Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE NIOSH SITE PROFILE FOR 

BROOKHAVEN NATIONAL LABORATORY 

Contract No. 200-2009-28555 

Task Order No. 1 

SCA-TR-SP2009-0001 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

September 2009 

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.

 
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Document No. 

SCA-TR-SP2009-0001 

S. Cohen & Associates: 

Effective Date: 

Draft – September 9, 2009 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 – DRAFT 

REVIEW OF THE NIOSH SITE PROFILE 

FOR BROOKHAVEN NATIONAL 

LABORATORY 

Page 1 of 59 

Task Manager: 

_______________________ Date: ___________ 

Joseph Fitzgerald 

Project Manager: 

_______________________ Date: ___________ 

John Mauro 

Supersedes: 

N/A 
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TABLE OF CONTENTS 

Acronyms and Abbreviations ..........................................................................................................4 

1.0 Executive Summary.............................................................................................................7 

1.1 Summary of Primary Findings.................................................................................9 

1.2 Opportunities for Improvement .............................................................................13 

2.0 Scope and Introduction ......................................................................................................14 

2.1 Review Scope.........................................................................................................14 

2.2 Assessment Criteria and Methods..........................................................................15 

2.2.1 Objective 1: Completeness of Data Sources.............................................16 

2.2.2 Objective 2: Technical Accuracy..............................................................16 

2.2.3 Objective 3: Adequacy of Data.................................................................16 

2.2.4 Objective 4: Consistency among Site Profiles..........................................16 

2.2.5 Objective 5: Regulatory Compliance........................................................16 

2.3 Dose Reconstruction under EEOICPA..................................................................17 

2.4 Report Organization...............................................................................................18 

3.0 Vertical Issues....................................................................................................................20 

3.1 Secondary Findings................................................................................................46 

3.1.1 Factual or Editorial Observations..............................................................49 

4.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................51 

4.1 Satisfying the Five Objectives...............................................................................51 

4.1.1 Objective 1: Completeness of Data Sources.............................................51 

4.1.2 Objective 2: Technical Accuracy..............................................................51 

4.1.3 Objective 3: Adequacy of Data.................................................................52 

4.1.4 Objective 4: Consistency among Site Profiles..........................................53 

4.1.5 Objective 5: Regulatory Compliance........................................................53 

5.0 References..........................................................................................................................54 

Attachment: Summary of Site Expert Interviews.........................................................................59 
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ACRONYMS AND ABBREVIATIONS 

Advisory Board Advisory Board on Radiation and Worker Health 

or ABRWH 

 

AF Absorption Factor 

AGS Alternating Gradient Accelerator 

AP anteroposterior

BGRR Brookhaven Graphite Research Reactor 

BLIP Brookhaven Linac Isotope Producer 

BMRR Brookhaven Medical Research Reactor 

BNL Brookhaven National Laboratory 

CBA Colliding Beam Accelerator 

CFR Code of Federal Regulations 

CR-39 Columbia Resin, type 39

D&D Decontamination and Decommissioning 

DOE Department of Energy 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

FN Fast neutron 

GeV Giga (thousand million) electron volts 

HFBR High Flux Beam Reactor 

HHS Health and Human Services 

HP Health Physics 

HPRS Health Physics Record System 

ICRP International Commission on Radiological Protection 

IR Infrared 

keV kilo electron volt; 1,000 electron volts 

LAT lateral 

LET Linear energy transfer 

LFMR Liquid Fuel Metal Reactor 

LINAC Linear Accelerator 

LLD Lower Limit of Detection 

LOD Limit of Detection 

μg Microgram 
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MDA Minimum Detectable Activity 

MDL Minimum Detectable Level

MeV Million electron volts 

MFP Mixed fission products 

mR milliroentgen 

mrem Millirem 

NIOSH National Institute for Occupational Safety and Health 

NP Non-penetrating 

NSLS National Synchrotron Light Source 

NTA Eastman Kodak Nuclear Track Film Type A 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities 

ORAUT Oak Ridge Associated Universities Team 

OTIB ORAU Technical Information Bulletin 

P Photon 

PA posteroanterior

PFG Photofluorography 

pCi picocurie 

POC Probability of Causation 

PM Personnel monitoring 

QA Quality Assurance 

QF Quality Factor 

R Roentgen 

RBE Relative Biological Effective 

RH Relative humidity 

RHIC Relativistic Heavy Ion Collider 

R&D Research and Development 

rem Roentgen equivalent man 

SC&A S. Cohen and Associates 

S&EP Safety and Environmental Protection 

SEB Slow Extracted Beam 

SRDB Site Research Database 

TBD Technical Basis Document 
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TIB/OTIB NIOSH Technical Information Bulletin 

TLD Thermoluminescent Dosimeter 

TP Tetra Protons 

UV Ultraviolet 

WB Whole body 

WBC Whole-body counting/counter 
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1.0 EXECUTIVE SUMMARY 

This draft report presents the S. Cohen and Associates (SC&A, Inc.) evaluation of the National 

Institute for Occupational Safety and Health (NIOSH) Summary Site Profile document for the 

Brookhaven National Laboratory (BNL), ORAUT-TKBS-0048 (ORAUT 2006). This review 

was conducted during the period February through August 2009, in support of the Advisory 

Board on Radiation and Worker Health (Advisory Board) in the latter’s statutory responsibility 

under the Energy Employees Occupational Illness Compensation Program Act of 2000 

(EEOICPA) to conduct such reviews and advise the Secretary of Health and Human Services 

(HHS) on the “completeness and adequacy” of the EEOICPA program. It was conducted in 

accordance with the Board’s “Data Access and Interview Procedures” (ABRWH-PROC-010), as 

well as Board-approved SC&A procedures for the conduct of site profile reviews. 

