

December 2014 Work Group meeting. 

12/4/2014: This item was discussed at the WG 

meeting. No further action required. 

7/28/2017: Observation not discussed. 

Recommendation from December 2014 

meeting holds.

— No Action 

Required

Thorium White Paper

ThObs3SC&A agrees with 

the following 

claimant-favorable 

assumptions 

presented in NIOSH 

2014a: triple 

separation of 

thorium; adjustment 

for bias on the chest 

counts of Ac-228 and 

Pb-212; Pb-212 

monitoring results 

should be used to 

calculate thorium 

intakes; and chest 

counts with a high 

Ac-228:Pb-212 ratio 

(greater than 1.5:1) 

be interpreted as 

intakes of a mixture 

of triple-separated 

thorium and 

unsupported Ra-228. 

This observation was discussed at the 

December 2014 Work Group meeting. 

12/4/2014: This item was discussed at the WG 

meeting. No further action required. 

7/28/2017: Observation not discussed. 

Recommendation from December 2014 

meeting holds.

— No Action 

Required
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ThObs4Given that 

discussions related to 

the method for 

analyzing coworker 

data are ongoing, a 

complete review of 

the in vivo coworker 

analysis is 

inappropriate until 

the time-weighted 

OPOS methodology 

is accepted by the 

Advisory Board.

This observation was discussed at the 

December 2014 Work Group meeting. Since 

that time, criteria for development of coworker 

models have been developed by NIOSH 

(Neton 2015). Implementation of NIOSH 2015

is being performed on a trial basis at a number 

of EEOICPA sites (notably SRS). 

12/4/2014: This item was discussed at the WG 

meeting. Future actions are dependent on 

acceptance of program-wide coworker 

modeling criteria. 

7/28/2017: Observation was not discussed 

during the WG meeting. No actions by WG 

are currently pending.

— No 

Actions 

Pending

Thorium White Paper

ThObs5Based on the review 

of the DOE records, 

CATI reports, and 

associated job 

descriptions of 22 

unmonitored claimant 

records, it is highly 

unlikely that the 

workers would have 

been continually 

exposed to airborne 

thorium levels above 

10% of the DAC for 

the entire duration of 

their employment in 

the 1990–1994 

period. 

This observation was discussed at the 

December 2014 Work Group meeting. 

12/4/2014: This item was discussed at the WG 

meeting. No further action required. 

7/28/2017: Observation not discussed. 

Recommendation from December 2014 

meeting holds.

— No Action 

Required

Thorium White Paper

ThObs6NIOSH should cite 

the aforementioned 

review and/or provide 

additional discussion 

of the underlying 

evidence that BL-13, 

BL-65, Cell 8, KS65, and RT-210 are 

representative of 

thorium material.

Updates to the Fernald internal TBD include 

Attachment E, which details the breathing zone 

methodology. In that section, NIOSH discusses 

and references the thorium breathing zone 

codes noted in the observation. 

12/4/2014: This item was not discussed at the 

WG meeting. 

7/28/2017: Observation was not discussed at 

the WG meeting. Based on the discussion of 

breathing zone methods in Attachment E of 

ORAUT-TKBS-0017-5, Rev. 03 (NIOSH 

2017), SC&A recommends Observation 6 be 

closed by the WG. 

— In 

Abeyance
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ThObs7It is not immediately 

clear what the 

temporal criteria was 

for collecting and 

analyzing breathing 

zone samples; 

however, it is evident 

that they were not 

necessarily collected 

on a daily basis. One 

likely possibility is 

that the breathing 

zone sample was 

measured over longer 

periods of time. 

However, 

documentation or 

other evidence should 

be provided to 

sufficiently establish 

that the breathing 

zone data are 

complete and 

represent 

comprehensive 

monitoring for 

thorium activities.

This observation was discussed at the 

December 2014 Work Group meeting.

