Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

INTEGRATED STATUS REPORT OF SITE PROFILE AND SEC 

ISSUES RELATED TO INL AND ANL-W 

Contract No. 211-2014-58081 

SCA-TR-2016-SEC011, Revision 0 

Prepared by

John Mauro, PhD, CHP 

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 2016 

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.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

2 of 48

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.

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

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: Integrated Status Report of Site Profile and SEC Issues Related to 

INL and ANL-W

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SEC011 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: July 15, 2016

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

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

DOCUMENT 

REVIEWER(S):

John Stiver, MS, CHP [signature on file]

Bob Barton, CHP [signature on file] 

Joe Fitzgerald [signature on file]

Steve Ostrow, PhD [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/15/2016 Initial issue
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

3 of 48

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.

TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 5

1.0 Introduction ...................................................................................................................... 7

2.0 Status of INL Site Profile Issues ...................................................................................... 8

2.1 Issues 1 and 2 (Outdoor exposures from chronic and episodic atmospheric releases) .. 10

2.2 Issue 19 (Angle of incidence) ......................................................................................... 14

2.3 Issues 9 and 23 (Hot particles) ....................................................................................... 15

2.4 Issue 24 (Extremity Monitoring) .................................................................................... 15

2.5 Issue 34 (High risk neutron exposures) .......................................................................... 16

3.0 Status of INL SEC Issues ............................................................................................... 17

3.1 SC&A Preliminary Review of the INL Evaluation Report for SEC-00219 .................. 18

3.1.1 Definition of the Class ..................................................................................... 19

3.1.2 Fission and Activation Product (FAP) Bioassay Indicator Radionuclides ...... 20

3.1.3 Reactor Modeling ............................................................................................ 21

3.1.4 Burial Grounds ................................................................................................ 21

3.1.5 Central Facilities Area (CFA).......................................................................... 22

3.1.6 Chemical Processing Plant Pre-1963 ............................................................... 22

3.1.7 Test Area North (TAN) ................................................................................... 22

4.0 SC&A Follow-up Investigations.................................................................................... 23

4.1 Review of NIOSH Strategy for Reconstructing Internal Doses to Workers at Test Area 

North (September 2015) ................................................................................................. 23

4.2 Evaluation of Available Survey Data for the Central Facilities Area at Idaho National 

Laboratory (September 2015) ........................................................................................ 24

4.3 NIOSH SEC-00219 Test Reactor Area (TRA) Modeling (September 2015) ................. 24

4.4 Evaluation of the Revised SEC Class Definition for the Idaho National Laboratory 

Chemical Processing Plant (1963–1974) ....................................................................... 25

4.5 SC&A’s Evaluation of the NIOSH Evaluation Report Proposed Use of FissionActivation Product Bioassay Indicator Radionuclides (in Conjunction with ORAUTOTIB-0054 and ORAUT-TKBS-0007-5) for Assessment of Fission-Activation Product 

and Actinide Intakes at Idaho National Laboratory (October 2015) .............................. 25

4.6 Evaluation of Internal Monitoring for Fission and Activation Products among INL 

Claimants (1949–1970) (October 2015) ........................................................................ 25

4.7 INL SEC-00219 Reactor Prioritization for Evaluation of ORAUT-OTIB-0054 

Applicability (March 2, 2016) ........................................................................................ 26

5.0 Issues Matrix for SEC-00219 ......................................................................................... 27

6.0 Status of ANL-W Site Profile and SEC Issues .............................................................. 41
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

4 of 48

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.

7.0 References...................................................................................................................... 44
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

5 of 48

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.

ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

or Advisory Board

ANL-W Argonne National Laboratory-West

ANP Aircraft Nuclear Propulsion 

CDC Centers for Disease Control and Prevention 

CFA Central Facilities Area

cpm counts per minute 

CPP Chemical Processing Plant

Cs cesium

D&D decontamination and decommissioning 

DCAS Division of Compensation and Analysis 

DOE U.S. Department of Energy 

DR dose reconstruction 

ER evaluation report

FAP fission and activation product 

FP fission product 

HDE Historical Dose Evaluation

HP Health Physics

IET Initial Engine Test

INEL Idaho National Engineering Laboratory 

INL Idaho National Laboratory 

MDL maximum detectable limit

MESODIF Mesoscale Atmospheric Transport Model 

MeV mega-electron volts 

MFP mixed fission product 

mrem millirem

MTR Materials Test Reactor

Np neptunium 

NIOSH National Institute for Occupational Safety and Health

NTA nuclear track emulsion, type A (film) 

ORAUT Oak Ridge Associated Universities Team
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

6 of 48

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.

ORIGEN Oak Ridge Isotope Generator 

OTIB ORAUT Technical Information Document 

POC probability of causation 

Pu plutonium 

SEC Special Exposure Cohort 

SL-1 Stationary Low-Power Reactor

Sr strontium 

SRDB Site Research Database

TAN Test Area North

TBD technical basis document

Th thorium 

TLD thermoluminescent dosimeter

U uranium 

UO2 uranium dioxide 

WG Work Group 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

7 of 48

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.

1.0 INTRODUCTION

The National Institute for Occupational Safety and Health (NIOSH) and SC&A have been 

assisting the Advisory Board on Radiation and Worker Health (ABRWH or “Advisory Board”) 

in identifying, reviewing and closing out issues related to Idaho National Laboratory (INL) site 

facilities, beginning with SC&A’s January 25, 2006, review of the 2004 version of NIOSH’s site 

profile for INL (SC&A 2006). In 2007, NIOSH issued a revision of the site profile, and on 

December 30, 2008, SC&A issued a supplement to its review of the site profile (SC&A 2008). 

This supplement contained 13 findings and 19 observations (collectively referred to as “issues” 

in this report). The latest INL issues resolution matrix currently available on the NIOSH Web 

site, dated March 20, 2014 (NIOSH 2014c), is a useful platform upon which to build a status 

report for all issues associated with both INL and the Argonne National Laboratory-West 

(ANL-W); this NIOSH/Division of Compensation Analysis and Support (DCAS) matrix follows 

closely SC&A’s INL SEC-00219: Compilation of SC&A Review issues, Comments, and 

Recommendations, dated February 23, 2016 (SC&A 2016a). 

Though administratively separate until 2005, with separate research programs, ANL-W is 

physically located on the INL site and shares many of the radiation protection issues with INL 

and also employs common radiation protection programs. Given the protracted review of issues 

related to INL site facilities, including a relatively recent Special Exposure Cohort (SEC) for the 

INL Chemical Processing Plant (CPP) (SEC-00219), and also the recent attention to ANL-W by 

NIOSH and the Advisory Board, including an ANL-W SEC (SEC-00224), the Advisory Board 

requested that SC&A compile a report on the status of all issues that have been identified and 

have been or are being addressed by the Board. This status report is provided in response to this 

request and is intended to help ensure that (1) no issues are left unaddressed, given the protracted 

nature of the INL facilities review, and (2) issues that are common the both INL and ANL-W are 

identified, which should help to streamline the review process for both facilities. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

8 of 48

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.

2.0 STATUS OF INL SITE PROFILE ISSUES

We elected to begin this process with a review of the March 20, 2014, NIOSH/DCAS issues 

resolution matrix (NIOSH 2014c), which addresses all facilities at INL except ANL-W and the 

Naval Research Facility. The matrix shows that Issues 3, 7, 10, 11, 12, 13, 22, 25, 37, and 38 

have been closed by the INL Work Group (WG); SC&A recommends in the matrix that the WG

close Issues 4, 8, 14, 17, 18, 20, 21, 26, 29, 30, 32, 33, 35, and 36. At the time of the preparation 

of the matrix, the remaining 14 issues were in various stages of review. SC&A recommended 

that these issues remain open for a variety of reasons, such as waiting on commitments by 

NIOSH to prepare white papers and coworker models. 

The following briefly identifies and describes the issues that remained open as of March 2014. 

Those issues that are generic (i.e., apply to more than a single site) and, in SC&A’s opinion, have 

been resolved under other venues, are so indicated. As such, these are new SC&A 

recommendations: 

• Issue 1: Onsite outdoor exposures to workers from routine atmospheric emissions. 

NIOSH issued a separate white paper on this issue, which is discussed in Section 2.1. 

• Issue 2: Onsite outdoor exposures to workers from episodic atmospheric emissions. In 

the matrix, NIOSH states that a response to this issue is in a separate white paper. That 

white paper is discussed in Section 2.1. 

• Issue 5: Internal doses from high-risk jobs. In the matrix, NIOSH argues that this issue is 

adequately addressed in the site profile. This matter is similar to Issue 34, in which 

neutron exposures to high-risk job categories is discussed (see Section 2.5). 

• Issue 6: Calibration of equipment used to collect the data used to reconstruct internal 

exposures. In the matrix, NIOSH argues that this issue is related to a Tiger Team finding 

and is not a site profile issue because the methods used in the site profile to reconstruct 

doses account for uncertainties associated with instrument calibration. NIOSH provides 

the basis for its position in Section 4.4 of the March 5, 2014, NIOSH white paper, NIOSH 

Investigation into the Issues Raised in Comment 1 from SCA-TR-TASK1-005, prepared by 

Brian Gleckler (NIOSH 2014e). The white paper explains that, because of deficiencies in 

the outdoor air monitoring program, including deficiencies in calibration, NIOSH elected 

not to use these data but instead relied on atmospheric models for reconstructing outdoor 

internal exposures at INL. We agree and recommend closing this issue). 

• Issue 9: Exposures from direct contamination of skin. This is a generic issue that was 

resolved during issues resolution related to ORAUT-OTIB-0017, Interpretation of 

Dosimetry Data for Assignment of Shallow Dose (ORAUT 2005), and other site profile 

reviews. SC&A recommends closing this issue with respect to methods for reconstructing 

such doses. However, there is a need for additional guidance in the site profile for when 

such doses need to be explicitly considered. This matter is discussed in considerable 

detail in Section 2.3. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

9 of 48

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.

• Issue 15: Exposures to emergency response personnel who responded to the Stationary 

Low-Power Reactor (SL-1) accident. A vast body of records pertaining to the exposure of 

these emergency response personnel has been compiled. In addition, the matrix indicates 

that an SL-1 specific coworker model is provided in the site profile. SC&A would like to 

revisit the site profile with respect to this issue before recommending closure. 

• Issue 16: Missed external dosimetry data and the need for a coworker model. NIOSH’s 

response to this issue in the matrix is that there is no need for an external dose coworker 

model. Coworker model issues remain of concern to both INL and ANL-W. We 

recommend that this issue remain in progress. 

• Issue 19: Angular dependence issues for external dosimetry. In the matrix, NIOSH 

explains that such angular adjustments are for workers at a glove box where the badge is 

worn on the collar, but the organ of concern is the lower body. Reference is made to 

ORAUT-OTIB-0010, Revision 01, A Standard Complex-Wide Methodology for 

Overestimating External Doses Measured with Film Badge Dosimeters (ORAUT 2006), 

and OCAS-IG-001, External Dose Reconstruction Implementation Guideline (NIOSH 

2007). NIOSH issued a white paper on this subject, which is discussed in Section 2.2. As 

indicated, it appears that this issue requires additional discussion by the WG before it can 

be closed because the documents cited by NIOSH do not appear to explicitly address the 

interactions of photons with the shielding that covers the film. This shielding could 

substantively affect the readout of the film when photons strike the badge at a sharp 

angle.

• Issue 23: External doses to high risk jobs (similar to issue 5). 

• Issue 24: Missed extremity doses. NIOSH issued a white paper on this subject, which is 

discussed below. 

• Issue 27: Questions pertaining to the use of 1⁄2 the maximum detectable limit (MDL) to 

account for missed dose, when the reconstructed doses are close to a probability of 

causation (POC) of 50%. SC&A recommends closing this issue because the use of 1⁄2 the 

MDL for missed dose is a well-established practice on the program. 

• Issue 28: Questions pertaining to the assignment of 1⁄2 the MDL for missed neutron 

doses, especially when using nuclear track emulsion, Type A (NTA) film, which could 

miss doses from neutrons below about 0.8 mega-electron volts (MeV). (This issue is 

similar to Issue 27 with respect to using 1⁄2 the MDL for missed dose. SC&A recommends 

closing this aspect of Issue 28. With respect to adjustment factors for reconstructing 

neutron doses, this issue has been resolved in other venues. In addition, we recently 

revisited the 2004 and 2011 INL technical basis documents (TBDs) and would like to 

withdraw this issue, because it appears that both TBDs thoroughly address this issue and 

have suggested adjustment factors for workers who were monitored with NTA film for 

the Zero Power Physics Reactor and Transient Reactor Test Facility at ANL-W.) 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

10 of 48

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.