The BNL is a multi-program national laboratory operated by Brookhaven Science Associates for 

the U.S. Department of Energy (DOE). The laboratory was established in 1947 on Long Island 

in Upton, New York, and has supported a diverse scope of radiological facilities over its long 

history, including research reactors, high-energy accelerators, medical isotope facilities, medical 

research facilities, and waste management operations. Early accelerator facilities included the 

3 GeV Cosmotron (1953–1966) and 30 GeV Alternate Gradient Synchrotron (AGS, 1960–

present), followed by the Tandem Van De Graaff, 60-inch Cyclotron, and Vertical Accelerator, 

which began operations in the 1960s. The Brookhaven Linac Isotope Producer (BLIP) became 

operational in 1973, followed by the National Synchrotron Light Source (NSLS) in 1982. 

Brookhaven’s newest accelerator facility is the Relativistic Heavy ion Collider (RHIC), which 

was completed in 1999. The Brookhaven Graphite Research Reactor (BGRR) (1950–1969) and 

High Flux Beam Reactor (HFBR) (1965–1999) were major sources of high-energy neutrons for 

research in the fields of medicine, biology, chemistry, physics, and nuclear engineering. Medical 

research and nuclear medicine began at BNL in 1950, with the Medical Research Center opening 

in 1958, supported by the operation of the Brookhaven Medical Research Reactor (BMRR) 

(1959–2000). 

A site visit was conducted from May 18–21, 2009, encompassing a comprehensive document 

review and unclassified site expert interviews. Interviews were conducted with 26 former and 

current BNL workers, including personnel from health physics (field and programmatic), 

dosimetry, medical, accelerator operations, reactor operations, support workers (i.e., maintenance 

and crafts), and research and development personnel. The purpose of these interviews was to 

hear first-hand accounts of past radiological control and personnel monitoring practices, and to 

better understand how operations and safety programs were implemented through time. 

A comprehensive review was conducted of documents that were considered relevant, including 

the following: 

• Select documents that were referenced in the BNL Summary Site Profile 

• Documents contained in the NIOSH Site Research Query Database 

• Documents obtained during a site visit to BNL on May 18–21, 2009. 

 
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The review found that the Summary Site Profile document for BNL (ORAUT 2006) does not 

provide adequate and sufficient information to guide dose reconstruction for a number of critical 

sources of historic internal and external exposure at the laboratory. 

 

For internal dose assessment, the site profile fails to address the adequacy and completeness of 

BNL bioassay data to support dose reconstruction. Uniform and comprehensive historic 

bioassay policies have not been cited nor located for BNL. With the exception of operators at 

the BGRR, bioassay monitoring for isotopes other than tritium at BNL appears to have been 

more “event driven,” rather than conducted on a routine preventive basis. A preliminary review 

of BNL bioassay records does not indicate that consistent long-term routine bioassay monitoring 

policies were in place. From a preliminary review of available BNL records and interviews with 

BNL health physics personnel, there is sufficient reason to question the completeness, accuracy, 

and accessibility of bioassay records for BNL from the late 1940s through the mid-1980s, or 

perhaps into the mid-1990s, when the centralized electronic Health Physics Records System 

(HPRS) became operational. 

The site profile does not specifically address the subject of NTA film threshold. NTA film

decreases in response starting at neutron energies below 1 MeV, and is almost completely 

insensitive to neutrons below 0.5 MeV (ORAUT 2005a, pg. 27); therefore, radiation fields 

containing an appreciable percentage of the total dose equivalent due to neutron exposures below 

1 MeV must be evaluated carefully, with attention given to the dose missed resulting from this 

threshold affect. This is particularly important, as SC&A found that four out of five final dose 

reconstruction reports for BNL claimants, completed after the site profile was issued, did not 

include the neutron adjustment factors of 1.5 or 1.35 for low-energy neutrons. 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. 

 

Similarly, 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. The 

problems associated with the NTA film threshold and track fading motivated a search by BNL 

(for example, Distenfeld and Klemish 1972 and Phillips 1974), as it did at other laboratories, for 

alternate neutron dosimeters; among those tested and selected for use were the 

thermoluminescent dosimeter (TLD), CR-39, 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 gamma-muon readings. During the 1980s 

and 1990s, a number of issues were ongoing between BNL and their dosimetry vendor, 

Landauer, pertaining to inconsistent and unsupportable results. The BNL site profile did not 

mention these dosimetry problems, if they were solved, or make any recommendation on the use 

of the neutron dose records concerning these issues. 

The present site profile document does not address key dosimetry problems associated with highenergy accelerators, the adequacy of dosimetry systems during accelerator startup periods, or if 

the dosimetry systems were sufficiently encompassing to accommodate the numerous 

operational changes that took place as accelerators were redesigned and modified. It does not 

discuss adjustment factors for neutron doses and if adjustments are needed to compensate for the 
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limitations of the dosimetry systems used as a function of time at different accelerator facilities 

(as illustrated in a discussion in this report concerning problems with NTA/TLD/Lexan/CR-39 

neutron dosimetry systems). The site profile does not address if, where, or when muon doses 

were of health physics concern, or how and if they were monitored and recorded and the 

interpretation of those doses, if recorded. Hazards from extracted high-energy proton beams and 

their dosimetry were also not addressed. The main body of the Occupational External Dosimetry 

section of ORAUT-TKBS-0048 consists of only six pages; this obviously cannot contain 

sufficient information to cover the important aspects of dosimetry at the many diverse BNL 

facilities for an operating period of approximately 60 years. Such a limited space could not 

cover the many health physics aspects of accelerator dosimetry (a few of which are outlined 

above), in addition to those of reactors, isotope production, medical research, hot cells, the 

NSLS, and other facilities with potential radiation exposures at BNL. 

With respect to medical x-rays, the site profile has failed to consider pertinent information on the 

number and types of examinations required as a condition of employment. Based on a 

preliminary review of the documented history of such procedures, further investigation of 

medical examination protocol is warranted. The statement in the site profile that posteroanterior 

(PA) chest photofluorography (PFG), anteroposterior (AP) lumbar spine, and lateral (LAT) 

lumbar spine exams were unlikely is contradicted by existing documentation. The site profile 

assumption that any radiograph that was not a PA chest or LAT chest was diagnostic and should 

not be included in dose reconstruction is likewise contradicted (the lumbar spine and forearm 

x-rays were required during the pre-employment and termination exams, and should not be 

considered diagnostic exams). 

