Draft 

SC&A’S ISSUES MATRIX FOR THE BROOKHAVEN NATIONAL LABORATORY 

SITE PROFILE TECHNICAL BASIS DOCUMENT 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2012 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
Brookhaven National Laboratory Site Profile Issues Matrix 

This matrix contains a list of the issues (formally titled Findings in the site profile review) that 

SC&A identified in Rev. 00 of the Brookhaven National Laboratory (BNL) technical basis 

document (TBD) ORAUT-TKBS-0048 (ORAUT 2006), with some status updating against the 

recent Rev. 01 edition of ORAUT-TKBS-0048 (ORAUT 2010). As of January 2012, SC&A has 

not performed a complete re-evaluation of the site profile issues in view of the recent Rev. 01 

edition, or the two NIOSH Special Exposure Cohort (SEC) evaluation reports (NIOSH 2009 and 

NIOSH 2012), awaiting Work Group direction. Two SECs presently exist for BNL; one for the 

period January 1, 1947, through December 31, 1979, and one for the period January 1, 1980, 

through December 31, 1993. 

 

This site profile issues matrix is based on preliminary assessments of the following: 

 The BNL TBD ORAUT-TKBS-0048, Rev. 00, August 30, 2006 (ORAUT 2006) 

 SC&A’s September 2009 review of the BNL site profile ORAUT-TKBS-0048, Rev. 00, 

August 30, 2006 (SC&A 2009) 

 The NIOSH SEC-00113 Evaluation Report dated September 29, 2009 (NIOSH 2009) 

 The BNL TBD ORAUT-TKBS-0048, Rev. 01, April 26, 2010 (ORAUT 2010) 

 The NIOSH SEC-00196 Evaluation Report dated January 5, 2012 (NIOSH 2012) 

Draft BNL Site Profile Issues Matrix 2 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

Finding 1: Bioassay Monitoring Not Adequately Established 

ORAUT-TKBS-0048 (ORAUT 2006) does not provide sufficient information to determine 

which workers were monitored for what radionuclides and what criteria were used to select 

workers for special, routine, and spot bioassay monitoring. To perform an adequate dose 

reconstruction, the dose reconstructor needs to know who, when, and why workers were 

bioassayed at a given DOE site. This information allows the dose reconstructor to determine if 

the worker should have been monitored, and prompts the dose reconstructor to search for such 

records, if applicable (especially important because of the lack of a centralized record system at 

BNL). Although bioassays for some radionuclides were conducted for some workers at BNL 

throughout the laboratory’s operating history, sufficient documentation of written procedures 

and requirements for bioassays is not apparent before the 1990s; this leaves 40 years of 

uncertainty concerning bioassay requirements. 

SC&A’s February 2012 update: The SECs negate this concern through 1993. SC&A needs 

to determine if this issue is still applicable after 1993. 

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 3 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

Draft BNL Site Profile Issues Matrix 4 SC&A – Updated February 13, 2012 

 This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 

NOTICE:

Finding 2: Records of Bioassay Monitoring Not Centralized or Knowingly Complete

The site profile does not address the issue of the completeness and accessibility of the bioassay 

records. There were numerous bioassay data recording systems and filing methods at BNL. 

Many of these earlier records are still located in various departments, making it difficult (as 

confirmed by current BNL health physics personnel) for BNL to properly and completely 

respond to NIOSH requests for bioassay records to be used for dose reconstruction. It is not 

currently known by BNL health physics personnel if all the hardcopy records have been 

located, are legible, and are accessible for dose reconstruction. As various departments were 

formed and supplanted, and as department heads came and left BNL, the hardcopy records may 

have survived, or they may have been destroyed or removed from the site. There is presently 

no method available to determine if all the records for a given employee are available for dose 

reconstruction purposes, particularly before the records were centrally stored in electronic 

databases. 

SC&A’s February 2012 update: The SECs negate this concern through 1993. SC&A needs 

to determine if this issue is still applicable after 1993.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 3: Minimum Detectable Activity and Uncertainty Values Not Sufficiently Defined

Minimum detectable activity (MDA) is mentioned several times in Section 5 of the site profile 

(ORAUT 2006), and a list of whole-body counter (WBC) MDA values is provided in Table 5-3, 

pp. 78–79) for the years 1999 through 2005. Additionally, urinalysis MDA values for some of 

the common radioisotopes found at BNL are listed in Table 5-3, pg. 80), mainly for 1999–2006. 

Therefore, a reasonable amount of MDA information for common radioisotopes is provided for 

1999–2006. However, what is lacking is a comprehensive listing of urinalysis and WBC MDA 

values for the 1940s–1990s, such as is found in other NIOSH site profiles. Additionally, 

uncertainty values are not provided, and are apparently not available, for most of the bioassay 

reporting period from the 1950s–1990s. 

SC&A’s February 2012 update: The SECs negate this concern through 1993. However, this 

issue is still pertinent for the period 1994–1998 for many of the radioisotopes.