• Issue 31: Missed neutron doses and the need for a coworker model. At the time of the 

preparation of this report, NIOSH is in the process of a data capture to fill in data gaps 

related to external dosimetry at INL and ANL-W. 

• Issue 34: High-risk jobs and neutron exposures. In its response in the matrix, NIOSH 

indicates that it has responded to this issue in a separate document that is associated with 

documentation of worker interviews. NIOSH has issued a white paper on this subject, 

which is discussed in Section 2.5. 

Given this historic background information, the approach used in this report is to first track the 

degree to which the remaining issues were subsequently addressed by NIOSH, SC&A, and the 

INL WG in order to determine if, as of the date of this report, we can recommend closing any of 

the remaining issues. This is followed by determining if any “new issues” have emerged 

subsequent to March 20, 2014, including those related to site profiles and INL and ANL-W SEC 

petition evaluation reports (ERs). During this process, we can assess the degree to which any 

“new issues” have already been adequately addressed as part of the issues resolution process. We 

also make certain judgments regarding whether a given new issue is unique to INL facilities, or 

if it might also have applicability to ANL-W as well. Our objective is to try to capture a broad 

view of issues that we believe need to be addressed by the Board that apply to INL as a whole, to 

ANL-W, and to specific facilities at INL and ANL-W. In addition, by revisiting the previously 

unaddressed INL issues, we may find that some might apply to ANL-W and might even be 

considered potential SEC issues. This report does not raise new issues. It is limited to providing 

the status of existing issues; this is a “book keeping” report. 

2.1 ISSUES 1 AND 2 (OUTDOOR EXPOSURES FROM CHRONIC AND EPISODIC 

ATMOSPHERIC RELEASES)

On March 5, 2014, NIOSH issued a white paper, NIOSH Investigation into the Issues Raised in 

Comment 1 from SCA-TR-TASK1-005, prepared by Brian Gleckler (NIOSH 2014e). This report 

was prepared by NIOSH in response to Issue 1 in the March 20, 2014, issues matrix (NIOSH 

2014c) dealing with outdoor exposure to workers associated with routine atmospheric releases 

from INL facilities and resuspension of particulates associated with ground contamination. A 

second NIOSH white paper that is closely related to Issue 1 and explicitly addresses Issue 2 is 

NIOSH Investigation into the Issues Raised in Comment 2 from SCA-TR-TASK1-005 Revision 0, 

by Brian Gleckler, September 3, 2013 (NIOSH 2013). The former addresses chronic emissions, 

while the latter has applicability to episodic releases. It is noteworthy that, to the degree to which 

the Advisory Board determines that these issues should remain open, they could also have 

applicability to ANL-W. 

However, as will be discussed, SC&A believes that many aspects of these issues have been 

resolved. With respect to Issue 1, one of SC&A’s concerns was with the use of a mesoscale 

atmospheric transport model (i.e., MESODIF), which, at that time, SC&A argued is used for 

offsite dose reconstruction 20 miles or more from the release point, and that it is not appropriate 

for assessing doses to workers onsite. NIOSH’s white paper (2014e) provides a description of 

MESODIF, citing National Oceanic and Atmospheric Administration documentation that 

explains that the code can be used in the near field by selecting dispersion coefficients as input to 

the code that apply to shorter distances. The white paper (NIOSH 2014e) acknowledges that 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

11 of 48

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.

MESODIF may not be appropriate for use in predicting airborne concentrations that are less than 

100 m from a release point. However, the white paper explains that all substantive airborne 

releases were from elevated stacks, and that there would not be substantial exposures to workers 

located within 100 m from the stack, unless there were fumigation conditions,

1

1 Fumigation conditions refer to atmospheric temperature, wind speed, and stability class that cause a 

downdraft of emissions from a stack that results in elevated concentration of stack emissions close to the base of the 

stack. This occurs during temperature inversion, i.e., when the temperature increases with elevation above the 

effluent point of release.

which NIOSH 

states occur less than 1% of the time at INL. NIOSH concludes that, because of this, worker 

exposures outdoors are likely to be dominated by atmospheric releases that are greater than 

300 m from the worker locations, i.e., distances where MESODIF applies.

The second part of the March 5, 2014, NIOSH white paper (NIOSH 2014e) addresses issues 

raised by SC&A regarding exposures to resuspended particles in soil outdoors. In the white 

paper, NIOSH acknowledges that the resuspension pathway was not explicitly addressed in the 

site profile but argues that the resuspension pathway is not a significant contributor to outdoor 

internal dose. 

A review this NIOSH white paper was prepared prior to the release of the SEC evaluation report 

in March 2015 but has not been finalized and distributed per WG direction.2

2 SC&A’s response to NIOSH’s white papers that addressed issues described in the March 20, 2014, white 

paper (NIOSH 2014c) was originally prepared by SC&A in May 2014 at the request of the WG. However, though 

SC&A’s responses were completed in draft form, they were never finalized and delivered to NIOSH and the Board

because of the emergence of the INL SEC, whose examination took precedence. At that time, it was determined that 

SC&A should delay delivering its responses to NIOSH’s white papers until a determination could be made with

regard to the SEC and its relevance to the various active INL site profile issues, as delineated above. These SC&A

draft white papers are currently undergoing internal review and, upon completion, will require review by the U.S.

Department of Energy (DOE). These white papers will then be delivered to NIOSH and the Advisory Board.

As will be seen in 

our draft review of this issue, we accept NIOSH’s arguments that MESODIF can be used at 

distances as little as 100 m from the release location. However, NIOSH should provide 

additional discussion on possible localized outdoor exposures due to downwash associated with 

the elevated releases and possible ground level releases. In addition, issues related to the 

deposition and resuspension of radionuclides onsite from the elevated releases, or from 

radionuclides in soil, should be explicitly addressed. Hence, we believe that this issue requires 

some additional discussion with the WG. Note that there is additional information on this subject 

in the NIOSH white paper dated September 3, 2013 (NIOSH 2013), which is discussed below. 

The subject of resuspension and resuspension factors is addressed in greater detail in a recently 

completed, but yet to be delivered, SC&A’s draft review of this subject. On that basis, we 

believe that NIOSH has adequately responded to some, but not all, of the concerns raised in 

Issue 1. 

The NIOSH white paper dated September 3, 2013 addresses, in part, Issue 2. NIOSH 

acknowledges that concerns raised by SC&A regarding airborne emissions from Initial Engine 

Test (IET) 10, as provided in SC&A 2006, require further investigation. To our knowledge, 

NIOSH has not prepared any material that adequately addresses this aspect of Issue 2. However, 

in its white paper, NIOSH explains the following: 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

12 of 48

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.

Section 4.2.2.3 and Attribution 11 of the environmental TBD (ORAUT 2010) 

indicates that when the analysis of the INEL-HDE (DOE 1991) was completed the 

meteorological diffusion trajectories were reviewed to determine which INL 

facilities were affected. The result of those trajectory reviews was that only 16 

releases had the potential to affect other INL facilities. As a result of those 

reviews, IETs #3, #4, and #10 were determined to not affect other INL facilities, 

and no onsite intakes for those episodic releases were calculated and included in 

the environmental TBD. [NIOSH 2013]

The NIOSH (2013) white paper provides detailed information on the trajectories of the plumes 

associated with IET 3 and 4. Based on this material, SC&A recommends closing these aspects of 

Issue 2. With respect to IET 10, the white paper explains that trajectories are not available for 

these releases. However, the white paper explains the following: 

Dispersion factors and air concentration values were generated for the 32 runs 

associated with IET #10 (DOE 1991d). When the dispersion factors and air 

concentrations for the 4 downwind locations in the shaded portions of Figure 5 

are zero, the releases associated with that specific run would not have affected the 

INL workers. Of the 32 runs, 12 of the runs (i.e. runs 5, 9, 11, 19, 20, 26, 32, 38, 

40, 48, 49, and 57) had air concentrations of zero for all 4 downwind locations, 

and thus did not have the potential to contribute to the internal doses of the INL 

workers. The dispersion factors and air concentrations for 20 of the runs indicate 

that 20 of the runs had the potential to contribute to the internal doses of the INL 

workers at varying degrees.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

13 of 48

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.

Figure 1. Figure 5 – Trajectory Area Affecting Other INL Facilities (from the NIOSH

white paper dated September 3, 2013) 

The white paper (NIOSH 2013) later states the following:

IET #10 was divided into three phases (Foster et al. 1958). Phase I consisted of 

the initial IET runs; Phase II started with the runs that occurred after January 17, 

1958; and Phase III included the runs that occurred after February 4, 1958 

(Foster et al. 1958). The document Critical Review of Source Terms for Select 

Initial Engine Tests Associated with the Aircraft Nuclear Propulsion Program at 

INEL indicates that the radioactive releases from the Phase III runs (i.e. runs 37, 

38, 40, 42, 43, 45, 46, 47, 48, 49, 52, 53, 54, 55, 56, and 57) were underestimated 

in the INEL-HDE (Behling et al. 2005). After reviewing the information presented 

in that document, NIOSH agrees that the radioactive releases for those runs were 

likely underestimated in the INEL-HDE, but NIOSH does not necessarily agree 

with the magnitude of the underestimates. Further research is needed to 

determine the magnitude of those underestimates. It should also be noted that the 

review of the dispersion factors and air concentrations for the Phase III runs 38, 

40, 48, 49, and 57 previously determined that these runs did not have the 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

14 of 48

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.

potential to contribute to the internal doses of the INL workers. Therefore, the 

releases from runs 38, 40, 48, 49, and 57 do not need to be reevaluated. 

During the INL WG meeting held on November 10, 2015, this issue was discussed, and NIOSH 

stated that it is continuing to investigate IET 10 but has confirmed that the trajectories of the 

releases of IET 3 and 4 were off site and away from workers. As such, NIOSH concluded that 

these releases are not an issue (ABRWH 2015b, see pages 214 through 218 of the transcript of 

the November 10, 2015 WG meeting). During the meeting, NIOSH committed to provide the 

WG with a white paper on this subject. SC&A would like to look into NIOSH’s conclusion with 

respect to this issue before recommending closure.

2.2 ISSUE 19 (ANGLE OF INCIDENCE)

On March 11, 2014, NIOSH issued a white paper, NIOSH Investigation into the Issues Raised in 

Comment 19 from SCA-TR-TASK1-005 (NIOSH 2014f), prepared by Brian Gleckler. As 

indicated earlier, SC&A has a draft report close to completion that addresses this issue. NIOSH’s 

(2014f) white paper indicates that both OCAS-IG-001 (NIOSH 2007) and ORAUT-OTIB-0010 

(ORAUT 2006) address this issue to some degree, and that the ANL-W site profile, Technical 

Basis Document for the Idaho National Laboratory and Argonne National Laboratory-West –

Occupational External Dosimetry (ORAUT 2011), provides additional information and guidance 

pertaining to this matter. In addition, the white paper also refers to SC&A’s discussion of this 

issue, as it applies to the Mallinckrodt site profile review, Third Supplemental Review of the 

Mallinckrodt Site Profile (SC&A 2005), and to Hine and Brownell’s Radiation Dosimetry

(1956), which is the technical document SC&A used as the basis for this issue. This matter was 

also discussed at an INL WG meeting held in March 2014. On page 305 of the transcript 

(ABRWH 2014), NIOSH states that this issue is addressed in ORAUT-OTIB-0010 (ORAUT 

2006), and that generic issues related to that OTIB were closed out by the Procedures 

Subcommittee. However, SC&A had not reviewed that OTIB at that time from the perspective of 

specific site profiles. In revisiting the OTIB, it appears that it addresses inverse square law 

issues, but not angle of incidence, as described in detail in the Hines and Brownell (1956) 

textbook. 

It is appropriate to also summarize SC&A’s comments on this subject as outlined in SC&A’s 

pending draft report. That draft report is useful because it provides a more complete discussion 

of the history of issues related to angle of incidence and further argues that the issue is not 

actually addressed in ORAUT-OTIB-0010 (ORAUT 2006), as stated by NIOSH; nor does 

OCAS-IG-001 (NIOSH 2007) provide explicit guidance with respect to this matter. In fact, 

OCAS-IG-001 explicitly addresses the need to address angle of incidence. NIOSH also refers to 

DCAS-TIB-0013 (DCAS 2010) as another document that addresses angle of incidence. Our 

pending draft report reviews this assertion and finds that this matter has still not been resolved. 