12/4/2014: This item was discussed at the WG 

meeting, and NIOSH provided additional 

information that specified that BZ data were 

collected on a daily basis but generally 

reported on a weekly basis. SC&A accepts 

NIOSH’s explanation and no further action is 

required. 

7/28/2017: Observation not discussed. 

Recommendation from December 2014 

meeting holds.

— No Action 

Required
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U-1 Although claimant 

favorable, the 

censoring of negative 

and zero bioassay 

results at the 

minimum observed 

positive value in a 

given year is 

inconsistent with the 

guidance provided in 

ORAUT-RPRT0053, Revision 02, 

Analysis of Stratified 

Coworker Datasets, 

which specifies that 

all negative bioassay 

values be censored at 

zero. Note that the 

treatment of negative, 

zero, and results less 

than the minimum 

detectable activity 

(MDA) is an ongoing 

topic of discussion 

with the Special 

Exposure Cohort 

(SEC) Issues Work 

Group. 

This represents a new issue that had not been 

previously discussed in a Work Group setting.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH agrees that 

current methods specify that negative values 

should be censored at zero and not at the 

lowest observed positive value for a given 

year. Given the likely minimal effect on 

derived values, NIOSH plans to proceed 

with dose reconstruction methods using the 

currently derived values. NIOSH will revise 

its coworker estimates in the future as 

resources and priorities allow. The WG 

recommends the issue be put In Abeyance.

— In 

Abeyance
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U-2 NIOSH should 

closely examine 

questionable bioassay 

pairs that demonstrate 

differences of exactly 

two orders of 

magnitude on the 

same day for the 

same worker to 

assure that all of the 

numerical results 

used in OTIB-0078 

accurately reflect the 

daily excretion rates 

for monitored 

workers at Fernald 

and are being 

interpreted correctly.

This represents a new issue that had not been 

previously discussed in a Work Group setting.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH has investigated 

the issue and concluded that the higher 

urinalysis results in observed bioassay 

sample pairs are the correct values. The 

lower urinalysis results in the bioassay pairs 

have been removed from analysis. In 

addition, any bioassay samples that report a 

decimal place are adjusted by a factor of 100 

to correct the assumed units to μg/liter. The 

WG recommends closure.

—

Closed

SC&A OTIB-0078 Review

UObs1SC&A was able to 

recreate the annual 

daily excretion rates 

reported in Table 2-3 

of OTIB-0078 with a 

reasonable degree of 

accuracy for most 

years. However, 

SC&A was not able 

to recreate the values 

reported for the years 

1986–1997. 

This represents a new issue that had not been 

previously discussed in a Work Group setting.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH clarified the use of 

RPRT-0053, and not PROC-0095, to derive 

coworker excretion rates for those years. 

SC&A agrees with NIOSH’s explanation. 

The WG recommends closure. 

— Closed
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UObs2A comparison of the 

median urinary 

excretion rates 

derived in Revision 

03 of OTIB-0078 

(using the TWOPOS 

method) with the 

excretion rates 

calculated in 

Revision 01 of OTIB0078 (using the 

pooled sample 

approach) showed 

very little difference. 

However, as 

expected, the use of 

TWOPOS methods 

results in a significant 

reduction in the 

variability of the 

derived distributions, 

and thus excretion 

rates at the 84th 

percentile were 

markedly lower using 

the TWOPOS 

method. 

This represents a new issue that had not been 

discussed previously.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH and the WG agree 

with the observation, and no further action 

is warranted. The WG recommends closure.

— Closed
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UObs3Sample results that 

were below the 

detection limit were 

not reported in a 

consistent fashion in 

the HIS_20 ORAU 

database. NIOSH has 

elected to treat 

negative and zero 

results by censoring 

the value at the 

lowest observed 

positive result by 

year. This approach is 

claimant favorable 

compared to using 

the negative and zero 

values as is although 

not consistent with 

the methodology in 

RPRT-0053 

This represents a new issue that had not been 

discussed previously.