NIOSH Response: 

SC&A Reply: 

Work Group Meeting: 

Board Action: 

Draft BNL Site Profile Issues Matrix 5 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

Finding 4: Radionuclide Characteristics Not Sufficiently Known

Unfortunately, as stated in Section 5.10 of the site profile (ORAUT 2006), specific solubility

data, particle size, and activity fractions are not known, or are not available, for most facilities 

at BNL. Table 5-5 lists a few of the activity fractions, presumed to have come from stack 

emission data. However, stack emissions are not always a good indicator of the types of 

radioisotopes present, or their concentrations, in the worker’s breathing zone (this also applies 

to Table 2-2). Interviews with BNL workers indicate that Tables 2-2 and 2-3 do not correctly 

reflect the historic radioisotopes present at some of the BNL facilities. Without appropriate 

characterization of workplace exposures, the adequacy and completeness of the internal and 

external monitoring programs come into question and may result in a less than favorable organ 

dose reconstruction. In addition, workplace specific monitoring data and/or source term data

do not appear to be available. 

SC&A’s February 2012 update: The SECs negate this concern through 1993. However, this 

issue is still pertinent after 1993.

NIOSH Response: 

SC&A Reply: 

Work Group Action: 

Board Action: 

Draft BNL Site Profile Issues Matrix 6 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 5: No Internal Coworker Dose Database Available

The site profile (ORAUT 2006) does not address internal coworker dose data. In view of the 

issues with the lack of a coordinated, consistent bioassay program and the problems with the 

availability of historic bioassay records, it would be advantageous to have a viable coworker 

database to use to assign unmonitored dose. Unfortunately, the lack of a routine and 

comprehensive bioassay program before the 1990s may make it difficult to create an adequate 

coworker internal dose table for the dose reconstructor to bridge monitoring or recordkeeping 

gaps for sporadically monitored workers, monitored workers whose complete records are not 

available, and for unmonitored workers who should have been monitored. 

SC&A’s February 2012 update: The SECs negate this concern through 1993. However, this 

issue is still pertinent after 1993.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 7 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 6: NTA Threshold Response Not Sufficiently Investigated

The threshold energy of NTA film and the amount of dose not registered due to this limitation 

is important in neutron dosimetry. NTA film decreases in response starting at neutron energies 

below 1 MeV, and is almost completely insensitive to neutrons below 0.5 MeV; therefore, 

radiation fields containing an appreciable percentage of the total dose equivalent due to 

neutrons below 1 MeV must be evaluated carefully, with attention given to the missed dose 

resulting from this threshold affect. The site profile does not specifically address the subject of 

the NTA film threshold. The site profile should address this issue and make clear and 

technically sound recommendations to compensate for the incomplete neutron doses as 

recorded by NTA film and contained in the dose of record. 

SC&A’s February 2012 update: SC&A needs to determine if the revised TBD provides 

additional information that could be applied to this issue.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 8 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 7: NTA Track Fading Not Covered in the Site Profile (ORAUT 2006)

The magnitude of the proton recoil tracks in NTA film resulting from neutron interactions 

depends on the energy of the interacting neutron. Lower-energy neutrons cause less dense 

proton recoil tracks; these tracks fade more rapidly with time than heavier tracks caused by 

more energetic recoil protons resulting from energetic neutrons (i.e., 0.5–1.0 MeV neutrons in 

the workplace versus 4 MeV neutrons from a calibration source). The site profile did not 

directly address NTA film track fading, provide evidence that it was not a problem at BNL, or 

describe any procedure necessary to compensate for it. 

SC&A’s February 2012 update: SC&A needs to determine if the revised TBD provides 

additional information that could be applied to this issue.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 9 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 8: NTA/TLD/Lexan/CR-39 Problems

The problems associated with the NTA film threshold and track fading initiated a search for 

other neutron dosimeters; among those tested and selected for use at BNL were the TLD, CR39, and Lexan neutron dosimeters. However, these neutron dosimeters were not without their 

own shortcomings. There were issues with NTA film, CR-39, and Lexan neutron dose 

readings, and even the gamma-muon readings. None of the detectors appeared to establish a 

long-term “gold standard” to which results could be compared. During the 1980s and 1990s, a 

number of issues were ongoing between BNL and their dosimetry vendor, Landauer. The BNL 

site profile does not cite these dosimetry problems, if they were solved, or make any 

recommendations on the use of the neutron dose records, given the concerns and uncertainties 

associated with these issues. 

SC&A’s February 2012 update: SC&A needs to determine if the revised TBD provides 

additional information that could be applied to this issue.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 10 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 9: Potential Exposures at Accelerators Not Sufficiently Covered

High-energy accelerators, such as the many diverse types operated at BNL during its 60-year 

history, present the standard health physics problems, as well as emergent new challenges, 

typically unique to each type of new accelerator. There are many situations at high-energy 

accelerators that have the potential for unconventional exposures leading to unrecorded or 

under-recorded doses. The present BNL site profile does not address the unique dosimetry 

problems associated with high-energy accelerators, if the dosimetry systems were adequate 

during the startup periods, or if the dosimetry systems were sufficiently encompassing to 

accommodate operational changes. Nor does the site profile discuss adjustment factors for 

neutron doses, and if they are needed to compensate for the limitations of the dosimetry systems 

used as a function of time at different accelerator facilities. 