The site profile does not mention the availability or applicability of coworker internal or external 

dose data. Therefore, the dose reconstructor is not provided with any recommendations 

concerning what doses to assign when a worker’s information indicates that the worker should 

have been monitored, but was not, or in those instances where bioassay records are unavailable. 

In view of the lack of a comprehensive bioassay program with established record accessibility, 

coupled with evidence that unmonitored BNL workers were exposed to radiation sources above 

background environmental levels, the availability (or lack thereof) of coworker dose information 

is an important issue at BNL for adequate dose reconstruction that needs to be addressed. 

1.1 SUMMARY OF PRIMARY FINDINGS 

Finding 1: Bioassay Monitoring Not Adequately Established 

ORAUT-TKBS-0048 (TBD) 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 
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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. 

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. 

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, 

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. 

Finding 4: Radionuclide Characteristics Not Sufficiently Known 

Unfortunately, as stated in Section 5.10 of the site profile, 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. 
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Finding 5: No Internal Coworker Dose Database Available 

The site profile 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. 

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. 

Finding 7: NTA Track Fading Not Covered in the Site Profile 

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. 

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, CR-39, 

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. 
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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 underrecorded 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. 

Finding 10: External Coworker Dose Data Not Addressed 

 

Section 6 of the site profile 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. 

Finding 11: Incidents and Unanticipated Events Not Addressed 

The site profile 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. 

Finding 12: Potential Environment Exposures from Igloo Area Not Addressed 

Nothing is mentioned in Section 4 of the site profile 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. 

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) 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 
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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. 

1.2 OPPORTUNITIES FOR IMPROVEMENT 

While the TBDs provided some detailed information concerning the history, developments, and 

facilities at BNL, there was not sufficient in-depth development in many areas to provide for 

adequate dose reconstruction recommendations. Some of these areas are as follows: 

• Different types/sources of radiation fields and their potential exposure to workers 

• Dosimetry systems, changes, and associated problems throughout the operating history of 

BNL 

• Accuracy, availability, and adequacy of external and bioassay records 

• Data integrity of dose records as record systems changed 

• Coworker internal intake and external dose data and/or dose reconstruction 

recommendations for under-monitored or unmonitored workers 

The TBD provided a large number of references at the end of each section; however, some of 

this material needs to be incorporated into specific recommendations in the TBD, especially for 

Sections 5 and 6, to ensure uniform and consistent dose reconstruction. 

There are numerous opportunities for the TBD to be further developed, so that it would be more 

useful in dose reconstruction by building on the basic information provided in the current 

version. 
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2.0 SCOPE AND INTRODUCTION 

The review of the BNL site, in Upton, New York, was authorized by the Advisory Board at its 

December 16–18, 2008, meeting in Augusta, Georgia, and the review was conducted during the 

February–August 2009 timeframe by a team of SC&A health physicists and technical personnel. 

All of the pertinent records reviewed were unclassified; however, two members of the SC&A 

team hold “Q” clearances that would have permitted unencumbered access, if needed. This 

review was performed in accordance with the Advisory Board’s ABRWH-PROC-010, “Data 

Access and Interview Procedure” (ABRWH 2009a), which provides for appropriate onsite 

coordination and data access protocols in conjunction with the Advisory Board, NIOSH, and 

DOE, and ABRWH-PROC-011, “Department of Energy Classification Review of Documents” 

(ABRWH 2009b) which provides for appropriate security clearance reviews. 

SC&A understands that site profiles are living documents, which are revised, refined, and 

supplemented with NIOSH technical information bulletins (TIBs) as required to help dose 

reconstructors. Site profiles are not intended to be prescriptive or necessarily complete in terms 

of addressing every possible issue that may be relevant to a given dose reconstruction. However, 

future revisions in the BNL site profile would serve to mitigate some of the gaps and issues 

raised in this report. 

2.1 REVIEW SCOPE 

Under the Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA) 

and federal regulations defined in Title 42, Part 82, Methods for Radiation Dose Reconstruction 

Under the Energy Employees Occupational Illness Compensation Program, of the Code of 

Federal Regulations (42 CFR Part 82), the Advisory Board is mandated to conduct an 

independent review of the methods and procedures used by NIOSH and its contractors for dose 

reconstruction. As a contractor to the Advisory Board, SC&A has been charged to support this 

effort by independently evaluating a select number of site profiles that correspond to specific 

facilities at which energy employees worked and were exposed to ionizing radiation. 

This report provides a review of the Summary Site Profile Document for the Brookhaven 

National Laboratory, ORAUT-TKBS-0048 (ORAUT 2006), issued on August 30, 2006. To 

date, this document has not been supplemented by site-specific TIBs, but there are several 

generic TIBs that provide additional guidance to the dose reconstructor. 

Implementation guidance is also provided by so-called “workbooks,” which have been 

developed by NIOSH for selected sites to provide more definitive direction to the dose 

reconstructors on how to interpret and apply TBDs, as well as other available information. To 

date, no BNL site-specific workbooks have been developed. 

SC&A, in support of the Advisory Board, has critically evaluated the BNL site profile for the 

following: 
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• Determine the completeness of the information gathered by NIOSH in behalf of the site 

profile, with a view to assessing its adequacy and accuracy in supporting individual dose 

reconstructions

• Assess the technical merit of the data/information

• Assess NIOSH’s use of the data in dose reconstructions

SC&A’s review of this site profile document focuses on the quality and completeness of the data 

that characterized the facility and its operations, and the use of these data in dose reconstruction. 

The review was conducted in accordance with Standard Operating Procedure for Performing 

Site Profile Reviews (SC&A 2004), which was approved by the Advisory Board. 

The review is directed at “sampling” the site profile analyses and data for validation purposes. 

The review does not provide a rigorous quality control process, whereby actual analyses and 

calculations are duplicated or verified. The scope and depth of the review are focused on aspects 

or parameters of the site profile that would be particularly influential in deriving dose 

reconstructions, bridging uncertainties, or correcting technical inaccuracies. 