7/28/2017: This issue was discussed during 

the WG meeting. Similar to Finding U-1, 

NIOSH agrees that current methods for 

treating negative, zero, and below MDA 

values were not in effect when OTIB-0078 

unmonitored coworker intakes were 

developed. Given the likely minimal effect 

on derived values, NIOSH plans to proceed 

with dose reconstruction methods using the 

currently derived values. NIOSH will revise 

its coworker estimates in the future as 

resources and priorities allow. The WG 

recommends the issue be put In Abeyance.

— In 

Abeyance

SC&A OTIB-0078 Review

UObs4NIOSH appears to 

have used reported 

values at the 

MDA/censoring level

(CL) in situations 

where a lower 

numerical result was 

provided in the 

comments section of 

the bioassay entry. 

This is a claimant 

favorable 

interpretation of these 

records.

This represents a new issue that had not been 

discussed previously.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH agrees with the 

observation and will take HIS_20 comments 

into account as appropriate in future 

revisions. Given the likely minimal effect on 

derived values, NIOSH plans to proceed 

with dose reconstruction methods using the 

currently derived values. NIOSH will revise 

its coworker estimates in the future as 

resources and priorities allow. The WG 

recommends the issue be put In Abeyance.

— In 

Abeyance
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UObs5SC&A observed 313 

sample entries that 

should likely have 

been removed from 

the coworker model 

due to comments 

indicating the sample 

was an invalid result 

or the sample was for 

pre-employment/reemployment 

purposes. Given the 

relatively small 

incidence of such 

samples, the 

cumulative effect of 

excluding those 

results is likely to be 

insignificant.

This represents a new issue that had not been 

discussed previously.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH agrees with the 

observation and will take HIS_20 comments 

into account as appropriate in future 

revisions. Given the likely minimal effect on 

derived values, NIOSH plans to proceed 

with dose reconstruction methods using the 

currently derived values. NIOSH will revise 

its coworker estimates in the future as 

resources and priorities allow. The WG 

recommends the issue be put In Abeyance.

— In 

Abeyance

SC&A OTIB-0078 Review

UObs6OTIB-0078 would 

benefit from a 

discussion of the 

additional intake 

information (intake 

pathway and 

solubility type) 

available in the 

HIS_20 ORAU 

database. Neither the 

pedigree and 

accuracy of such 

indicators, nor 

whether appropriate 

adjustments to the 

intake model may be 

warranted, are known 

at this time.

This represents a new issue that had not been 

discussed previously.

7/28/2017: This issue was discussed during 

the WG meeting. NIOSH agrees that such 

designations are available in HIS-20 but 

does not know the source or accuracy of 

such indicators. NIOSH also notes that it is 

standard practice to evaluate coworker data 

using all solubility types when the specific 

material qualities are unknown. SC&A 

accepts NIOSH’s position to disregard 

information provided in the HIS-20 

regarding intake pathway and solubility 

type. The WG recommends closure.

— Closed
Effective Date:

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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 2008b. An Alternative Assessment of Radon Releases from K-65 Silos, An SC&A White 

Paper, SC&A, Inc., Vienna, Virginia. November 2008.

SC&A 2010a. Response to NIOSH’s Statements Regarding the RAC Model for Estimating Radon 

Releases from K-65 Silos, SC&A, Inc., Vienna, Virginia. January 26, 2010.

SC&A 2010b. A Second White Paper Addressing Enhanced Radon Releases from the K-65 Silos 

at the Fernald Site, SC&A, Inc., Vienna, Virginia. April 2010.
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SC&A 2010c. Review of the NIOSH “White Paper on Fernald Th-230 and Other Associated 

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

Maryland. May 2010.

SC&A 2010d. Strategies to Investigate Allegations of Corrupt Bioassay Monitoring at Fernald,

SC&A, Inc., Vienna, Virginia. June 15, 2010.