SC&A’s February 2012 update: SC&A needs to determine if the revised TBD provides 

additional information that could be applied to this issue.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 11 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 10: External Coworker Dose Data Not Addressed

 Section 6 of the site profile (ORAUT 2006) does not address or provide any coworker data for 

use in assigning doses to workers who should have been monitored, but were not. Coworker 

data are needed in cases where the worker had the potential to receive greater than 

environmental doses, but by the criteria at the time, the individual was not considered a 

radiation worker and, therefore, was not badged, or the monitoring results cannot be located. 

SC&A’s February 2012 update: Although some of the information has changed in the 

revised TBD, there appears to be no significant changes concerning this issue; therefore, this 

issue is still pertinent.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 12 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 11: Incidents and Unanticipated Events Not Addressed

The site profile (ORAUT 2006) does not sufficiently address incidents or unusual events that 

could affect external dose reconstruction. Some examples of incidents were found in the BNL 

documents; however, the site profile itself did not address such incidents for their implications 

to dose reconstruction, and whether the doses of record were correct under these exposure 

conditions. Likewise, specific environmental-related incidents and releases and their impact on 

onsite occupational doses to unmonitored workers are not addressed. 

SC&A’s February 2012 update: Although some of the information has changed in the 

revised TBD, there appears to be no significant changes concerning this issue; therefore, this 

issue is still pertinent.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 13 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

 

Finding 12: Potential Environment Exposures from Igloo Area Not Addressed

Nothing is mentioned in Section 4 of the site profile (ORAUT 2006) concerning the Igloo 

storage area in the Hazardous Waste Management Facility and its impact on localized 

environmental doses. Averaged site parameter yearly readings, and other readings inside the 

BNL site, may not reflect the true environmental doses received by unmonitored workers who 

spent any significant time in the areas outside the Igloo or other hazardous waste facility areas. 

SC&A’s February 2012 update: Although some of the information has changed in the 

revised TBD, there appears to be no significant changes concerning this issue; therefore, this 

issue is still pertinent.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 14 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

Finding 13: The Site Profile has Inadequately Characterized the Number and Types of 

X-rays Received by BNL Employees in Early Years

 The site profile (pg. 50) (ORAUT 2006) states that BNL had machines capable of 

photofluoroscopic/ fluoroscopic exams in 1951 and 1960, but on page 50, it is concluded that 

only the diagnostic unit was used for routine exams, and on page 52, it is stated that it seems 

unlikely that the greater dose units were used for routine exams. These potential exposures 

were not further addressed in the site profile. It references Brodsky 1964 as one of its reasons 

to conclude that only the diagnostic unit was used routinely for examinations. However, 

Sunderman (1947) summarized the health program used for BNL employees in September 

1947. Sunderman recommended that employees of BNL be observed medically (1) upon hire at 

BNL, (2) routinely for employees requiring health maintenance, (3) when employees become 

sick or injured, and (4) when employees terminated. Candidates for employment were to 

receive “fluororoentgenograms of the chest, AP and LAT roentgenograms of the spine, and 

roentgenogram of one forearm.” During Health Maintenance exams of employees, an annual 

fluororoentgenogram of the chest was completed. 

SC&A’s February 2012 update: There have been some changes in this area in the revised 

TBD (ORAUT 2010); therefore, SC&A needs to determine if the revised TBD provides 

additional information that could be applied to this issue.

NIOSH Response: 

SC&A Reply: 

Work Group Actions: 

Board Action: 

Draft BNL Site Profile Issues Matrix 15 SC&A – Updated February 13, 2012 

NOTICE: This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 
Brookhaven National Laboratory Site Profile Issues Matrix 

Draft BNL Site Profile Issues Matrix 16 SC&A – Updated February 13, 2012 

 This February 13, 2012, updated report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Future versions of this report will require additional review prior to public release. 

NOTICE:

References:

Brodsky, A., 1964. Minutes of a meeting (no title) held on June 29, 1964 between A. Brodsky of 

BNL and Paul Klevin of the Atomic Energy Commission. Brookhaven National Laboratory, 

Upton, New York. Ref ID 17344. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00113, Rev. 0. National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. September 29, 2009. 

NIOSH 2012. SEC Petition Evaluation Report, Petition SEC-00196, Rev. 0. National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. January 5, 2012. 

ORAUT 2006. Technical Basis Document for the Brookhaven National Laboratory, ORAUTTKBS-0048, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 30, 

2006. 

ORAUT 2010. Technical Basis Document for the Brookhaven National Laboratory, ORAUTTKBS-0048, Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 26, 

2010. 

SC&A 2009. Review of the NIOSH Site Profile for the Brookhaven National Laboratory,

ORAUT-TKBS-0048, Rev. 00, 2006. SCA-TR-TASK1-0001. SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. September 2009. 

Sunderman, F.W., M.D., 1947. Health Program for Employees of the Brookhaven National 

Laboratory, Brookhaven National Laboratory, Upton, New York. August 27, 1947.