The BNL site profile document serves as site-specific guidance used in direct support of dose 

reconstructions for claimants. This site profile provides the health physicist who conducts dose 

reconstructions on behalf of NIOSH with consistent general information and specifications to 

support their individual dose reconstructions. This report was prepared by SC&A to provide the 

Advisory Board with an evaluation of whether and how the TBD can support dose reconstruction 

decisions. The criteria for evaluation include whether the TBD provides a basis for scientifically 

supportable dose reconstruction in a manner that is adequate, complete, efficient, and claimant 

favorable. Specifically, this review was conducted as an evaluation of whether dose 

reconstructions based on this site profile would provide for robust compensation decisions. 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and determine the level of exposure the worker received in that 

environment through time. The hierarchy of data used for developing dose reconstruction 

methodologies is dosimeter readings and bioassay data, coworker data and workplace monitoring 

data, and process description information or source term data. 

2.2 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profile that is used in the 

individual dose reconstruction process. This document is reviewed for completeness, technical 

accuracy, adequacy of data, consistency with other site profiles, and compliance with the stated 

objectives, as defined in SC&A Standard Operating Procedure for Performing Site Profile 

Reviews (SC&A 2004). This review is specific to the BNL site profile; however, items identified 

in this report may be applied to other facilities, especially facilities with similar source terms and 

exposure conditions. The review identifies a number of issues and discusses the degree to which 

the site profile fulfills the review objectives delineated in SC&A’s site profile review procedure. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

2.2.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The two elements examined under this objective are (1) determining if the site profile 

made use of available data considered relevant and significant to the dose reconstruction, and 

(2) investigating whether other relevant/significant sources are available, but were not used in the 

development of the site profile. 

2.2.2 Objective 2: Technical Accuracy 

Objective 2 requires SC&A to perform a critical assessment of the methods used in the site 

profile to develop technically defensible guidance or instructions, including evaluating field 

characterization data, source term data, technical reports, standards and guidance documents, and 

literature related to processes that occurred at the BNL site. The goal of this objective is to 

analyze the data according to sound scientific principles, and then evaluate this information in 

the context of dose reconstruction. 

2.2.3 Objective 3: Adequacy of Data 

Objective 3 requires SC&A to determine whether the data and guidance presented in the site 

profile are sufficiently detailed and complete to conduct dose reconstruction, and whether a 

defensible approach has been developed in the absence of data. In addition, this objective 

requires SC&A to assess the credibility of the data used for dose reconstruction. The adequacy 

of the data identifies gaps in the facility data that may influence the outcome of the dose 

reconstruction process. For example, if a site did not monitor all workers exposed to neutrons 

who should have been monitored, this would be considered a gap, and therefore an inadequacy in 

the data. An important consideration in this aspect of our review of the site profile is the 

scientific validity and claimant favorability of the data, methods, and assumptions employed in 

the site profile to fill in data gaps. 

2.2.4 Objective 4: Consistency among Site Profiles 

Objective 4 requires SC&A to identify common elements within site profiles completed or 

reviewed to date, as appropriate. In order to accomplish this objective, the BNL site profile was 

compared to other TBDs previously reviewed. This assessment was conducted to identify areas 

of inconsistencies and determine the potential significance of any inconsistencies with regard to 

the dose reconstruction process. 

2.2.5 Objective 5: Regulatory Compliance 

Objective 5 requires SC&A to evaluate the degree to which the site profile complies with stated 

policy and directives contained in 42 CFR Part 82. In addition, SC&A evaluated the site profile 

for adherence to general quality assurance policies and procedures utilized for the performance 

of dose reconstructions. 
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2.3 DOSE RECONSTRUCTION UNDER EEOICPA 

In order to place the above objectives into the proper context as they pertain to the site profile, it 

is important to briefly review key elements of the dose reconstruction process, as specified in 

42 CFR Part 82. Federal regulations specify that a dose reconstruction can be broadly placed 

into one of three discrete categories. These three categories differ greatly in terms of their 

dependence on and the completeness of available dose data, as well as on the 

accuracy/uncertainty of data. 

Category 1: Least challenged by any deficiencies in available dose/monitoring data are dose 

reconstructions for which even a partial assessment [or minimized dose(s)] corresponds to a 

probability of causation (POC) value in excess of 50%, assuring compensability to the claimant. 

In some cases, such partial/incomplete dose reconstructions with a POC greater than 50% may 

involve only a limited amount of external or internal data. In extreme cases, even a total absence 

of a positive measurement may suffice for an assigned organ dose [based on the limits of 

detection (LOD)] that results in a POC greater than 50%. For this reason, dose reconstructions in 

this category may only be marginally affected by incomplete/missing data or uncertainty of the 

measurements. In fact, regulatory guidelines recommend the use of a partial/incomplete dose 

reconstruction, the minimization of dose, and the exclusion of uncertainty for reasons of process 

efficiency, as long as this limited effort produces a POC equal to or greater than 50%. 

Category 2: A second category of dose reconstruction defined by federal guidance recommends 

the use of “worst-case” assumptions. The purpose of worst-case assumptions in dose 

reconstruction is to derive maximal or highly improbable dose assignments. For example, a 

worst-case assumption may place a worker at a given work location 24 hours per day and 

365 days per year. The use of such maximized (or upper bound) values, however, is limited to 

those instances where the resultant maximized doses yield POC values below 50%, which are 

not compensated. For this second category, the dose reconstructor needs only to ensure that all 

potential internal and external exposure pathways have been considered, and that the approach is 

scientifically supportable. 

The obvious benefit of worst-case assumptions and the use of maximized doses in dose 

reconstruction is efficiency. Efficiency is achieved by the fact that maximized doses avoid the 

need for precise data and eliminate consideration for the uncertainty of the dose. Lastly, the use 

of bounding values in dose reconstruction minimizes any controversy regarding the decision not 

to compensate a claim. 