SC&A 2011a. Evaluation of Occupational Environmental Exposure to Radon at the Fernald 

Environmental Management Project, SC&A, Inc., Vienna, Virginia. February 2011.

SC&A 2011b. Focused Review of “Uncertainty and Variability in Historical Time-Weighted 

Average Exposure Data” (Davis and Strom 2008) and Its Application in Dose Reconstruction 

Under EEOICPA, Revision 1, Draft White Paper, SC&A, Inc., Vienna, Virginia. February 2, 

2011.

SC&A 2012a. SC&A’S Response to NIOSH’s Subgroup 10A Impact Analysis Dated November 1, 

2011, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. February 6, 2012.

SC&A 2012b. Completeness and Adequacy of Thorium In-Vivo Records (1979–1989), SC&A, 

Inc., Vienna, Virginia. November 26, 2012.

SC&A 2014a. Memo from J. Mauro (SC&A) to the Procedures Review Subcommittee. Subject: 

SC&A Position Regarding Skin Exposures Associated with the Direct Deposition of Fine 

Particles and Flakes of Uranium Oxide onto Skin and Clothing, SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. January 7, 2014.

SC&A 2014b. Review of Proposed NIOSH Methods for Reconstructing Thorium Doses at 

Fernald (1979–2006), Revision 0, SC&A, Inc., Vienna, Virginia. November 2014.

SC&A 2016. Draft Review of ORAUT-OTIB-0078, Revision 03, Internal Dosimetry Coworker 

Data for the Feed Materials Production Center, SC&A, Inc., Vienna, Virginia. May 2016. 

[SRDB Ref. ID 164387]
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ATTACHMENT – DETAILED SC&A UPDATES TO SELECTED

FINDINGS

FINDING 16

Section 6.6.2 of the Fernald site profile (ORAUT-TKBS-0017-6, Revision 01, March 25, 2014) 

refers to ORAUT-OTIB-0017, Technical Information Bulletin: Interpretation of Dosimetry Data 

for Assignment of Shallow Dose (October 11, 2005; hereafter referred to as “OTIB-0017”). The 

section titled “Non-Uniform Exposure of the Skin” addresses this subject, which has been further 

clarified at numerous Work Group meetings. The section explains that, when only a portion of 

skin is exposed and there is reason to believe that a diagnosed skin cancer occurred within that 

location, the localized dose should be used as input to IREP (i.e., do not dilute the exposure over 

the entire surface area of the skin). OTIB-0017 does not explicitly address the direct deposition 

of particles onto the surface of the skin, but the natural extension of OTIB-0017 guidance would 

indicate that this strategy also applies to exposures of the skin directly beneath a particle 

deposited on the skin, if there is affirmative evidence that such exposures might have occurred, 

as might be indicated in the computer-assisted telephone interview (CATI) or the worker’s 

records. This latter interpretation of OTIB-0017 has been confirmed at meetings of the 

Procedures Review and Dose Reconstruction Subcommittees and at site profile work group 

meetings. (See SC&A Position Regarding Skin Exposures Associated with the Direct Deposition 

of Fine Particles and Flakes of Uranium Oxide onto Skin and Clothing, January 2014, and the 

resolution of this specific issue during the Procedures Review Subcommittee meeting held on 

February 13, 2014, page 42–52). Hence, SC&A recommends closure of this issue. However, we 

also recommend that dose reconstructors remain diligent in implementing this unique aspect of 

OTIB-0017.

FINDING 17

Section 6.11 of the site profile, titled “Geometric Correction Factors,” cites DCAS-TIB-0013, 

Selected Geometric Exposure Scenario Considerations for External Dose Reconstruction at 

Uranium Facilities (NIOSH 2010; hereafter referred to as “TIB-0013”), as a means to address 

extremity doses. TIB-0013 is limited to the development of correction factors for photon 

exposures of the abdomen or extremities based on recorded photon exposures on lapel 

dosimeters and for specific geometries, such as cleaning up a spill on the floor, working with a 

uranium ingot, drum, or denitration pot. The correction factors, which range from about 1.5 to 

3.5, were derived using models and also empirical data where both wrist and lapel dosimeters 

were used.