DCAS-TIB-0013 uses computer simulations to estimate doses to specific organs from specific 

sources of uranium located at different distances and angles relative to the organs of interest.

However, DCAS TIB-0013 does not appear to address the complex interactions of photons, 

especially low energy photons, that strike the film badge at sharp angles. SC&A believes that 

there is a need for additional discussion of this matter with the Advisory Board.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

15 of 48

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.

2.3 ISSUES 9 AND 23 (HOT PARTICLES)

On March 18, 2014, NIOSH issued a white paper, Investigation of “Hot Particles” and the 

Health Physics Programs at the Idaho National Laboratory (INL) by Jodi Jenkins (NIOSH

2014a). As discussed in Section 2.0, SC&A believes that Issue 9, which deals with exposures to 

skin due to the deposition of hot particles on clothing and skin, has been resolved from the 

perspective that NIOSH has adopted generic protocols for performing these types of dose 

reconstruction, and they were reviewed and approved by the procedures subcommittee during the 

review of OTIB-0017 (ORAUT 2005) and other site profile reviews. Hence, SC&A agrees that 

NIOSH has developed scientifically sound and claimant-favorable protocols for performing these 

types of dose reconstructions and recommends that NIOSH reference these protocols in the INL 

site profile.

However, it is SC&A’s position that care must be taken to avoid rushing to judgment to dismiss 

this issue for particular claims. SC&A recommends that NIOSH provide additional guidance to 

dose reconstructors regarding when doses to skin from hot particle exposure at INL and ANL-W 

need to be considered, taking into consideration information that identifies skin cancer cases 

where hot particle exposures were likely but not included in the dose reconstruction. In its white 

paper (NIOSH 2014a), NIOSH provides a thorough review of the hot particle issue as it might 

apply to INL (and presumably also ANL-W), along with a summary of the generic literature 

addressing hot particles. At the end of the white paper, NIOSH draws the following conclusion: 

Based upon the above, NIOSH concludes that the likelihood of a “hot particle” 

going undetected on an employee’s skin for a significant period of time is remote.

There is no evidence that INL employees were contaminated with undetected “hot 

particles” for significant periods of time. Also, no other site-specific TBDs, with 

the exception of Hanford, provide guidance for undetected “hot particles.” The 

Hanford “hot particle” situation is unique and the same issue did not exist at 

INL. In addition, there is complex wide guidance in place that addresses skin 

contaminations and “hot particle” exposures as they relate to skin cancers. 

SC&A believes that hot particle exposures are, in fact, an issue at INL, and that the site profile 

should provide guidance to dose reconstructors regarding when exposures to hot particles need to 

be explicitly addressed, especially for claimants with skin cancer.

On close inspection, Issue 23, which deals with hazardous jobs, is primarily concerned with hot 

particles deposited on skin and clothing. Hence, SC&A reaffirms its earlier opinion (which was 

adopted by the WG and NIOSH) that Issue 23 is similar to Issue 9, and that the issues should be 

grouped together. 

2.4 ISSUE 24 (EXTREMITY MONITORING)

On March 6, 2014, NIOSH issued a white paper, NIOSH Investigation into INL Site Profile 

Review - Issue 24” by Jodi Jenkins (NIOSH 2014d). The white paper explains that 53 claimants 

were diagnosed with 62 cancers at INL/ANL-W and that 3% involved cancer of the extremities. 

The white paper explains that the external dosimetry monitoring programs at INL/ANL-W 

involved the use of extremity monitoring beginning in 1953 but, prior to the 1980 time period, 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

16 of 48

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.

multi-badge monitoring was rare. The white paper further explains the conditions where 

extremity monitoring was performed but also states that not all operators were provided with 

extremity dosimetry in the early years. As a follow-up to this white paper, and with the objective 

of closing this issue, SC&A recommends that we review the cases that involved extremity 

cancers (especially before 1980) and assess how the doses were reconstructed. SC&A is 

currently reviewing radiological monitoring practices among randomly sampled claimants at 

ANL-W and preparing a white paper. Our draft observation at this time (referred to in our draft 

report as Observation 4) is as follows:

Observation 4: Even among sampled workers who were most likely to require 

extremity monitoring on a semi-regular basis, extremity monitoring is often 

sparse from year to year for many workers. Nonetheless, it may be instructive for 

NIOSH to evaluate available extremity monitoring data to determine if the typical 

methods employed in DCAS-OTIB-0013 (DCAS 2010) are applicable and 

claimant favorable for ANL-W claimants. 

2.5 ISSUE 34 (HIGH RISK NEUTRON EXPOSURES)

On March 11, 2014, NIOSH issued a white paper, NIOSH Investigation into the Issues Raised in 

Comment 34 from SCA-TR-TASK1-005 (NIOSH 2014g). Issue 34 deals with whether potential 

doses to personnel performing “high-risk” jobs, with respect to neutron exposures, are 

adequately identified. As indicated in the March 2014 issues resolution matrix (NIOSH 2014c), 

both NIOSH and SC&A were directed to look into this matter further. The NIOSH (2014g) white 

paper cited above addresses this concern. SC&A concurs with NIOSH with regard to its response 

to the neutron dosimetry issues raised by SC&A and how NIOSH plans to remedy these issues. 

However, NIOSH’s position in its white paper is that all sources of potentially significant 

neutron exposures have been accounted for, and that employees who had the potential of 

receiving significant neutron exposures were adequately monitored. SC&A is addressing this 

issue in a white paper currently in preparation. In addition, our preliminary review of the 

ANL-W ER for SEC-00224 identifies potential data gaps in the neutron dosimetry records. At 

the time of the preparation of this review, NIOSH is in the process of capturing additional 

external dosimetry data that might help fill these gaps, or at least put NIOSH into a position to 

develop coworker models applicable to specific facilities, campaigns, and experiments at 

ANL-W.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

17 of 48

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.

3.0 STATUS OF INL SEC ISSUES

NIOSH released the SEC Petition Evaluation Report for SEC-000219 for the Idaho National 

Laboratory (NIOSH 2015a) on March 12, 2015. On March 25, 2015, NIOSH presented the 

petition ER at the 104th meeting of the Advisory Board on Radiation and Worker Health, which 

took place in Richland, Washington. At that time, NIOSH recommended the following class 

definition of workers for inclusion to the SEC class: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at Idaho National Laboratory in 

Scoville, Idaho, and were monitored for external radiation at the Idaho Chemical 

Processing Plant (CPP) (e.g., at least one film badge or TLD dosimeter from 

CPP) between January 1, 1963 and December 31, 1974 for a number of work 

days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established 

for one or more other classes of employees in the Special Exposure Cohort. 

[NIOSH 2015a]

When this class definition was proposed, it was defined only for workers at the CPP and 

included the time period January 1, 1963, through December 31, 1974. One of the main issues 

addressed by the Advisory Board with respect to this definition of the class was difficulties in 

providing assurance that some INL workers might have worked at CPP but did not have 

dosimeters that clearly indicated their work location, and, as a result, these workers would be 

missed using this definition of the class (see ABRWH 2015a, pp. 187–210). SC&A was then 

tasked by the Advisory Board to investigate the available dosimetry records in order to assess the 

validity of the class definition, as proposed by NIOSH. In response to that request, on June 29, 

2015, SC&A issued SC&A Evaluation of Idaho Chemical Processing Plant Class Definition 

Requiring Evidence of External Dosimetry (1963–1974) (SC&A 2015h). That report contained a 

number of findings related to weaknesses in the available external dosimetry that confirmed 

many of the Board’s concerns regarding the definition of the class and how it would be 

implemented. 

One of the outcomes of these investigations and deliberations was the apparent need to revise the 

definition of the class by expanding the definition to all workers at INL but limiting the time 

period covered by the class from March 1, 1970, through December 31, 1974, until such time 

that NIOSH completes its research on the adequacy of the external dosimetry data. In order to 

accommodate this need, NIOSH issued a revised petition ER (NIOSH 2015b) on July 21, 2015, 

and, on May 2, 2016, the Advisory Board recommended a revision to the class definition, as 

follows: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Idaho National Laboratory 

(INL) in Scoville, Idaho, and were monitored for external radiation at INL (e.g., 

having at least one film badge or TLD dosimeter) during the period from March 

1, 1970, through December 31, 1974, and were employed for a number of work 

days aggregating at least 250 work days, occurring either solely under 

employment during the period from March 1, 1970, through December 31, 1974, 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

18 of 48

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.

or in combination with work days within the parameters established for one or 

more other classes of employees in the Special Exposure Cohort. [ABRWH 2016] 

During its deliberations on this matter, NIOSH indicated that it believed that there are sufficient 

external dosimetry data for the first time period (i.e., January 1, 1963, through February 28, 

1970) to limit the definition of the class to CPP workers. At the time of the preparation of this 

report, NIOSH was compiling external dosimetry data that it believes will allow limiting the 

definition of the class to CPP workers for this earlier time period. 

During this time period, there was also some discussion regarding whether a group of workers 

referred to as the CADRE should be included in the definition of the class. The outcome of these 

investigations was a NIOSH report, CADRE Evaluation (Area Code 71) for Consideration as 

Part of the Idaho Chemical Processing Plant Special Exposure Cohort, prepared by Timothy D. 

Taulbee and dated February 25, 2016 (NIOSH 2016a). The conclusion of those investigations is 

that the personnel referred to as CADRE should not be included in the class. 

3.1 SC&A PRELIMINARY REVIEW OF THE INL EVALUATION REPORT FOR 

SEC-00219 

In addition to matters related to the definition of the class, and as part of the review of the 

NIOSH Petition ER for SEC-00219 (NIOSH 2015a) (dated March 12, 2015), SC&A performed a 

number of focused reviews, which identify technical issues that require additional investigation. 

On July 6, 2015, SC&A issued Interim Summary Report on the Evaluation of NIOSH’s Idaho 

National Laboratory SEC-00219 Petition Evaluation Report (SC&A 2015a). This report, 

referred to as the July 6, 2015, interim summary report, is not a conventional complete ER 

review but served as a status update of SC&A’s review as of the date of its publication, along 

with a recommendation for follow-up investigations. 

In its July 6, 2015, interim summary report (SC&A 2015a), SC&A reviewed the Site Research 

Database (SRDB) in support of the INL site profile and ER for areas, subareas, and time periods 

at INL, including various research projects and special campaigns, where external and internal 

dosimetry data might be incomplete (i.e., data gaps). Unlike most reviews of this type, it does not 

contain findings but provides a number of preliminary commentaries and recommendations for 

consideration by NIOSH and the Advisory Board for further investigation. This approach was 

employed because it was acknowledged by NIOSH and the Board that the SEC review process 

was a work in progress, and the review should be performed in a graded manner. Specifically, 

the ER (NIOSH 2015a), in addition to identifying an SEC class, also identified operations and 

time periods that were held in reserve, meaning that additional investigations were needed by 

NIOSH in order to determine whether any of these reserved operations and associated time 

periods should be included in the class. The ER also identified operations and time periods where 

NIOSH judged that doses could be reconstructed and recommended denial of those portions of 

the SEC petition (see Table 1). SC&A focused its preliminary review of the ER on the latter 

operations and time periods, where NIOSH determined that doses could be reconstructed with 

sufficient accuracy. 

Given the complexity of the site, SC&A divided its review into different categories of 

investigation corresponding primarily to different areas within INL (not including ANL-W) with 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

19 of 48

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.

respect to dose reconstructability and gap analysis and providing a plan for more detailed 

reviews. Table 1 of SC&A’s July 6, 2015, interim summary report (SC&A 2015a) is reproduced 

here, because it provides a convenient roadmap of SC&A’s preliminary review of the ER. 

Table 1. INL SEC 00219 Evaluation Report: Feasibility of Reconstructing Internal Doses 

for January 1, 1963, to December 31, 1974 (a), (b)

Operating Area (c) Reconstruct?

Chemical Processing 

Plant (CPP)

Yes: 1/1/53–12/31/62: Bioassay data available.

No: 1/1/63–12/31/74: Insufficient bioassay data to support reconstruction of 

internal exposures to U, Np, Pu, and other related transuranics. Beginning in 

1963, increased α-contamination levels were detected with no accompanying 

increase in Pu bioassay.

Reserved: 1/1/75–?: Evaluate CPP HP Program Improvements 1971–1980.