Although simplistic in design, the site profile must, at a minimum, provide information and data 

that clearly identify (1) all potential radionuclides, (2) all potential modes of exposure, and 

(3) upper limits for each contaminant and mode of exposure, to satisfy this type of a dose 

reconstruction. Thus, for external exposures, maximum dose rates must be identified in time and 

space that correspond to a worker’s employment period, work locations, and job assignment. 

Similarly, in order to maximize internal exposures, highest air concentrations and surface 

contaminations must be identified. 
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Category 3: The most complex and challenging dose reconstructions consist of claims where 

the case cannot be dealt with in one of the two categories above. For instance, when a minimum 

dose estimate does not result in compensation, a next step is required to make a more complete 

estimate. Or when a worst-case dose estimate that has assumptions that may be physically 

implausible results in a POC greater than 50%, a more refined analysis is required. A more 

refined estimate may be required either to deny or to compensate. In such dose reconstructions, 

which may be represented as a “reasonable” or “best-case” estimate, NIOSH has committed to 

resolve uncertainties in favor of the claimant. According to 42 CFR 82, NIOSH interprets 

“reasonable estimates” of radiation dose to mean the following: 

... estimates calculated using a substantial basis of fact and the application of 

science-based, logical assumptions to supplement or interpret the factual basis. 

Claimants will in no case be harmed by any level of uncertainty involved in 

their claims, since assumptions applied by NIOSH will consistently give the 

benefit of the doubt to claimants. (Emphasis added.) 

SC&A’s draft report and preliminary findings will subsequently undergo a multi-step resolution 

process. Prior to and during the resolution process, the draft report is reviewed by the DOE 

Office of Health, Safety, and Security to confirm that no classified documents or information 

have been incorporated into the report. Resolution includes a transparent review and discussion 

of draft findings with members of the Advisory Board Working Group, petitioners, claimants, 

and interested members of the public. This resolution process is intended to ensure that each 

finding is evaluated on its technical basis in a fair and impartial manner. 

 

All review comments apply to Revision 00 of the BNL site profile document, which is the most 

recently published version. Site expert interviews were conducted with former and current BNL 

site workers to help SC&A obtain a comprehensive understanding of the radiation protection 

program, site operations, and historic exposure experience. 

An attachment to this report will be provided later. The attachment will summarize the 

interviews conducted by SC&A during the course of this review. The interviewees included a 

good cross-section of former and current BNL site workers, including health physics (field and 

programmatic), dosimetry, medical, accelerator operations, reactor operations, support workers 

(i.e., maintenance and crafts), and research and development that worked at the BNL site from 

1957 through the present. The interviews were conducted at the main technical library at BNL 

by Joseph Fitzgerald (SC&A/Saliant Inc.) and Kathy Robertson-DeMers (SC&A/Saliant Inc.), 

on May 18–21, 2009. 

2.4 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board, this report is organized into 

the following sections: 
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(1) Executive Summary 

(2) Scope and Introduction 

(3) Vertical Issues 

(4) Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction 

Based on the issues raised, SC&A prepared a summary list of findings, which are provided in the 

Executive Summary. Issues are designated as “Primary Findings” if SC&A believes that they 

represent deficiencies in the site profile that need to be corrected and which have the potential to 

have a substantial impact on at least some dose reconstructions. Issues can also be designated as 

Secondary Findings or Observations if they simply raise questions, which, if addressed, would 

further improve the site profile and may possibly reveal deficiencies that will need to be 

addressed in future revisions. Detailed analyses of the primary and secondary findings are 

provided in Section 3 of this report. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

3.0 VERTICAL ISSUES 

Finding 1: Bioassay Monitoring Not Adequately Established 

ORAUT-TKBS-0048 (TBD) 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 some 40 years of uncertainty 

concerning bioassay requirements. 

Until the 1990s, the determination of “who, when, and what” radionuclides for which workers 

were monitored was apparently a decision made at the departmental level, as opposed to being 

determined according to a centralized BNL policy. Unfortunately, this mode of operation led to 

inconsistencies in bioassay monitoring between departments, and fragmented and ad hoc 

recordkeeping (a later finding in its own right). This is further complicated by the fact that many 

of the bioassays were concerned with tritium intake, and tritium subsequently became an 

indicator, or surrogate, dosimetry source term for other radionuclides. However, it is clear that 

this approach is not necessarily a reliable one, particularly for short-lived radioisotopes to which 

workers may have been exposed at the BLIP facility and at the numerous onsite accelerators 

located at BNL; these and other radioisotopes would exhibit a different biological behavior than 

tritium. 

With the exception of operators at the Brookhaven Graphite Research Reactor (BGRR), bioassay 

monitoring for radionuclides other than tritium at BNL appears to have been more “event 

driven,” rather than conducted on a routine preventive basis. A preliminary review of BNL 

bioassay records does not indicate that consistent long-term routine bioassay monitoring policies 

were in place. When bioassays were conducted, it appears that the emphasis was on reactor 

operators; however, some of the most exposed workers were likely support service workers, i.e., 

those fueling, modifying, and maintaining the reactors (crafts and technicians). Of the current 66 

claims at BNL (as of July 2009), very few were pile/reactor operators according to the listed job 

titles. Therefore, the issue of the adequacy and completeness of bioassays for all categories of 

BNL workers is relevant to performing adequate dose reconstruction. 

According to the site profile and claimant records, Form 1720 was used to record bioassay data 

from 1952–1986. The following is an example of the form and the information it contained: 
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BROOKHAVEN NATIONAL LABORATORY BIOASSAY RECORD 

 NAME___________________________________ BNL LIFE NO.________ DEPT./DIV.___________________ H.P. LOCATION_______________________ 

BETA ALPHA 

D/M/DAY μc/l 

No. 

DATE 

RECV’D 

I 

S 

COLLECTION 

DATE/TIME 

COUNT 

DATE 

TOTAL 

SAMPLE

SAMPLE 

TYPE MFP 90Sr 3

H NUCLIDE AMOUNT UNITS MISCELLANEOUS & REMARKS 

 

A review of these forms in the claimant files indicates that there has been information entered in 

each space in columns 1–7, on each line, and generally column 8 for mixed fission products 

(MFP) contained a number, and occasionally column 9 for 90Sr contained a number. While the 

site profile provides some history concerning the in-vitro urine analysis, there is no information 

concerning the technical details of the MFP analysis. For dose reconstruction, some information 

is needed concerning the individual radioisotope analyzed for, and the method(s) of analyses. 