This procedure has been previously reviewed by the procedures subcommittee and its issues 

have been largely resolved. However, this procedure is silent regarding non-penetrating doses to 

the skin of the extremities. This issue is currently being reviewed as part of the site profile 

review for the Idaho National Laboratory (INL). In that review, NIOSH identified 62 skin cancer 

extremities, and SC&A is currently investigating the methods used to reconstruct those doses. 

SC&A recommends that this issue remain open while the INL investigations proceed.
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FINDING 22

As indicated in the matrix, on April 10, 2014, SC&A recommended that this issue should remain 

open so that SC&A has an opportunity to evaluate this finding as now addressed in ORAUTTKBS-0017-4, Fernald Environmental Management Project – Occupational Environmental 

Dose, Revision 2, March 13, 2014 (referred to here as the “Fernald 2014 site profile”).

By way of background information, this issue was first raised in SC&A’s November 6, 2006, 

initial review of the Fernald site profile dated April 6, 2004. We thought it prudent to reiterate 

the original issue and summarize how it is now addressed in the March 13, 2014, version of the 

Fernald site profile, within the context of all that has transpired with respect to issues resolutions 

on other matters and Special Exposure Cohorts (SECs) that have been granted. 

Inspection of Finding 22 located in Section 5.7.1 of SC&A’s November 6, 2006, site profile 

review raises an issue with the estimated atmospheric release of uranium based on a series of 

reports that reveal that estimates of the atmospheric release of uranium were revised a number of 

times, and that the site profile at that time did not take into consideration the most recent 

estimates. The specific concern raised by SC&A was that the site profile uses data compiled by 

Boback et al. (1987) as updated by Dolan and Hill (1988)1

 and RAC (1995) as the bases for the 

estimated annual atmospheric releases. However, SC&A was critical of the site profile because it 

makes no mention of work by Clark et al. 1989. 

1 The TBD erroneously refers to this publication as Dolan and Dolan 1988 (TBD Vol. 4, p. 9). The 

reference list for this publication should also be corrected from “Dolan, L.C. and C.A. Dolan...” to “Dolan, L.C., 

and C.A. Hill...”

A number of developments have transpired on this project since the preparation of the first 

Fernald site profile and SC&A’s review of the site profile in 2006, which makes this issue 

somewhat moot. First, the vast majority of internal uranium dose reconstructions for workers at 

NIOSH are based on bioassay samples because over 90% of the workers were under a bioassay 

program after the early 1950s. In addition, three classes of Fernald workers have been added to 

the SEC, including subcontractors at Fernald who were not adequately covered by the bioassay 

program (1951–1983). However, there is still a need to perform partial dose reconstructions for 

workers who are not covered by the SEC and/or who do not have bioassay data. Therefore, there 

are circumstances where internal doses associated with the atmospheric releases of uranium 

might be required. Section 4.4 of the March 13, 2014, site profile presents the methods NIOSH 

plans to use to reconstruct internal exposures to uranium in atmospheric effluents. Section 

4.4.1.1 states that: 

For the purpose of environmental dose reconstruction, this TBD uses the larger of 

the emissions quantities from either Voillequé et al. (1995) or Boback et al. 

(1987). The values for routine and nonroutine uranium discharges from 

operations and episodic releases during the operating years are from Voillequé 

et al. 

This is the same language used in the original site profile, and any issues with these data as 

provided by Clark et al. 1989 are still not addressed. 