Test Reactor Area 

(TRA)

Yes:

• 1/1/55–12/31/66

• 1/1/67–12/31/70: coworker model.

Reserved: 1/1/61–12/31/70: TAN-607 (Fuel Storage Vaults) and TAN-615 

(Actuator Building) due to potential U exposures in the absence of MFPs.

Test Area North (TAN) Yes:

• 1/1/55–12/31/66

• 1/1/67–12/31/67 and 1/1/69–12/31/70: coworker model.

Reserved: 1/1/68–12/31/68: Insufficient data currently available for ARA-I 

(Auxiliary Reactor Area-I) due to potential unmonitored exposures to Pa-233 

from separation of that isotope from irradiated Th slugs.

Central Facilities Area 

(CFA)

Yes:

• 1/1/49–12/31/66

• 1/1/67–12/31/70: coworker model.

Burial Grounds Yes:

• 1/1/52–12/31/66

• 1/1/67–12/31/68: coworker model.

Reserved: 1/1/69–12/31/70: Evaluate a newly-implemented procedure of 

waste exhumation and retrieval

(a) SEC-00219 time period evaluated by NIOSH is 1/1/63–12/31/74 for CPP based on insufficient data to 

reconstruct internal doses.

(b) Operations at INL began 1/1/49, but some of the areas began operations later.

(c) ANL-W is not included in this SEC, but will be the subject of SEC-00224, which is under development.

(d) NIOSH is developing an internal, mixed fission product (MFP) coworker model stratified by area for time 

periods beginning 1/1/67.

Source: SC&A 2015a.

Each of these areas were investigated to a limited extent in the July 6, 2015, interim summary 

report (SC&A 2015a). The following summarizes the results of these preliminary investigations. 

3.1.1 Definition of the Class

SC&A’s initial investigation pertaining to class definition involved a review of 30 semirandomly selected claimants, emphasizing contract workers, in order to determine if they had 

sufficient dosimetry records for 1963 through 1974 to identify those workers exposed at CPP. 

The results of these inquiries were presented at the July 2015 full Advisory Board meeting.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

20 of 48

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.

SC&A was then directed to continue its review of claimants in the context of the proposed class 

definition. 

Subsequently, SC&A performed a mock class implementation for the entire claimant population 

at INL, so all claims were looked at but with varying degrees of scrutiny (if a claim already met 

the requirements of the class it was not looked at further). This was delivered in September 2015 

(SC&A 2015e) and resulted in the follow-up for 18 claims with the site and another report 

(discussed in January and March 2016). During discussions in March 2016, the INL Work Group 

requested that SC&A and NIOSH update their respective analyses to include claims that had 

been filed after the initial studies had been completed in the summer of 2015. SC&A delivered 

its updated analyses in May 2016 (SC&A 2016f); this report is planned to be discussed during 

the upcoming WG meeting in August 2016. 

In addition, SC&A also reviewed interview summaries of about 50 sets of workers. Based on 

those interviews, SC&A found no contradictory evidence to suggest that workers entered CPP 

without external dosimetry badging. However, there were indications that the requirement of a 

specific CPP badge may have been relaxed at some later date to only require a dosimetry badge 

for any INL facility. The results of these investigations partly contributed to the revised 

definition of the class, as described in Section 3.0, and some of the follow-up investigations 

related to the scope and definition of the class that are continuing at the time of the preparation of 

this report. 

3.1.2 Fission and Activation Product (FAP) Bioassay Indicator Radionuclides 

SC&A assessed the appropriateness of the methods that NIOSH proposes to use to determine 

internal doses for areas and times where it asserts that it can reconstruct doses. NIOSH’s basis 

for assigning internal doses for most years and locations not covered by the proposed SEC class 

and the reserved areas and dates relies on the following four assumptions (as stated in SC&A 

2015a): 

A. FAP Bioassays – Sufficient worker records containing FAP bioassay (in-vitro and invivo) results are available to assign intakes and resulting doses from FAP (some 

periods/areas may need an FAP coworker model developed). 

B. FAP Intakes – Except for special situations, all the dosimetrically significant FAP intakes 

are directly tied to an indicator radionuclide (strontium-90 [Sr-90] or cesium-137 

[Cs-137]). The FAP ratios and intake assignment methods provided in ORAUT-OTIB0054 (ORAUT 2015; hereafter referred to as “OTIB-0054”) bound all FAP exposure 

potentials at INL

C. Actinide Intakes – Except for special situations, the actinide (uranium, plutonium, 

thorium, etc.) intakes are directly tied (in a constant ratio) to the FAP; therefore, actinide 

intakes and resulting doses can be assigned using Table 5-22 (Sr-90 ratios) and/or 

Table 5-23 (Cs-137 ratios) of ORAUT-TKBS-0007-5 (ORAUT 2010). 

D. Special Situations Actinides – Personnel involved in operations and situations (planned 

or unplanned) with actinides present, that were not directly tied to an FAP in a constant 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

21 of 48

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.

ratio, were adequately monitored, and the results are available in the workers’ records. 

Therefore, actinide intakes and resulting doses can be reconstructed in these special 

situations. 

SC&A’s July 6, 2015, interim summary report (SC&A 2015a) provides commentary on Items B 

and C. Item A is the topic of a separate report described in Section 4.6 and Item D requires 

further investigation. SC&A’s commentaries regarding Items B and C are summarized as 

follows. 

Item B: The use of OTIB-0054 protocols for reconstructing internal doses from mixed FAPs 

associated with reactor operations at INL is questionable because of the very unique nature of the 

reactor design, operations, and experiments performed at many of the areas at INL. Though 

ANL-W is not addressed in SC&A’s July 6, 2015 (SC&A 2015a), and October 26, 2015, ER 

reviews (SC&A 2015f, 2015g), this comment is also applicable to ANL-W reactors.

Item C: The methods used in the ER for reconstructing internal doses for actinides, using 

indicator radionuclides, as provided in Tables 5-22 and 5-23 in the TBD (ORAUT 2010) are 

questionable because of the unique nature of operations at the various facilities at INL, including 

ANL-W. 

The interim summary report (SC&A 2015a) recommended a number of follow-up investigations 

related to these matters. These investigations were subsequently performed, and the associated 

white papers are discussed below (see Sections 4.1–4.3, 4.5 and 4.7). 

3.1.3 Reactor Modeling

The July 6, 2015, interim summary report (SC&A 2015a) further investigated the limitation of 

OTIB-0054 (ORAUT 2015) as applied to reactor workers at INL and recommended that further 

study should be done for off-normal operations, including “special” materials irradiation runs, 

and for any incidents that might have occurred and exposed personnel to radiation. It also 

recommended that these investigations should be extended to other reactor areas, especially 

TAN, which hosted very unusual reactor experiments, such as the Aircraft Nuclear Propulsion 

(ANP) reactors, which were decidedly different in fuel composition and arrangement and 

operation than other types of reactors. These investigations were subsequently performed, and 

the associated white paper (SC&A 2015b) is discussed in Section 4.1. 

3.1.4 Burial Grounds

The July 6, 2015, interim summary report (SC&A 2015a) investigated issues associated with the 

reconstruction of doses, primarily internal doses, of workers at the burial grounds. SC&A looked 

into the adequacy of the health physics oversight programs and contamination controls, waste 

characterization, data completeness, and the methods used to reconstruct internal doses using the 

available bioassay data. SC&A’s review identified key concerns with NIOSH’s ability to 

reconstruct worker exposures, especially internal exposures to mixed FAPs and transuranics. 

SC&A 2015a provides a number of recommendations for follow-up investigations pertaining to 

waste characterization, contamination controls, bioassay data, and air sampling and swipe data, 

and the feasibility of relying on OTIB-0054 and ORAUT-OTIB-0060 (ORAUT 2014; hereafter 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

22 of 48

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.

referred to as “OTIB-0060”), that are currently being accomplished through additional onsite 

data captures and former worker interviews.

3.1.5 Central Facilities Area (CFA)

The July 6, 2015, interim summary report (SC&A 2015a) investigated issues primarily 

associated with the reconstruction of internal exposures at CFA using gross beta/gamma analysis 

of urine samples, and OTIB-0054 and OTIB-0060 and the need to separately evaluate exposures 

to uranium. We found limitations in the bioassay and air sampling programs that raise questions 

regarding the ability to reconstruct internal exposures at CFA. As may be noted, these are

recurring issues throughout the INL complex that require further investigation. 

3.1.6 Chemical Processing Plant Pre-1963 

The July 6, 2015, interim summary report (SC&A 2015a) focused on the external and internal 

dosimetry monitoring data at CPP pre-1963 because this is the time period where NIOSH 

believes that sufficient data are available to reconstruct doses. The time period from 1963 to 

1970 is under investigation by NIOSH for possible SEC consideration, and an SEC was 

recommended for 1970 to 1974. SC&A looked at the operations and the external and internal 

dosimetry data pre-1963, especially contamination events, and recommended continuing these 

investigations.

3.1.7 Test Area North (TAN)

The July 6, 2015 interim summary report (SC&A 2015a) divided its investigations into the 

various subareas at TAN because of the unique nature of the research and campaigns associated 

with each subdivision and time period. We found that, as a whole, there are extensive external 

monitoring data for workers at TAN throughout its history. However, the records cannot always 

be grouped according to subdivisions within TAN. As a result, it appears that it might be difficult 

to construct external dosimetry coworker models for the various subdivisions. If it is determined 

that coworker models are needed due to data gaps at TAN, this could become an SEC issue 

because of the unique nature of the activities at the different subdivisions at TAN (i.e., the data 

cannot be pooled for the purpose of constructing coworker models for individual TAN 

subdivisions). SC&A also found limitations in the completeness of neutron dosimetry data at 

TAN. SC&A 2015a recommends a number of follow-up investigations, including additional data 

capture, to help create a more complete external dosimetry record. Shortly after submission of 

this report, NIOSH indicated that it had plans for additional data capture. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

23 of 48

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.

4.0 SC&A FOLLOW-UP INVESTIGATIONS

During the July 8, 2015, INL WG teleconference, which followed delivery of the July 6, 2015, 

interim summary report (SC&A 2015a), SC&A was tasked to prepare a series of white papers in 

accordance with the recommendation provided by SC&A in the interim summary report. These 

reports were delivered to NIOSH and the Board in September (SC&A 2015b, 2015c, 2015d, 

2015e) and October of 2015 (SC&A 2015f, 2015g). In addition, a follow-up report pertaining to 

the SEC class definition for CPP was delivered in January 2016 (SC&A 2016b). The following 

subsections present a brief summary of each report. Each summary was excerpted directly from 

the executive summary of each report, with slight modifications to references and acronyms to fit 

this report. 

4.1 REVIEW OF NIOSH STRATEGY FOR RECONSTRUCTING INTERNAL DOSES 

TO WORKERS AT TEST AREA NORTH (SEPTEMBER 2015) 

This report addresses selected aspects of the TAN operations and facilities that SC&A identified 

as particularly important. The topics noted for more detailed investigation in this follow-up 

report include: (1) the applicability of OTIB-0054 (ORAUT 2015) and Tables 5-22 and 5-23 of 

the site profile internal dosimetry TBD, ORAUT-TKBS-0007-5 (ORAUT 2010) to the 

performance of internal dose reconstruction for facilities that handled and stored spent and 

irradiated fuel; (2) the very unique circumstances associated with the ANP program; and (3) an 

evaluation of the completeness of the external dosimetry data at the various TAN facilities.

SC&A’s primary findings are as follows: 

1. The reactor, fuel, and operational combinations that underpin the OTIB-0054 

methodology reflect situations where burnup often occurred over protracted periods of 

time (hundreds of days) and the fuel maintained its integrity during burnup. The fuel at 

some of the TAN operations, however, had very short burnup times and the reactors 

operated at high enrichments and at temperatures where the fuel was allowed to melt. The 

implications of these findings are that the isotopic mix of radionuclides used in 

OTIB-0054 may not apply to the fuel handled at many TAN facilities.

2. It is likely that some onsite workers were exposed to some of these emissions from the 

IETs, even though the emissions were released under controlled conditions to minimize 

both onsite and offsite exposures. In addition, there were likely maintenance operations 

where workers might have been exposed to residue from these tests and their emissions. 

The emissions associated with the IETs, as reported by DOE and its contractors, were 

often significantly underestimated. The implications are that the reconstruction of doses 

to workers at INL involved with the IETs and who may have been exposed to airborne 

emissions associated with them, must take into consideration the revised information 

cited by the SC&A investigations regarding the emissions and not depend entirely on the 

data reported at that time by DOE and its contractors. 