For example, some issues that need to be addressed include the following: 

• When were gross beta, alpha, and/or gamma counting used? 

• When were beta, alpha, and/or gamma spectrometry methods used? 

• At the time of bioassay sampling and analysis, what radioisotopes were of concern, and 

what were not? How did this change as a function of time and work locations 

(buildings)? 

• What were the constituents of MFPs? Did this change as a function of time and facility? 

• When did BNL start to perform bioassay analysis for different isotopes of a given 

radionuclide (i.e., instead of analyzing for total uranium, when did BNL start analyzing 

for U-234, U-238, etc.)? 

• What are the radioisotopes that are the major organ dose contributors that the dose 

reconstructor needs to include in the dose reconstruction? 

Information concerning the radioisotope of intake is important when performing dose 

reconstruction; while radioisotopes in stack emissions, inventory, etc., may provide useful 

information, they are not primary sources in assigning internal doses. In addition to the reactors, 

critical assemblies (Court et al. 1967), isotope production, and the numerous accelerator facilities 

at BNL produced activation products and other radionuclides that could create potential internal 

exposure. Accelerator beams can activate iron, copper, aluminum, and structural material, 

resulting in activation products that would include Na-22, Na-24, V-48, 

Mn-54, Fe-55, Co-57, Co-59, and Co-60. Bioassay analyses for these internal radioisotopes are 

not addressed in the site profile. 

According to the site profile, and a review of the claimant files, the BNL Tritium Exposure 

Evaluation form was used to record tritium bioassay results from 1968–1986. The following is 

an example of the form and the information it contained: 
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HEALTH PHYSICS DIVISION 

Brookhaven National Laboratory 

TRITIUM EXPOSURE EVALUATION 

 Name ........................................ BNL No. ............ Location ................................... 

Date No. of 

Intervening 

Days 

Gross μc/l 

Current 

Date 

Gross μc/l 

Previous 

Date 

Fraction 

Present of 

Previous 

Concentration 

μc/l 

Remaining 

from Previous 

Date 

Net μc/l 

Current 

Date 

Tritium 

Body Dose 

for Current 

Date 

MREM 

Cumulative 

Tritium 

Body Dose 

MREM 

A review of the claimant files reveals that, in general, these forms contain data for most of the 

columns, especially for reactor operators. However, no documented BNL procedures have been 

located that establish bioassay policies laboratory-wide, and as a function of time. The site 

profile makes the statement in Section 5.4.2 that this form could be a secondary source of 

information, should Form 1720, discussed above, be missing or illegible. However, as can be 

seen from the column headings on the tritium exposure form, there is only information for 

tritium and no other radioisotopes; it is not stated how other radioisotope intakes can be 

determined from tritium intake data. 

For a number of years, BNL was involved in monitoring the conditions and people of the 

Marshall Islands, where atomic tests were previously conducted. The site profile does not 

address the monitoring issues involved in this program, such as whether BNL personnel who 

traveled to the islands were potentially exposed, or information regarding bioassay requirements 

for BNL personnel involved in this program, the location and availability of the bioassay records, 

and other pertinent information to guide dose reconstruction. Based on independent 

investigations performed by SC&A, islands on Bikini, Enewetak, and Rongelap Atolls have 

elevated external radiation fields1 and the potential for elevated internal exposures to Cs-137, if 

locally grown food was consumed for protracted periods of time (e.g., several months) during 

visits to the northern atolls. 

It is mentioned on page 75 of the site profile that decontamination and decommissioning (D&D) 

workers were sampled for various radioisotopes during D&D operations in recent years (e.g., 

interviewees indicated bioassay sampling was done for transuranics and fission products during 

D&D of the BGRR). However, no information is provided concerning these workers, such as: 

• Were these BNL employees, or outside contractors? 

• Were the bioassay monitoring requirements the same or different than those of regular 

BNL employees? 

• Was cohort or individual sampling performed? 

 1

 According to health physicists involved in the program, workers from BNL participating in the Marshall 

Islands project did not require external dosimetry for the purposes of this project. They indicated that the highest 

contaminated areas where they worked were on Bikini Atoll, where external dose rates were tens of microrem per 

hour. 
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• What types of bioassays were performed? 

• Where are the bioassay records located and are they accessible? 

More information is needed for the D&D worker bioassay program to adequately support 

accurate and complete dose reconstruction for that activity. 

In summary, the site profile does not address the adequacy and completeness of BNL bioassay 

data to support dose reconstruction. Uniform and comprehensive historic bioassay policies have 

not been cited nor located for BNL. An adequate basis for dose estimation has not been 

established by the site profile for BNL. 

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. As confirmed by interviews with several veteran BNL health physicists, there were 

numerous bioassay data recording systems and filing methods at BNL. Many of these earlier 

records are still located in various departments at the laboratory, making it difficult for BNL to 

properly and completely respond to NIOSH requests for bioassay records to be used in dose 

reconstruction. It is not currently known if all the hardcopy records have been located, are 

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

disestablished, and as department heads came to and left BNL, these original hardcopy records 

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

is no means available at this time to determine if all the records for a given employee are 

available for dose reconstruction purposes, particularly before the time period when all records 

were entered into electronic databases. Additionally, the site profile did not address issues 

surrounding the transfer of bioassay data from the hardcopies to electronic databases, e.g., if the 

transferred data were checked for accuracy and completeness, and whether the data transfers to 

upgraded electronic systems were checked using quality control. 