 
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In order to help close out this issue, we reviewed the Clark et al. 1989 report to determine if the 

source term information is somehow incompatible with the current source terms used in the 2014 

version of the Fernald site profile. Table 4-5 of the 2014 site profile presents estimates of the 

total atmospheric release of uranium by year from 1951 through 1988 for each of 12 different 

sources of emissions. The grand total is 308,495 kilograms (kg). The question is whether the 

information provided in the Clark et al. 1989 report incompatible with the values used in the site 

profile in Table 4-5. 

As described in the introduction of Clark et al. 1989: 

The review for additional radionuclide air sources required a re-creation of the 

history of operations at the FMPC. This was done by reviewing plant records and 

interviewing long term employees. While these efforts enabled the authors to 

prepare a revised estimate, the 37-year history of FMPC radionuclide air 

emissions cannot be prepared without some degree of uncertainty. The factors 

which introduce uncertainty into the historic air emission estimate include: 

• Documentation of all operations and events did not exist or could not be 

found. 

• Personal recall of events was useful, but is incomplete and was not always 

consistent.

• Some measurements necessary to calculate emissions were not recorded 

or archived.

The summary of the report states the following: 

This study results in estimated uranium air emissions of 179,000 kg and an 

estimated thorium air emission of 6500 kg for the years of 1951 through 1987. 

It certainly appears that the estimate of the total uranium emissions to the atmosphere used in the 

2014 Fernald site profile of 308,495 kg is substantially larger than the estimate provided by 

Clark et al., 1989. Hence, SC&A recommends that this issue be closed. 

As a postscript to this finding, SC&A believes that any internal doses associated with uranium 

atmospheric releases for workers who do not have bioassay data and are not covered by the SEC 

are best performed using a coworker model constructed using bioassay data and not atmospheric 

releases and dispersion modeling, especially considering the large uncertainties associated with 

reconstructing such doses; i.e., you need some knowledge of the location of the worker at the 

time of the releases, information that is generally not available. In addition, if, the source terms 

are needed for dose reconstructions, such as for workers outdoors, without bioassay data, and are 

not covered by the site profile, the source term data provided in the 2014 version of the site 

profile certainly appears to be scientifically sound and claimant favorable. 

FINDING 23

Section 5.7.2 of SC&A’s 2006 review of the Fernald site profile explains that many of the source 

terms are episodic, and we expressed concern that standard Gaussian modeling using annual joint 
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frequency data to derive average annual chi/Q values at receptor locations to reconstruct doses to 

workers without bioassay data might not be claimant favorable. Section 4.4.1.3.6 of the Fernald 

2014 site profile explicitly addresses the methods that NIOSH plans to use to reconstruct outdoor 

exposures to episodic releases (presumably for workers without bioassay data and not covered by 

the SEC). Table 4-6 of the 2014 site profile lists six significant episodic releases that occurred 

over a period of less than 1 day (we agree that these are the types of releases that were of concern 

to SC&A in our original review of the site profile in 2006). Equation 4-7 of the 2014 site profile 

presents the atmospheric diffusion equation that will be used to model the atmospheric 

dispersion factors for these releases. This model was taken from Slade (1968), which is 

recognized as one of the seminal documents on atomic energy and meteorology. The model 

specifically takes into consideration the wind speed, direction, and stability class at the time of 

the episodic release, using conservative values for these parameters if the joint frequency data 

are not available for the specific time of a given episodic release. SC&A believes that this 

material is fully responsive to our original concerns and recommends that this finding be closed. 

FINDING 24

This issue is discussed in Section 5.7.3 of SC&A 2006 review of the Fernald site profile. 