3. The most significant finding of our investigations is that we do not believe we can 

consistently assign the external dosimetry monitoring data to the different work areas, 

operations, and campaigns within TAN, at least given the data we reviewed. The 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

24 of 48

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.

implications are that NIOSH might not be able to build coworker models for many of the 

different subdivisions at TAN. This could be an important SEC issue for TAN, because 

the types of activities at TAN were so diverse that different coworker models might be 

required. 

4.2 EVALUATION OF AVAILABLE SURVEY DATA FOR THE CENTRAL 

FACILITIES AREA AT IDAHO NATIONAL LABORATORY (SEPTEMBER 2015) 

This report (SC&A 2015c) presents a review of the available survey data for the CFA, both 

during operations and prior to decontamination and decommissioning (D&D), in order to 

determine the actinide to Sr-90 and actinide to Cs-137 ratios and compare these ratios to the 

values in Tables 5-22 and 5-23 of ORAUT-TKBS-0007-5 (ORAUT 2010). The report provides a 

summary of NIOSH’s proposed methods for bounding operational period internal doses for the 

CFA, a review of the available survey data, and a comparison of the derived values to the values 

in Tables 5-22 and 5-23 of ORAUT-TKBS-0007-5. 

SC&A identified and reviewed 79 radiological contamination smear results and 18 soil sample 

results. Our analyses of the smear data and soil sample results indicated at least general 

agreement in the magnitude of the maximum contamination ratios for uranium and plutonium 

given in Tables 5-22 and 5-23 of ORAUT-TKBS-0007-5 (ORAUT 2010). However, there are 

several limitations in the data, as follows:

1. The CFA-669 Hot Laundry operated from 1950 until 1981. The survey data found were

very limited and for 1954–1956, the period of early operations.

2. The survey data are written given in units of counts per minute (cpm). While assumptions

regarding the equipment and detection efficiencies can be made based on the time period

and equipment used at that time, it may be more beneficial to use more recent and well

documented survey information.

3. The soil samples were collected during D&D operations from a trench and berm formed

during the excavation of the 8-in contaminated sanitary sewer line on the north side of

CFA-669. It may be more useful to use more sample results, particularly those obtained

during the characterization survey, prior to D&D.

SC&A believes the approach used by NIOSH to reconstruct doses at the CFA could be improved 

if the above three data limitations could be minimized.

4.3 NIOSH SEC-00219 TEST REACTOR AREA (TRA) MODELING 

(SEPTEMBER 2015) 

This report (SC&A 2015d) seeks to determine whether the reactors that have operated, or are 

currently operating, in TRA specifically are adequately enveloped by the representative reactors 

of OTIB-0054, so that the OTIB can be used to reconstruct internal doses. SC&A 2015d 

compares the characteristics of the reactors used to establish the isotopic mix of radionuclides in 

OTIB-0054 to the characteristics of the reactors at TRA. The report does not have any findings, 

but is used to help guide future investigations related to reconstructing internal doses for workers 

at INL reactors using OTIB-0054 and worker bioassay data. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

25 of 48

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.

4.4 EVALUATION OF THE REVISED SEC CLASS DEFINITION FOR THE IDAHO

NATIONAL LABORATORY CHEMICAL PROCESSING PLANT (1963–1974) 

This report (SC&A 2015e) follows up on the class definition issues discussed above. Some of the 

key observations are that SC&A was able to identify workers with evidence to suggest potential 

radiological exposures at CPP during the time period covered by the SEC that did not have 

sufficient external monitoring records to meet the SEC class definition requirements. The report 

also raised questions regarding whether CADRE workers should be included in the class. As 

described in Section 3.0, this issue was resolved. SC&A recommended additional data capture at 

that time, which NIOSH indicated was under way. 

4.5 SC&A’S EVALUATION OF THE NIOSH EVALUATION REPORT PROPOSED 

USE OF FISSION-ACTIVATION PRODUCT BIOASSAY INDICATOR 

RADIONUCLIDES (IN CONJUNCTION WITH ORAUT-OTIB-0054 AND 

ORAUT-TKBS-0007-5) FOR ASSESSMENT OF FISSION-ACTIVATION 

PRODUCT AND ACTINIDE INTAKES AT IDAHO NATIONAL LABORATORY 

(OCTOBER 2015) 

This report (SC&A 2015f) goes into further detail on the discussion provided above with respect 

to the four fundamental assumptions, A through D, used by NIOSH to reconstruct internal doses 

using bioassay data (see Section 3.1.2). Specifically, this report further investigates the validity 

of assumptions B, C, and D. Assumption A is addressed in a separate report (see Section 4.6). 

SC&A found that many of these assumption are not supported by the data reviewed with respect 

to (1) the Cs-137/Sr-90 ratios, (2) the relationship between Cs-137 and Sr-90 and the actinides as 

provided in Tables 5-22 and 5-23 in the site profile (ORAUT 2010), and (3) establishing special 

relationships between fission products and actinides in bioassay samples. 

4.6 EVALUATION OF INTERNAL MONITORING FOR FISSION AND 

ACTIVATION PRODUCTS AMONG INL CLAIMANTS (1949–1970) 

(OCTOBER 2015) 

This report (SC&A 2015g) was prepared by SC&A under the direction of the WG to further 

investigate an issue identified in SC&A’s July 6, 2015, interim summary report (SC&A 2015a) 

as Item A, which is related to the sufficiency of worker bioassay records for reconstructing doses 

to fission and activation products. This investigation involved the review of 92 randomly 

selected claimants in order to determine the availability of FAP bioassay data for the purpose of 

determining the need for one or more coworker models for use in reconstructing internal doses. 

SC&A found the data somewhat incomplete, thereby requiring the development of coworker 

models, but not to the extent that would preclude the development of coworker models as 

required for particular time periods and areas. This issue was discussed in depth during the 

March 2016 INL WG meeting, and it was agreed that a coworker model for FAP material was 

needed.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

26 of 48

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.

4.7 INL SEC-00219 REACTOR PRIORITIZATION FOR EVALUATION OF ORAUTOTIB-0054 APPLICABILITY (MARCH 2, 2016) 

This report (SC&A 2016c) was prepared to help to organize the Advisory Board’s investigations 

of one of the more substantive issues identified in SC&A’s review of the ER; i.e., concerns that 

there might be significant limitations to using the default mixes of radionuclides adopted in 

OTIB-0054 for reconstructing internal doses to workers at reactors where the data characterizing 

the internal exposures to those workers consisted of gross beta/gamma analysis. The primary 

concern is that the reactors used in OTIB-0054 for establishing the radionuclide mixes in the fuel 

were different than many of the reactors at INL, including ANL-W. Because of the large number 

of reactors at INL and ANL-W, SC&A was requested by the Board to prioritize the reactors that 

are of greatest concern with respect to this issue. SC&A’s March 2, 2016, report (SC&A 2016c) 

was prepared in response to this request. Following discussion with the WG, SC&A was 

requested to provide additional description of the basis for the prioritization of the reactors at 

INL and ANL-W. In response to that request, SC&A issued INL SEC-00219 Reactor 

Prioritization for Evaluation of ORAUT-OTIB-0054 Applicability, Revision 1 (SC&A 2016d) on 

June 10, 2016; the report was revised to include additional evaluation factors. This report is 

intended to help initiate and prioritize additional investigations by NIOSH and SC&A to 

determine the degree to which OTIB-0054 could be used for specific reactors. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

27 of 48

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.

5.0 ISSUES MATRIX FOR SEC-00219

Following the publication of SC&A’s July 6, 2015, interim summary report (SC&A 2015a) and 

the focused reviews delivered from September 2015 to January 2016, many of SC&A’s concerns 

were discussed at three WG meetings. An issues matrix, INL SEC-00219: Compilation of SC&A 

Review Issues, Comments, and Recommendations, was published March 13, 2016 (SC&A 

2016e), which captures the concerns expressed in the reports and the exchange of information at 

the WG meetings. Tables 2 and 3 reproduce this most recent INL SEC matrix, which can also be 

found at https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-inlsec219im-031316.pdf. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

28 of 48

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.

Table 2. INL SEC 0219: Compilation of SC&A Review Issues, Comments, and Recommendations – March 2016 

No. Description References Notes & Additional Comments

Issue A: Test Area North (TAN) – Scope of Review: (1) Applicability of ORAUT-OTIB-0054 (OTIB-0054 or ORAUT 2013) and Tables 5-22 and 

5-23 of the site profile internal dosimetry technical basis document (TBD) to the performance of internal dose reconstruction for facilities 

that handled and stored spent and irradiated fuel; (2) unique circumstances associated with the Aircraft Nuclear Propulsion (ANP) program; 

(3) completeness of the external dosimetry data at the various TAN facilities.

A-1 “...we do not believe we can consistently assign the external 

dosimetry monitoring data to the different work areas, operations, 

and campaigns within TAN, at least given the data we reviewed. The 

implications are that NIOSH might not be able to build coworker 

models for many of the different subdivisions at TAN. This could be 

an important SEC [Special Exposure Cohort] issue for TAN, because 

the types of activities at TAN were so diverse that different coworker 

models might be required.”

Review of NIOSH Strategy for 

Reconstructing Internal Doses to 

Workers at Test Area North, SC&A 

Report SCA-TR-2015-SEC0074A, 

Revision 0, draft, September 28, 2015. 

Executive Summary.

Resolution might require 

additional data capture.

SC&A comment: At the November 

11, 2015, Work Group (WG) 

meeting, NIOSH indicated that 

they only sampled the dosimetry 

data for TAN and that much more 

remains (pp. 170 & 176 of 

November 11, 2015, WG 

transcript).

The only area that they made a 

concerted effort to try and get all 

of the dosimetry was associated 

with the Chemical Processing Plant 

(CPP), and that was just between 

1963 and 1974.

They also indicated that they do 

not intend to develop an external 

coworker model for the Idaho 

National Laboratory (INL) (p. 173 

of November 11, 2015, WG 

transcript).

The WG agreed that this is a lower 

priority issue compared to some of 

the other areas of concern (p. 177 

of November 11, 2015, WG 

transcript).
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

29 of 48

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.

No. Description References Notes & Additional Comments

A-2 “For neutron dosimeters, the data appear to be spotty. If it can be 

assumed that neutron dosimeters were only assigned to individuals 

whom the radiation protection staff deemed at risk of neutron 

exposure, then the temporal gaps seen in the available neutron 

dosimetry data might indicate that there was no need for neutron 

monitoring because there was no source of neutron exposure 

potential. Investigation into the types of activities and experiments 

conducted during the periods of time for which no neutron

dosimeters were found might be needed to determine if neutron 

exposure was or was not likely.”

Ibid. (A1), Section 5.2. Ibid. (A1).

A-3

A-3

A-3

“Given the unique features of the aircraft nuclear propulsion 

systems [ANPs] tested at INEL [Idaho National Engineering 

Laboratory] and their equally unique mixtures of radionuclides that 

were released, SC&A believes that ‘conventional’ reactors and their 

modeled values may not be appropriate for deriving internal dose 

estimates to INEL workers.” Therefore, for spent nuclear fuel 

associated with ANP, use of ORAUT-OTIB-0054 is inappropriate for 

the following reasons:

Ibid. (A1), Section 4.0. —

• “...highly enriched uranium fuel (enrichments in excess of 90%) 

would contain very little Pu-239 and other actinides related to 

U-238 neutron interactions. Hence, it is unlikely that a substantial 

portion of TAN irradiated fuel would contain mixes of actinides 

that resemble the default mixes employed in Tables 5-22 and 

5-23 of the internal dosimetry TBD. We confirmed these concerns 

by performing a series of simplified ORIGEN runs. Hence, we 

believe that these matters could represent potential SEC issues.”

Ibid. (A1), Executive Summary. —

• “Wafer-thin ribbons of UO2 and absence of cladding ensured high 

release fraction by recoil and/or diffusion of many FPs [fission 

products]. Most notably are volatile radionuclides (iodine, 

cesium, etc.).”

J. Mauro PowerPoint presentation at 

November 10, 2015, INL Work Group 

Meeting, showing results of report 

SCA-TR-2015-SEC0074A.

—
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

30 of 48

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.

No. Description References Notes & Additional Comments

A-3 • “Release and depletion of FPs from fuel elements must further be 

assumed by the fact that for some IETs [Initial Engine Tests], 

intentional fuel failure (and unintentional fuel failure) resulted 

from temperatures exceeding 3,200°F.”