The site profile does not address the data recording and storage methods used from the late 1940s 

to the retroactive start of the use of Form 1720 (~1952), and the start of the use of the Tritium 

Exposure Evaluation Form (1968). As previously discussed, Form 1720 was used to record 

MFPs and Sr-90 bioassay beta count results during 1967–1986 (with some indication that 

bioassay information from 1950s–1966 was transferred to this form in 1967), and the Tritium 

Exposure Evaluation Form was used during 1968–1986. However, interviews with former and 

current BNL health physicists indicate that, while the individual worker file may contain records 

that bioassays were performed, they do not necessarily contain the results of the bioassay from 

the late 1940–1970s. During the 1970s and 1980s, BNL was in a state of transition from 

hardcopy to electronic recordkeeping; this resulted in the individual record folders becoming 

increasingly incomplete. Starting in the 1990s, a more systematic electronic-based Health 

Physics Record System (HPRS) was implemented, which provides for a more complete and 

centralized data storage system. 

BNL started whole-body counts (WBC) in the 1970s, or earlier, but unfortunately many of the 

results were recorded in logbooks instead of in the individual workers’ files. Additionally, 
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WBCs were provided primarily for BNL reactor operators and for the Marshall Islands exposure 

subjects; other BNL employees were counted only as WBC time became available, and there 

appears to be a gap in WBCs from ~1977–1981, when no WBCs were performed. 

A preliminary review of claimant files shows that the DOE records used to perform dose 

reconstruction contain some data on Form 1720, some data on the Tritium Exposure Evaluation 

Form, and some WBC reports in various forms. However, in general, the records do not appear 

to show a continuous or correlated bioassay methodology; i.e., some claimants may have WBC 

records, but no urinalysis records in their DOE files. A preliminary examination of the DOE 

files for 23 of the current (as of July 2009) 66 BNL claimants (whose job titles would indicate 

the possible need for bioassay monitoring and whose work history was fairly evenly distributed 

over the period 1947–2002) did not reveal a consistent pattern of routine bioassay monitoring for 

most of these individuals. It is not possible to determine at this time whether this irregular 

monitoring stemmed from the lack of a need for bioassay monitoring, the lack of bioassay 

monitoring, or from lack of record availability. Most of the DOE files of the 23 claimant cases 

reviewed contain a BNL response form, PM3421, which states that there was no in-vitro or invivo measurement data for a specific worker. However, a few of the DOE files created later 

contain WBC and/or urinalysis (mainly tritium) data for short periods of time. This indicates 

that some of the records were not available during the first request for records to be used for dose 

reconstruction, but were located later. However, there is no way to determine if they have all 

been recovered. 

The extent of the records retrieval problem is evident from interviews with BNL personnel 

monitoring staff: 

For purposes of responding to NIOSH requests for individual EEOICPA internal 

dose claimant data, I am collecting whatever hardcopy internal dose records I 

can from various onsite sources, such as the medical program. However, there is 

no way of knowing whether the retrieved records are complete for individuals or 

programs, because there was no coherent, centralized system of recordkeeping. 

Some records resided with individual department heads who may have disposed 

of records, removed them upon departure, or transferred them elsewhere. Data 

may be missing, but there is no way to tell. 

For example, if someone who worked at the BGRR was potentially exposed to 

MFP and Sr-90, and received bioassays during their timeframe of work, their 

individual records may indicate that they had been given bioassays, but the 

results, themselves, may be missing and unavailable. The only avenue would be 

to search through PM’s [Personnel Monitoring] collected records by identifier 

and see what is there – however, there is no way to verify that the data is 

complete. After the approximate time frame of 1999, there is bioassay data and 

chain of custody documents to support the bioassay program. 

In summary, the site profile does not sufficiently address the issue of whether complete and 

accurate bioassay records exist during BNL’s operating history to perform adequate dose 
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reconstruction. As evident from the information provided above, there are sufficient reasons to 

question the completeness, accuracy, and accessibility of bioassay records for BNL from the late 

1940s through the mid-1980s, or perhaps into the mid-1990s when the HPRS became 

operational. 

Finding 3: MDA and Uncertainty Values Not Sufficiently Defined 

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

and a list of WBC MDA values is provided in Table 5-3, pages 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 on page 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 1940s–1990s, 

such as is found in some of the other DOE site profiles [i.e., ORAUT-TKBS-0012-5 (ORAUT 

2007), Table 5-9, pg. 16]. Furthermore, the site profile has not considered detection limits 

associated with the fission track technique used in some cases for the detection of uranium and 

plutonium (Moorthy and Baum 1985). In addition to the MDA values for common 

radioisotopes, the MDA values for, or procedure for identifying, other less common (but 

potentially present) radioisotopes should be provided, so that the dose reconstructor can consider 

and assign missed dose in specific cases where other radioisotopes could be present. For 

example, one can compare the relatively few radioisotopes, and associated time periods, listed in 

Table 5-3 on page 80 that the dose reconstructor has to work with, with the many radioisotopes 

listed in Tables 2-2, 2-3, and 5-5 occurring over more than a 50-year period. Some MDA values 

are obtainable from BNL documents, one example from Miltenberger (1978) being the BNL 

WBC MDL for U-235, which was 800 pCi (370 μg) in 1978. Additionally, uncertainty values 

are not provided and are apparently not available for most of the bioassay reporting period from 

the 1950s–1990s. 

Table 2-2 of Section 2.5 of the site profile provides an extensive list of isotopes assumed to be 

present at the various facilities at BNL. Although it is stated on page 37 that this table is to 

provide background information only, this list could be misleading, as it is reflective of the 

airborne radionuclides released, as opposed to the radionuclides actually present in the work 

areas. The site profile does not provide a reference for the data presented in the unlabeled table 

in Section 4.51 on page 63, nor the unlabeled table on page 64, which identifies some isotopes 

that are assumed to be the isotopes that were monitored in the stacks. Additionally, the lists of 

isotopes in the latter table do not contain all the isotopes listed in Table 4-2 on pages 65–67, i.e., 

it lacks Sr-90, Nb-95/Zr-95, Tc-99, TC-99m, Ru-103, Ra-226, and Th-228; it is assumed that 

these isotopes were monitored at ground level, and not in the stack, but this is not explicitly 

stated. MDA values for most of these radioisotopes are not provided prior to the late 1990s. 