SC&A’s concern at the time was that, though the site profile addressed the diffuse emissions 

from the waste pits caused by wind erosion, it did not address potentially important sources of 

diffuse emissions at Fernald, many of which are described in SC&A’s review of this issue, such 

as:

• “Outside Williams Mill” (General Air, 44.3 MAC)

• “Breaking Salt at outside mill” (Breathing Zone, 30.8 MAC) 

• “Shovelling onto conveyor at outside mill” (Breathing Zone, 137.80 

MAC)

• “Changing drums at outside mill” (Breathing Zone, 122.90 MAC) 

These are issues separate from episodic releases because they are highly localized, ground-level 

releases that cannot be readily modeled. What is needed is an upper-bound estimate of the 

localized airborne concentrations (such as the above bulleted items) of these types of windblown 

fugitive emissions, and then use these concentrations and appropriate exposure durations to 

derive intakes and doses. Of course, this would only apply to workers who were not on a routine 

bioassay program for the radionuclides of interest and were not covered by the SEC. 

The 2014 site profile does not explicitly address this issue, but explains in the matrix that: 

In addition to stack effluent for the operational period, NIOSH has identified 

releases of thorium and uranium that emerged from building exhaust, waste pits, 

UF6 release from storage containers and six specifically identified off-normal 

events. NIOSH is unaware of any additional significant sources. 

It is not apparent that identifying the quantities of releases from building exhaust, waste pits, UF6

release from storage containers and six specifically identified off-normal events adequately 

addresses this issue, because we can envision a worker located near these localized fugitive 
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emissions for protracted periods of time, and the atmospheric modeling methods, even the 

episodic release protocols, do not address this unique set of potential conditions. We suspect that 

this level of granularity is not possible, because it would require placing specific workers at 

specific locations for known periods of time. Nevertheless, we recommend leaving this issue 

open, so that we can discuss it a little more at the next Work Group meeting. 

FINDING 27

Issue 27 is discussed in Section 5.9.1 of SC&A’s 2006 review of the Fernald site profile. The full 

text of this issue is relatively brief and is repeated here:

Given the documentation regarding high diffuse emissions and high uranium and 

thorium concentrations outdoors (discussed above), it is possible that the external 

environmental dose, other than that from the K-65 silos, may have derived mainly 

from deposition of uranium and thorium dust on workers. For thorium dust, this 

could involve considerable deep dose as well as shallow dose, while for uranium 

it would mean mainly the latter. NIOSH should evaluate the extent of the problem, 

which may have been significant in some outdoor production areas. 

NIOSH’s response to this issue as provided in the issues matrix is as follows:

The “Exposure Areas” concept is also applied to external dose consistent with the 

NIOSH position on Item 22 for the ORAUT-TKBS-0017-4, “Fernald 

Environmental Management Project – Occupational Environmental Dose” 

revision.

Section 4.5 of the 2014 Fernald site profile addresses external exposure from ambient radiation. 

This issue applies to unmonitored workers who might have been externally exposed outdoors to 

deposited radionuclides and are not covered by the SEC. Section 4.5 of the 2014 site profile 

explicitly addresses outdoor radiation fields and exposures to the K-65 silos, thorium residues in 

various warehouses throughout the site, and the radionuclides in the Production Plants and other 

onsite facilities. To a lesser extent, the radioactive waste pit area was another direct radiation 

source for unmonitored personnel who worked in that area. Table 4-19 of the 2014 site profile 

presents the results of thermoluminescent dosimeter (TLD) measurements at 10 locations at the 

site boundary from 1976 to 1995. Table 4-20 presents the results of TLD measurements at other 

locations, and Figure 4-11 presents the locations of TLD measurements in the vicinity of the 

waste pits from 1996 to 2005. Figures 4-14 and 4-15 present external dose rate contour maps for 

1976 and 1985. Section 4.5.4 presents onsite ambient dose rate estimates, 1952 to 1975. This 

section explains that, since there are no usable external dose rate measurements before 1976, a 

protocol is provided to reconstruct external outdoor exposures due to residual radioactivity 

outdoors at the site. 