Ibid. —

A-4 “Independent analyses of airborne emissions associated with the 

major IETs, as performed by SC&A under contract to CDC, revealed 

that the DOE [Department of Energy] significantly underestimated 

the airborne emissions for the IETs with the largest airborne 

emission.” “Outdoor exposures associated with releases from the 

ANP need to consider the results of CDC’s investigations into these 

source terms.”

Ibid. SC&A comment: At the November 

11, 2015, WG meeting, NIOSH was 

tasked to prepare a white paper 

on IET #10.

NIOSH indicated that they will not 

be prepared to discuss IET #10 at 

the March 1, 2016, WG meeting, 

as it has been delayed due to 

other priorities.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

31 of 48

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.

No. Description References Notes & Additional Comments

Issue B: Central Facilities Area (CFA) – Scope of Review: Evaluate available survey data for the CFA, both during operations and prior to 

demolition and dismantlement, to determine the actinide-to-Sr-90 and actinide-to-Cs-137 ratios and compare these ratios to the values in 

Tables 5-22 and 5-23 of the internal dosimetry TBD (ORAUT-TKBS-0007-5).

B-1 “Analyses of the smear data and soil sample results...indicates at 

least general agreement in the magnitude of the maximum 

contamination ratios for uranium and plutonium given in Tables 5-22 

and 5-23 of ORAUT-TKBS-0007-5.... However, there are several 

limitations in the data used.” 

1. The CFA-669 Hot Laundry operated from 1950 until 1981. The 

survey data found were very limited and from 1954–1956, the 

period of early operations.

2. The survey data are written given in units of counts per minute 

(cpm). While assumptions regarding the equipment and 

detection efficiencies can be made based on the time period 

and equipment used at that time, it may be more beneficial to 

use more recent and well-documented survey information. 

3. The soil samples were collected during decontamination and 

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

formed during the excavation of the 8-inch contaminated 

sanitary sewer line on the north side of CFA-669. It may be more 

useful to use more sample results, particularly those obtained 

during the characterization survey, prior to D&D.

Evaluation of Available Survey Data for 

the Central Facilities Area at Idaho 

National Laboratory, SCA-SEC-2015-

0074-B, Revision 0, draft, September 

28, 2015. Section 4.0. 

SC&A comment: Data capture in 

January 2016 sought relevant 

information. The items recovered 

for the Site Research Data Base 

(SRDB) may provide some insight 

when available. — We still have 

the Seattle and return INL data 

captures coming up later in 2016.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

32 of 48

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.

No. Description References Notes & Additional Comments

Issue C: Test Reactor Area (TRA) – Scope of Review: Does the methodology of ORAUT-OTIB-0054 (Fission and Activation Product Assignment 

for Internal Dose-Related Gross Beta and Gross Gamms Analysis) adequately model the reactor characteristics and operations of the Test 

Reactor Area (TRA)?

C-1 “The MTR [Materials Test Reactor]...ran for a period of time with 

plutonium rather than uranium fuel.... It is not clear which, if any, of 

the nine OTIB-0054 cases...would adequately envelope this 

situation.”

“The issue of whether OTIB-0054 adequately envelopes the MTR 

when fueled with plutonium merits further investigation and 

discussion.”

NIOSH SEC-00219 Test Reactor Area 

Modeling, SC&A Report SCA-SEC-2015-

0074-C, Revision 0, draft, September 

28, 2015. Section 3.2.

SC&A comment: Discussed pp. 

132–144, November 11, 2015, WG 

transcript.

SC&A is tasked to develop a 

prioritized list of the 52 reactors at 

INL, to ascertain if OTIB-0054 

methods are bounding and 

sufficiently accurate. That report 

will be delivered in March 2016. 

Issue D: Chemical Processing Plant (CPP; 1963–1974) – Scope of Review: Evaluate if the revised SEC class definition may unintentionally 

exclude workers from the SEC class due to contemporaneous dosimetry requirements. 

D-1 “Observation 1: While the class definition provides the example of 

‘at least one film badge,’ SC&A has assumed that any evidence of 

monitoring during the latter SEC period (3/1/1970–12/31/1974) will 

satisfy the intended criteria.” [i.e., one badge, one area  one 

badge, multiple areas (3/1/1970)  one badge, one area (12/1974)]

Evaluation of the Revised SEC Class 

Definition for the Idaho National 

Laboratory Chemical Processing Plant 

(1963–1974), SCA-SEC-2015-D, 

Revision 0, draft, September 28, 2015. 

Section 2.1. 

SC&A comment: All 6 observations 

related to this issue were 

discussed at the November 11, 

2015, and January 15, 2016, WG 

meetings. Review of the remaining 

18 cases in coordination with 

NIOSH is complete. Issue D was 

the focal point of the March 1, 

2016, WG meeting.

D-2 “Observation 2: SC&A identified a single claim that contained in-vivo 

dosimetry related to CPP, but did not have related external 

dosimetry. It is recommended that this claim be included with the 

claims requiring additional data capture at INL.”

Ibid. Section 2.1. —
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

33 of 48

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.

No. Description References Notes & Additional Comments

D-3 “Observation 3: Clarification is warranted to establish how 

‘temporary’ and/or ‘visitor badges’ are utilized in the 

implementation of the class definition during the latter SEC period 

(3/1/1970–12/31/1974).”

Ibid. Section 2.1. SC&A comment: NIOSH clarified at 

the November 11, 2015, WG 

meeting that temporary and 

visitor badges and location cards 

are adequate if the 250-day 

requirement is met. 

D-4 “Observation 4: Absent additional information to the contrary, 

dosimetry associated with ‘CADRE’ should be considered CPP for the 

purposes of determining SEC eligibility. Similar to the CPP dosimetry 

records, it is important to establish that ‘CADRE’ badging records 

have all been captured from INL.”

Ibid. Section 2.2. 

CADRE Evaluation (Area Code 71) for 

consideration as part of the Idaho 

Chemical Processing Plant Special 

Exposure Cohort. NIOSH. February 25, 

2016.

SC&A comment: NIOSH clarified at 

the November 11, 2015, WG 

meeting that it will reach out to 

site personnel to clarification.

NIOSH releases findings on 

‘CADRE’ issue in February 25, 

2016, memo.

Issue was discussed at March 1, 

2016, WG meeting and consensus 

was reached that ‘CADRE’ refers to 

Emergency Response Center 

personnel who were not likely at 

CPP during the SEC period. Issue 

was closed by WG.

Note: the issue of monitoring 

practices for other emergency 

response personnel that may have 

entered CPP (such as “firemen”) is 

pending NIOSH response.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

34 of 48

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.

No. Description References Notes & Additional Comments

D-5 “Observation 5: NIOSH should consider the additional claims 

identified by SC&A as candidates for upcoming data-capture efforts 

at INL to assure that all monitoring records are complete for these 

workers.” 

Ibid. Section 3.0. SC&A Comment: Supplemental 

dosimetry records were received 

from the site in December 2015. 

SC&A delivered the white paper: 

“Evaluation of Claims with 

Supplemental Dosimetry 

Requests.” This white paper was 

discussed at the January 2015 WG 

teleconference (see Sub Issue DD, 

below, for noted observations). 

D-6 “Observation 6: A review of the ten claimants NIOSH identified as 

requiring follow-up research and data capture at INL indicates a 

thorough search to identify potential workers who were exposed at 

the CPP for which the required dosimetry currently is not available. 

SC&A agrees with NIOSH’s assessment that these claimants warrant 

further investigation.”

Ibid. Section 4.0. See response to Item D-5 and Sub 

Issue DD. 

Sub Issue DD: Chemical Processing Plant (CPP; 1963–1974) – Evaluation of Claims with Supplemental Dosimetry Requests.

DD-1 “Observation 1: Five of the 18 claims contained a listing of a ‘box’ 

and ‘record number’ for the relevant claimant dosimetry records. In 

one of those five claims, it appears that an ‘area exposure report’ 

related to the claimant could not be located. It should be noted that 

NIOSH has undertaken a comparison of monthly Health Physics (HP) 

reports versus the available dosimetry printouts, and NIOSH 

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

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

Evaluation of Claims with Supplemental 

Dosimetry Records, SCA-2016-SEC0074F, Revision 0, draft, January 12, 

2016, Section 2.1.

SC&A Comment: NIOSH noted that 

the particular missing record was 

related to MTR and prior to the 

SEC period, this confirmed SC&A’s 

assertion stated in the white 

paper. On the issue of missing 

records in general, NIOSH 

reaffirmed that they feel they 

have a complete set of CPP 

dosimetry for the purposes of SEC 

implementation. (INL WG 

teleconference, January 15, 2016, 

pp. 87–94)
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

35 of 48

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.

No. Description References Notes & Additional Comments

DD-2 “Observation 2: SC&A identified evidence (specifically an in-vivo 

record) of a claimant entering CPP in 1966 that did not have 

associated external dosimetry for CPP.”

Ibid. Section 2.2. SC&A Comment: NIOSH identified 

a set of visitor badges associated 

with this claimant for MTR and the 

Special Power Excursion Reactor 

Test (SPERT) but no evidence of 

monitoring at CPP. It is NIOSH’s 

position that this in vivo record at 

CPP is likely a typo. (INL WG 

teleconference, January 15, 2016, 

p. 55)

Issue also briefly discussed during 

March 1, 2016, WG meeting; no 

new information was provided. 

DD-3 “Observation 3: Case #3 provides an example where internal 

monitoring indicates CPP during the latter SEC period (1970); 

however, there is no external monitoring at INL after 1960.”

Ibid. Section 2.3. SC&A Comment: NIOSH obtained 

visitor badges at CPP for this 

individual which correspond to the 

internal monitoring result 

identified in Observation 3. (INL 

WG teleconference, January 15, 

2016, pp. 85–86)

March 1, 2016, WG: NIOSH 

identified an INL policy, which was 

not to index some visitor cards 

that reported zero dose in the 

general timeframe of 1968–1974. 

NIOSH has captured all visitor 

cards for CPP during this time and 

is working to index visitor cards for 

the remaining site areas 

(projected to take 6–9 months).
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

36 of 48

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.

No. Description References Notes & Additional Comments

DD-4 “Observation 6: The ‘annual dose summary’ report for Case #6 

indicates that the claimant was monitored from 1963 to 1966; 

however, individual dosimetry reports are not available to ascertain 

the exact work location during this time.”

Ibid. Section 2.6. SC&A Comment: NIOSH indicated 

that they have searched all 

available temporary and film 

badge reports at CPP for this 

individual and did not locate any 

records. However, NIOSH also 

stated they have not searched 

through temporary and/or visitor 

records at other INL areas where 

the Energy Employee may have 

been monitored but not captured 

in the DOE response. (INL WG 

teleconference, January 15, 2016, 

pp. 111–116)

March 1, 2016, WG: This issue was 

not specifically discussed. 

Resolution pending capture and 

indexing of all visitor/temporary 

badge records for INL (projected 

6–9 months). 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

37 of 48

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.

No. Description References Notes & Additional Comments

Issue E1: Fission and Activation Product (FAP) Bioassay Indicator Radionuclides – Scope of Review: Analyze FAP indicator ratios, actinide-toFAP ratios, and special situations/bioassays.

E1-1 “FAP intakes assigned using NIOSH’s recommendations in ORAUTOTIB-0054...based on Sr-90 intake values are generally (but not 

always) equal to, or greater than, those derived from actual 

measured values.”

SC&A’s Evaluation of the NIOSH 

Evaluation Report Proposed Use of 

Fission-Activation Product Bioassay 

Indicator Radionuclides (in Conjunction 

with ORAUT-OTIB-0054 and ORAUTTKBS-0007-5) for Assessment of 

Fission-Activation Product and Actinide 

Intakes at Idaho National Laboratory, 

SCA-SEC-2015-0074-E1, Revision 0, 

draft, October 26, 2015. Executive 

Summary.

SC&A comment: It needs to be 

determined if records of analyses 

of dissolver contents are available, 

preferably for a variety of INL 

reactor fuel elements and also fuel 

elements from offsite reactors.

Data capture in January 2016 

sought relevant information. The 

items recovered for the SRDB may 

provide some insight when 

available. — We still have the 

Seattle and return INL data 

captures coming up later in 2016. 

SC&A tasked at the November 11, 

2015, WG meeting to update the 

Issue E1 report when the relevant 

data are obtained.