Taken in its entirely, it appears that the 2014 site profile provides guidance that can be used to 

reconstruct external exposures outdoors from all sources of stored and residual radioactivity at 

the site. We recommend that this issue be closed with one proviso; we recommend that a 

statement be made in the site profile that exposures to skin will be reconstructed in accordance
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with OTIB-0017 and the commitments agreed to by NIOSH and the Board on how localized 

doses to skin from direct deposition will be reconstructed. 

FINDING 28

Issue 28 is discussed in Section 5.9.2 of SC&A’s 2006 review of the Fernald site profile. The full 

text of this issue is relatively brief and is repeated here:

The TBD is silent on how external doses to workers from the silos were derived 

for persons that may have spent time in the area of Fernald containing the silos 

(i.e., EA-6). This is of particular concern for the early years before additional 

shielding was provided for the silos. It is also of concern for those unmonitored 

workers who may have taken breaks near the silos. For instance, it may especially 

affect female employees during the years when they were not monitored. 

NIOSH’s response to this issue as provided in the issues matrix is as follows:

The external environmental dose for workers near the K-65 silos is addressed in 

the ORAUT-TKBS-0017-4, “Fernald Environmental Management Project – 

Occupational Environmental Dose,” revision. 

Section 4.5.1 of the 2014 Fernald site profile addresses external exposure from ambient radiation 

associated with the K-65 silos and production plants for 1976–2005, based on TLD 

measurements taken at various locations on the site and at the fence line boundary. Section 

4.5.4.1 of the 2014 Fernald site profile address external exposure from ambient radiation 

associated with the K-65 silos prior to 1976. Prior to 1976, average direct dose rates at the K-65 

silo fence line were modeled based on a combination of interpreted historic description of the 

K-65 silo radiation levels and the application of measured dose rate values. 

It appears that the 2014 site profile provides guidance that can be used to reconstruct external 

exposures outdoors from the K-65 silos. We recommend that this issue be closed. 

FINDINGS 30–32 

The Fernald technical basis document (TBD) or site profile for Occupational Medical Dose 

(ORAUT-TKBS-0017-3, Revision 1) was issued on January 2, 2014. We have reviewed this 

TBD and other NIOSH guidance to assess the degree to which these three issues can be closed at 

this time.

The three issues deal with matters that have been of concern on numerous occasions since the 

inception of this program; i.e., under what conditions is it appropriate to assume that workers at a 

given facility should be assigned occupational medical dose, including chest anterior-posterior 

and lateral x-rays, lumbar spine x-rays, and photofluorography (PFG) examinations, and what 

should be taken into consideration when assigning a given dose, such as type of equipment, 

retakes, collimation, uncertainty, etc. A review of the Fernald 2014 site profile reveals that a 

comprehensive set of instructions are provided on how to reconstruct occupational medical 

exposures at Fernald. Section 3.2 of the TBD explains that pre-employment, annual, and 

termination examinations were required as a condition of employment from the beginning of 
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operations in 1952, but evolved over time. The instructions also state, lacking information to the 

contrary, it should be assumed that all workers received annual chest x-rays from 1952 to 2006. 

The year 2006 is established as the end date because all x-ray equipment was removed from the 

site in that year.

Information is provided on the different types of x-ray equipment that were used and, based on 

that information and guidance in ORAUT-OTIB-0006 (Revision 04, June 20, 2011), which was 

previously favorably reviewed by SC&A, x-ray exposures are assigned to different organs and as 

a function of time. A review of ORAUT-OTIB-0006 reveals that collimation is addressed in 

Section 3.4 and retakes are addressed in Section 7.0 in making these assignments.

Tables 3-3 through 3-8 in the TBD provide convenient look-up tables for doses to various organs 

as a function of time for 1952–2006. Since the records reviewed by NIOSH are quite detailed 

with respect to the types of equipment and examinations performed, we conclude that there is no 

basis to assume that either lumbar spine or PFG examinations were performed, and that the three 

issues identified above have been adequately addressed. On this basis, SC&A recommends 

closing these findings.