March 1, 2016: process of 

capturing relevant data still 

ongoing.

E1-2 “The Cs-137/Sr-90 intakes are not always 1:1 as assumed in ORAUTOTIB-0054...and ORAUT-TKBS-0017-5 ...; frequently, large variations 

in the ratio exist. This brings into question the validity of using an 

indicator radionuclide when deriving FAP and actinide intakes, 

because the assigned intakes/doses are dependent on the indicator 

radionuclide bioassayed at the time. This may be the most important 

result of this study because a Cs-137/Sr-90 value of approximately 

1:1 is one of the cornerstones for use of the ratio method at the 

INL.”

Ibid. SC&A comment: Further INL 

document research is needed to 

evaluate NIOSH’s recommended 

ratio values, especially for 

actinides and Cs-137/Sr-90.

See response to Item E1-1.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

38 of 48

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.

No. Description References Notes & Additional Comments

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

ORAUT-TKBS-0017-5..., Table 5-22 based on Sr-90 intake values, or 

Table 5-23 based on Cs-137 intake values, are sometimes 

significantly less than those derived from actual measured values.”

Ibid. SC&A comment: Resolution is 

contingent on revised Issue E1 

report.

E1-4 “It is difficult to evaluate when ‘special’ (situations where actinides 

were not tied to a fission product in a given ratio) bioassays were 

needed, if they were performed, and if they are indicated as such in 

the bioassay records.”

Ibid. SC&A comment: It needs to be 

determined if special or nonroutine bioassays were associated 

with special exposure events...or, 

if instead, the terms were applied 

to the priority of processing over 

“routine” bioassays.

Future data capture will seek to 

address these concerns.

See response to Item E1-1.

Issue E2: Fission and Activation Product (FAP) Bioassay Worker Records – Scope of Review: Determine, through a semi-random sample of 

claimants, if sufficient workers records containing FAP bioassay (in-vitro and in-vivo) results are available to assign intakes and resulting 

doses from FAP.

E2-1 Observation 1: SC&A believes that coworker models should be 

developed for the period of 1967–1970 for each relevant area under 

consideration.

Evaluation of Internal Monitoring for 

Fission and Activation Products Among 

INR Claimants (1949-1970), SCA-SEC2015-0074-E2, Revision 0, draft, 

October 26, 2015. Executive Summary.

Response to Observations presented in 

“Evaluation of Internal Monitoring for 

Fission and Activation Products among 

INL Claimants (1949-1970),” SCA-SEC2015-0074-E2, Revision 0. NIOSH, 

February 25, 2016.

SC&A comment: Issue E2 

discussed pp. 221–244 of the 

November 11, 2015, WG meeting. 

Tasking from the November 11, 

2015, WG meeting: NIOSH to 

evaluate the need for additional 

coworker analysis.

February 15, 2016: NIOSH releases 

white paper response to coworker 

requirements.

March 1, 2016: Issue E2 was 

briefly discussed at WG meeting. 

NIOSH agrees that further 

coworker models are required for 

the various facilities of INL.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

39 of 48

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.

No. Description References Notes & Additional Comments

E2-2 “Observation 2: Based on SC&A’s review of sampled claimants, it is 

not apparent that the lack of internal monitoring data is indicative of 

a lack of internal exposure potential. Given the uncertainty in 

establishing work areas, activities and ultimately exposure potential 

for claimants (particularly in the early years), it is recommended that 

coworker models be evaluated and developed for workers who were 

unmonitored, but likely should have been monitored during all 

periods for which such exposures are possible.”

Ibid. SC&A comment: See response to 

Item E2-1.

E2-3 “...it appears there are credible situations where it would be 

appropriate and claimant favorable to assign coworker intakes of 

FAPs and actinides to account for unmonitored portions of the 

claimants’ work history. Many of these examples predate the period 

currently identified by NIOSH as requiring coworker evaluations 

(1967–1970).”

— SC&A comment: See response to 

Item E2-1.

Table 3. INL SEC 0219: Items under Investigation by SC&A 

No. Description References Notes & Additional Comments

Item 1: Burial Grounds (1952–1970)

1-1 Evaluation of the adequacy of the contamination control program at 

the burial grounds. Evidence exists that a “strict” contamination 

control program was not in place. The burial grounds may have lacked 

adequate smear counting capabilities.

Pending. Subject of site data captures and 

worker interviews:

– January 25–28, 2016

– February 16, 2016

– February 23–24, 2016

– March 15–16, 2016

1-2 Radioactive waste was not specifically identified/labelled for most 

drums, boxes, and other containers (particularly in the early years). 

This would limit the ability for health physics staff to take proper 

precautions specific to the waste being handled.

Pending. See additional comments for 

Item 1-1.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

40 of 48

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.

No. Description References Notes & Additional Comments

1-3 Waste was received from offsite sources, such as commercial, 

university, Atomic Energy Commission/Energy Research and 

Development Administration and military sources, which may not 

have been adequately identified or characterized.

Pending. See additional comments for 

Item 1-1.

1-4 Concerns over the lack of priority being given radiation protection at 

the Burial Grounds as evidenced by a lack of management support, as 

well as the apparent conflict of interest for health physics staff who 

had the dual role of radiological protection and oversight of the actual 

operation of the burial grounds. 

Pending. See additional comments for 

Item 1-1.

1-5 Questionable characterization of the robust nature of the health 

physics program given evidence of shortcomings involving radiological 

controls and also internal monitoring protocol for burial ground 

workers.

Pending. See additional comments for 

Item 1-1.

Item 2: Chemical Processing Plant (Pre-1963)

2-1 Inadequate internal dosimetry program at CPP to allow for the direct 

assessment of potential intakes of transuranic/actinide contaminants.

Pending. Subject of site data captures and 

worker interviews:

– January 25–28, 2016

– February 16, 2016

– February 23–24, 2016

– March 15–16, 2016

2-2 Inadequate contamination control program to limit “hot areas” to the 

actual process cells (similarities to conditions found at CPP during the 

proposed SEC period 1963–1974).

Pending. See additional comments for 

Item 2-1.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

41 of 48

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.

6.0 STATUS OF ANL-W SITE PROFILE AND SEC ISSUES

Many of the issues identified above for INL also have applicability to ANL-W. However, it 

wasn’t until relatively recently, when NIOSH issued SEC Petition Evaluation Report, SEC 

Petition SEC-00224 (Argonne National Laboratory – West), dated February 18, 2016 (NIOSH 

2016b), that explicit consideration was given to ANL-W by the Advisory Board. The Board 

reviewed the petition and on May 2, 2016, recommended that the following SEC be granted: 

All employees of the Department of Energy, its predecessor agencies, and their 

contractors and subcontractors who worked at the Argonne National LaboratoryWest during the time period from April 10, 1951, through December 31, 1957, for 

a number of work days aggregating at least 250 work days, occurring either 

solely under this employment, or in combination with work days within the 

parameters established for one or more other classes of employees in the Special 

Exposure Cohort. 

The petition was granted based on the Board’s determination that both external and internal 

doses could not be reconstructed with sufficient accuracy for the designated time period. 

To date, SC&A has not issued a review of the ANL-W ER. However, there has been an 

exchange of correspondence that is noteworthy. At the request of the Advisory Board, SC&A 

prepared a work plan for the review of the ER, Up-date-SC&A’s Review of the NIOSH Petition 

Evaluation Report for SEC-00224, ANL-W, dated May 6, 2016. One of the seven action items, 

Item 2, states the following: “SC&A reviewed an early version of the ANL-W site profile, and our 

review is captured in an integrated INL/ANL-W matrix. We need to cross walk the combined [site 

profile] matrix with ANL-W to identify potential commonalities.” This report fulfills that part of 

our work plan. 

Tables 4 and 5 present SC&A’s understanding of all issues that are currently active for INL and 

identify those issues that we believe also apply to ANL-W, along with the action items 

delineated in our May 6, 2016, work plan for ANL-W and those issues that might be SEC issues. 

Table 4. Integrated Matrix for INL and ANL-W June 17, 2016: 

Original Site Profile Review Dated December 30, 2008 

Issue 

No.

Issue Description‡ Applicability 

to INL*

Applicability 

to ANL-W*

1 Reconstruction of near-field exposures from routine 

atmospheric releases. Recommend closing the aspect of 

this issue for exposures beyond 100 m of the elevated 

release point, but remain in progress for workers located 

with 100 m of the release where there could be downwash 

from atmospheric releases and also exposures to ground 

level releases.

Yes Yes

2 Resolved for most episodic releases, but there remain 

concerns with underestimating the releases associated with 

IET 10.

Yes No

3 Closed by Work Group. — —

4 SC&A recommends closing. — —

5 Reiteration of Issues 1 and 2. No need to separately track. — —
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

42 of 48

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.

Issue 

No.

Issue Description‡ Applicability 

to INL*

Applicability 

to ANL-W*

6 SC&A recommends closing. — —

7 Closed by Work Group. — —

8 SC&A recommends closing. — —

9 Recommend closing the generic aspect of this issue dealing 

with OTIB-0017, but there is a need for NIOSH to identify 

specific circumstances when hot particle exposures might 

be an issue, especially for workers with skin cancer.

Yes Yes

10 Closed by Work Group. — —

11 Closed by Work Group. — —

12 Closed by Work Group. — —

13 Closed by Work Group. — —

14 SC&A recommends closing. — —

15 Adequacy of ability to reconstruct doses to SL-1 responders Yes No

16 Need for an external dose coworker model Yes* Yes*

17 SC&A recommends closing. — —

18 SC&A recommends closing. — —

19 Angular dependence Yes Yes

20 SC&A recommends closing. — —

21 SC&A recommends closing. — —

22 Closed by Work Group. — —

23 The issue has to do with hazardous jobs, with an emphasis 

on hot particles. See Issue 9.

Yes Yes

24 Extremity exposures. SC&A would like to review the cases 

of extremity cancers and whether NIOSH had the data 

needed to reconstruct these exposures.

Yes Yes

25 Closed by Work Group. — —

26 SC&A recommends closing. — —

27 SC&A recommends closing. — —

28 Need for adjustment factors for neutron exposures Yes Yes

29 SC&A recommends closing. — —

30 SC&A recommends closing. — —

31 Neutron dosimetry completeness issues. Merge with 

Issue 16.

Yes* Yes*

32 SC&A recommends closing. — —

33 SC&A recommends closing. — —

34 Adequacy of neutron exposure monitoring. Yes* Yes*

35 SC&A recommends closing. — —

36 SC&A recommends closing. — —

37 Closed by Work Group. — —

38 Closed by Work Group. — —

‡ Where the issue has been closed or SC&A recommends closure, no description of the issue is provided. However, 

if SC&A recommends keeping the issue in progress, a brief description of the issue is provided

* An asterisk indicates that the issue may be an SEC issue.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

43 of 48

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.

Table 5. Integrated Matrix for INL and ANL-W June 17, 2016: 

Issues Associated with SEC—00219 and SC&A’s July 6, 2015 Interim Status Report on the 

Review of the ER and associated Special Reports**

Issue 

No.

Issue Description‡ Applicability 

to INL*

Applicability 

to ANL-W*

Issue A TAN — —

A-1 Applicability of ORAUT-OTIB-0054 (OTIB-0054 or ORAUT 

2013) and Tables 5-22 and 5-23 of the site profile internal 

dosimetry technical basis document (TBD) to the 

performance of internal dose reconstruction for facilities that 

handled and stored spent and irradiated fuel;

Yes* Yes*

A-2 Spotty neutron dosimetry data Yes ?

A-3 ANP/IET unique radionuclide mixes in irradiated fuel Yes No

A-4 IET 10 atmospheric releases and associated outdoor 

exposures

Yes No

Issue B CFA unique radionuclide mixes Yes* No

Item C Unique reactors at TRA Yes* Yes*

Item D CPP Yes* No

D-1 Definition of the class Yes* No

D-2 Found CPP worker with bioassay but no film badge Yes* No

D-3 Temporary workers and visitors Yes* No

D-4 CADRE Resolved No

DD-1 18 claimant review Yes* No

DD-2 Found claimant entering CPP with in-vivo record but no film 

badge record

Yes* No

DD-3 A third case with internal monitoring data after 1970 but no 

film badge data after 1960

Yes* No

‡ Where the issue has been closed or SC&A recommends closure, no description of the issue is provided. However, 

if SC&A recommends keeping the issue in progress, a brief description of the issue is provided. 

*An asterisk indicates that the issue may be an SEC issue.

**A more detailed matrix of issues related to SC&A’s review of the evaluation report for SEC-00219 is provided in 

Section 5 above and on the NIOSH website at https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-inlsec219im031316.pdf , dated March 13, 2016. That matrix should be consulted during the issues resolution process.
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

44 of 48

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.

7.0 REFERENCES

ABRWH 2014. Advisory Board on Radiation and Worker Health – Transcript of the Idaho 

National Laboratory Work Group – Hebron, Kentucky. Centers for Disease Control, National 

Institute for Occupational Safety and Health. March 25, 2014. 

ABRWH 2015a. Advisory Board on Radiation and Worker Health – Transcript of the 104th 

Meeting – Richland, Washington. Centers for Disease Control, National Institute for 

Occupational Safety and Health. March 26, 2015. 

ABRWH 2015b. Advisory Board on Radiation and Worker Health – Transcript of the Idaho 

National Laboratory Work Group – Hebron, Kentucky. Centers for Disease Control, National 

Institute for Occupational Safety and Health. November 10, 2015. 

ABRWH 2016. Advisory Board Recommendation on SEC Petition 219 – Letter to the Secretary 

Burwell of the Department of Health and Human Services. Centers for Disease Control, National 

Institute for Occupational Safety and Health. May 2, 2016. 

Behling and Mauro 2005. U.H. Behling and J. Mauro, Critical Review of Source Terms for Select 

Initial Engine Tests Associated with the Aircraft Nuclear Propulsion Program at INEL, SC&A, 

Inc. and SENES Oak Ridge, Inc., under Centers for Disease Control and Prevention Contract No. 

200-2002-00367. July 2005. [SRDB Ref. ID 103215] 

CDC 2002. Identification and Prioritization of Radionuclide Releases from the Idaho National 

Engineering and Environmental Laboratory, RAC Report No. 3-CDCTask Order 5-2000-

FINAL, U.S. Centers for Disease Control and Prevention, Department of Health and Human 

Services, October 8, 2002. [SRDB Ref ID: 1141] 

DCAS 2010. Selected Geometric Exposure Scenario Considerations for External Dose 

Reconstruction at Uranium Facilities, DCAS-TIB-0013, Revision 01, Division of Compensation 

Analysis and Support, Cincinnati, Ohio. November 23, 2010. 

DCAS 2011. Technical Information Bulletin: Best Estimate External Dose Reconstruction for 

Glovebox Workers, Revision 4, DCAS-TIB-0010, Division of Compensation Analysis and 

Support. November 28, 2011. [SRDB Ref. ID 104815]

DOE 1991a. Idaho National Engineering Laboratory Historical Dose Evaluation, 

DOE/ID-12119, Volume 1, Idaho Operations Office, Idaho National Engineering Laboratory, 

Idaho Falls, Idaho. August 1991. [SRDB Ref. ID 1107]

DOE 1991b. Idaho National Engineering Laboratory Historical Dose Evaluation, 

DOE/ID-12119, Volume 2, Idaho Operations Office, Idaho National Engineering Laboratory, 

Idaho Falls, Idaho. August 1991. [SRDB Ref. ID 1109]

DOE 1991c. Idaho National Engineering Laboratory Historical Dose Evaluation Quality 

Assurance File – Summary of Dispersion Factors for IET #4, #6, #12, #13, #22, and #24 Tests, 

DOE/ID-12119-QAF-090, Idaho Operations Office, Idaho National Engineering Laboratory, 

Idaho Falls, Idaho. May 1991. [SRDB Ref. ID 87576, pp. 12–39] 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

45 of 48

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.

DOE 1991d. Idaho National Engineering Laboratory Historical Dose Evaluation Quality 

Assurance File –IET #10 Source Term Characterization, DOE/ID-12119-QAF-026, Idaho 

Operations Office, Idaho National Engineering Laboratory, Idaho Falls, Idaho. March 1991. 

[SRDB Ref. ID 88731] 

Foster et al. 1958. D.C. Foster, S.W. Gabriel, J.W. Highbert, and N.K. Sowards, Power Testing 

Results from D 101 D2 Core (IET # 10), XDCL-58-7-715. 1958. [SRDB Ref. ID 83589] 

Hine and Brownell 1956. G.J. Hine and G. L. Brownell, Radiation Dosimetry, Academic Press, 

Inc., New York, New York. 1956. 

NIOSH 2007. External Dose Reconstruction Implementation Guideline, OCAS-IG-001, 

Revision 3, National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio. November 21, 2007. [SRDB Ref. ID 38864] 

NIOSH 2013. NIOSH Investigation into the Issues Raised in Comment 2 from SCA-TR-TASK1-

005, NIOSH Draft White Paper, Revision 0, Brian Gleckler, National Institute for Occupational 

Safety and Health, Cincinnati, Ohio. September 3, 2013. 

NIOSH 2014a. Investigation of “Hot Particles” and the Health Physics Programs at the Idaho 

National Laboratory (INL), NIOSH Draft White Paper, Revision 0, Jodi Jenkins, National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. March 18, 2014. 

NIOSH 2014c. Issue Resolution Matrix for Findings and Key Observations, National Institute 

for Occupational Safety and Health, Division of Compensation Analysis and Support, Cincinnati, 

Ohio. March 20, 2014. 

NIOSH 2014d. NIOSH Investigation into INL Site Profile Review – Issue 24, NIOSH Draft 

White Paper, Revision 0, Jodi Jenkins, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. March 6, 2014. 

NIOSH 2014e. NIOSH Investigation into the Issues Raised in Comment 1 from SCA-TR-TASK1-

005, NIOSH Draft White Paper, Revision 0, Brian Gleckler, National Institute for Occupational 

Safety and Health, Cincinnati, Ohio. March 5, 2014. 

NIOSH 2014f. NIOSH Investigation into the Issues Raised in Comment 19 from SCA-TRTASK1-005, NIOSH Draft White Paper, Revision 0, Brian Gleckler, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. March 11, 2014. 

NIOSH 2014g. NIOSH Investigation into the Issues Raised in Comment 34 from SCA-TRTASK1-005, Revision 0, Brian Gleckler, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. March 11, 2014. 

NIOSH 2015a. SEC Petition Evaluation Report, Petition SEC-00219 (Idaho National 

Laboratory), Revision 0, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. March 12, 2015. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

46 of 48

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.

NIOSH 2015b. SEC Petition Evaluation Report, Petition SEC-00219 (Idaho National 

Laboratory), Revision 01, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. July 21, 2015. 

NIOSH 2016a. CADRE Evaluation (Area Code 71) for Consideration as Part of the Idaho 

Chemical Processing Plant Special Exposure Cohort, Timothy D. Taulbee, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. February 25, 2016. 

NIOSH 2016b. SEC Petition Evaluation Report, Petition SEC-00224 (Argonne National 

Laboratory – West), Revision 0, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. February 18, 2016. 

ORAUT 2004. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational External Dosimetry, ORAUT-TKBS-0007-

6, Revision 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 6, 2004. 

[SRDB Ref. ID 19521] 

ORAUT 2005. Interpretation of Dosimetry Data for Assignment of Shallow Dose, ORAUTOTIB-0017, Revision 1, Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 11, 

2005. 

ORAUT 2006. A Standard Complex-Wide Methodology for Overestimating External Doses 

Measured with Film Badge Dosimeters, ORAUT-OTIB-0010, Revision 01, Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. June 5, 2006. 

ORAUT 2010. Technical Basis Document for the Idaho National Laboratory and Argonne 

National Laboratory West – Occupational Internal Dose, ORAUT-TKBS-0007-5, Revision 03, 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 2, 2010. [SRDB Ref. 

ID 79571] 

ORAUT 2011. Technical Basis Document for the Idaho National Laboratory and Argonne 

National Laboratory-West – Occupational External Dosimetry, ORAUT-TKBS-0007-6, 

Revision 03, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 19, 2011. 

[SRDB Ref. ID 94104] 

ORAUT 2014. Internal Dose Reconstruction, ORAUT-OTIB-0060, Revision 01, Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. September 8, 2014. 

ORAUT 2015. Fission and Activation Product Assignment for Internal Dose-Related Gross Beta 

and Gross Gamma Analyses, ORAUT-OTIB-0054, Revision 3, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. February 6, 2015. 

SC&A 2005, Third Supplemental Review of the Mallinckrodt Site Profile, Revision 1, Third 

Supplement to SCA-TR-TASK1-0002, McLean, Virginia. August 16, 2005. [SRDB Ref. 

ID 15451] 

SC&A 2006. Review of the NIOSH Site Profile for the Idaho National Laboratory, Idaho, SCATR-TASK1-005, McLean, Virginia. January 25, 2006. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

47 of 48

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.

SC&A 2008. Idaho National Laboratory (INL) Site Profile Review Update, SCA-TR-TASK1-

005, Supplement 1, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. 

December 10, 2008. 

SC&A 2015a. Interim Summary Report on the Evaluation of NIOSH’s Idaho National 

Laboratory SEC-00219 Petition Evaluation Report, SC&A, Inc., Vienna, Virginia, and Saliant, 

Inc., Jefferson, Maryland. July 6, 2015 

SC&A 2015b. Review of NIOSH Strategy for Reconstructing Internal Doses to Workers at Test 

Area North, SCA-TR-2015-SEC0074A, Revision 0, SC&A, Inc., Vienna, Virginia and Saliant, 

Inc., Jefferson, Maryland. September 28, 2015. 

SC&A 2015c. Evaluation of Available Survey Data for the Central Facilities Area at Idaho 

National Laboratory, SCA-TR-2015-SEC0074B, Revision 0, SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc., Jefferson, Maryland. September 28, 2015. 

SC&A 2015d. NIOSH SEC-00219 Test Reactor Area Modeling, SCA-TR-2015-SEC0074C, 

Revision 0, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. September 28, 

2015. 

SC&A 2015e. Evaluation of the Revised SEC Class Definition for the Idaho National Laboratory 

Chemical Processing Plant (1963–1974), SCA-TR-2015-SEC0074D, Revision 0, SC&A, Inc., 

Vienna, Virginia, and Saliant, ,Inc., Jefferson, Maryland. September 28, 2015. 

SC&A 2015f. SC&A’s Evaluation of the NIOSH Evaluation Report Proposed Use of FissionActivation Product Bioassay Indicator Radionuclides (in Conjunction with ORAUT-OTIB-0054 

and ORAUT-TKBS-0007-5) for Assessment of Fission-Activation Product and Actinide Intakes at 

Idaho National Laboratory, SCA-SEC-2015-0074E1, Revision 0, SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. October 26, 2015. 

SC&A 2015g. Evaluation of Internal Monitoring for Fission and Activation Products among 

INL Claimants (1949–1970), SCA-SEC-2015-0074E2, Revision 0, SC&A, Inc., Vienna, 

Virginia, and Saliant, Inc., Jefferson, Maryland. October 26, 2015. 

SC&A 2015h. SC&A Evaluation of Idaho Chemical Processing Plant Class Definition Requiring 

Evidence of External Dosimetry (1963–1974), Revision 0, SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc. Jefferson, Maryland. June 29, 2015. 

SC&A 2016a. INL SEC-00219: Compilation of SC&A Review Issues, Comments, and 

Recommendations, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. 

February 23, 2016. 

SC&A 2016b. Evaluation of Claims with Supplemental Dosimetry Requests, SCA-2016-SEC0074F, Revision 0, SC&A, Inc., Vienna, Virginia, and Saliant, Inc. Jefferson, Maryland. 

January 12, 2016. 
Effective Date:

07/15/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SEC011

Page No.

48 of 48

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.

SC&A 2016c. INL SEC-00219 Reactor Prioritization for Evaluation of ORAUT-OTIB-0054 

Applicability, SCA-TR-2016-SEC002, Revision 0, SC&A, Inc., Vienna, Virginia, and Saliant, 

Inc., Jefferson, Maryland. March 2, 2016. 

SC&A 2016d. INL SEC-00219 Reactor Prioritization for Evaluation of ORAUT-OTIB-0054 

Applicability, SCA-TR-2016-SEC002, Revision 1, SC&A, Inc., Vienna, Virginia, and Saliant, 

Inc., Jefferson, Maryland. June 10, 2016. 

SC&A 2016e. INL SEC-00219: Compilation of SC&A Review Issues, Comments, and 

Recommendations, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. March 

13, 2016. 

SC&A 2016f. Evaluation of New Claims Filed Since the Summer of 2015 for Idaho National 

Laboratory, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. May 26, 2016.