In summary, the site profile does not sufficiently address the MDA and uncertainty values that 

the dose reconstructor is to use for the different types of bioassays as a function of time, nor does 

it provide default MDAs and uncertainty values to use if none are available. 
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Finding 4: Radionuclide Characteristics Not Sufficiently Known 

Tables 2-2, 2-3, and 5-5 collectively provide information on the radionuclides by facility, the 

solubility data, particle size, and activity fractions. References are not provided for the 

information compiled in these tables, making it difficult to verify the information. As stated in 

Section 5.10 of the site profile, specific solubility data, particle size, and activity fractions are 

not known, or are not available, for most facilities at BNL. Site experts interviewed indicated 

the data in these tables reflect stack emission data, rather than workplace data. The use of stack 

emission data is not always a good indicator of the types of radioisotopes present, or their 

concentrations, in the worker’s breathing zone. Interviews with BNL workers indicate that 

Tables 2-2 and 2-3 do not correctly reflect the radioisotopes present at some of the BNL 

facilities. For example, the radioisotopes listed in Tables 2-2 and 2-3 for the Hot Laboratory 

should include As-73, Sr-82, Sr-85, Ge-68, Cu-67, Y-88, Fe-52, Sn-117m, Zn-65, Fe-55, Ni-63, 

Rb-84, Rb-86, Xe-127, I-123, I-122, Pd-103, Mg-28, and Mo-99; Co-58, H-3, Mn-54, Br-82, 

Se-75, and V-48 were present in trace quantities. Isotopes produced at the BLIP facility should 

include Sr-82, Sr-85, Ge-68, Cu-64, Cu-67, Y-86, Y-88, Fe-52, Sn-117m, Zn-65, Rb-84, Rb-86, 

Xe-127, I-123, I-122, Pd-103, Mg-28, and As-73. The relative fractions of radionuclides 

assumed is inconsistent with what site experts say they were handling in the workplace. In 

addition, there are inconsistencies between Tables 2-2 and 2-3 under the site description, and 

Table 5-5 in the internal dosimetry section. 

Without a proper characterization of workplace exposures, the adequacy of the internal and 

external monitoring programs cannot be effectively evaluated. For instance, since the 

radionuclides at the Hot Laboratory and BLIP were absent from the characterization, the site 

profile could not evaluate whether workers received appropriate bioassay for what they were 

exposed to, and whether that bioassay was collected in a timely manner. In addition, workplacespecific monitoring data and/or source term data do not appear to be available (TBD 

Sections 5.12 and 5.13). Lack of appropriate radiological characterization can also affect 

occupational environmental dose assumptions. This could result in less than claimant-favorable 

assumptions for organ dose reconstruction. 

There is no support or reference listed for using a reduction factor of 0.01 to convert the 

measured stack concentrations to ground-level concentrations, as recommended in Section 4.5.2 

on page 64. It is worth noting that this “short-cut approach” for placing an upper bound on 

occupational environmental exposures to airborne emission was used in at least one other site 

profile, and it is currently under review in that venue. 

Finding 5: No Internal Dose Coworker Database Available 

The site profile does not address coworker data. In view of the issues with the lack of a 

coordinated, consistent, bioassay program and the problems with the availability of the 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 

makes it difficult to create an adequate coworker internal dose table for the dose reconstructor to 

use to bridge the gaps for sporadically monitored workers, monitored workers whose complete 
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records are not available, and unmonitored workers who should have been monitored. As 

previously described, the records contain sporadic bioassay data; therefore, coworker internal 

dose data are needed for BNL. 

The site profile does not mention the availability or applicability of coworker internal dose data. 

Therefore, the dose reconstructor is not provided with any recommendations concerning what 

doses to assign when a worker’s information indicates that the worker should have been 

monitored, but wasn’t, or the bioassay records are unavailable. In view of the lack of a solid 

bioassay program and record accessibility, the availability, or lack of, coworker dose information 

is an important issue at BNL for adequate dose reconstruction. 

Finding 6: NTA Threshold Response Not Sufficiently Investigated 

The threshold energy of NTA film (0.5–1.0 MeV) and the amount of dose not registered because 

of this threshold is important in neutron dosimetry. This threshold was identified as early as 

1956 in a BNL Health Physics Summary Report for November 1956 (BNL 1956, pg. 2):

As expected, it was found that the film will not detect neutrons below 0.5 MeV and 

that the sensitivity drops off sharply in the region from 0.5 to l.2 MeV. 

In 1974, it was stated in a BNL article by L. Phillips (Phillips 1974, pg. 21):

A serious disadvantage of personnel neutron monitoring using NTA emulsion is 

the blind region from thermal energies to approximately 500 keV. The effect of a 

certain amount of moderation of epithermal neutrons by the body and detection 

by the N(n,p) reaction cannot be relied upon as a significant effect using present 

calibration techniques. A new albedo dosimetry technique, which reduces the 

error in this “blind” energy region, has recently been reported in the literature. 

NTA film decreases in response starting at neutron energies below 1 MeV and is almost 

completely insensitive to neutrons below 0.5 MeV [ORAUT-TKBS-0010-6 (ORAUT 2005a), 

pg. 27); therefore, radiation fields containing an appreciable percentage of the total dose 

equivalent due to neutron below 1 MeV must be evaluated carefully, with attention given to the 

missed dose resulting from this threshold affect. Additionally, NTA tracks fade more rapidly 

with time as the interacting neutron energy decreases, resulting in more missed neutron dose 

(note the related “fading” issue addressed in this report for additional details). 

According to BNL documents located by SC&A, neutrons with energies ranging from thermal to 

1 MeV were present at various BNL facilities, in addition to the medium and higher energy 

neutrons (i.e., greater than 1 MeV) for much of its operating history. For example, the article by 

Handloser and Delihas (1955) contains various locations at the BGRR, where an energy range of 

thermal to fast neutrons was present. 

A 1973 neutron energy spectra measurement using Bonner spheres at the BMRR patient 

treatment facility likewise indicated that the majority of the dose outside the treatment room, 
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where workers may have been present, was due to low-energy neutrons; i.e., the highest dose 

came from neutrons with 600 keV of energy (Nelson 1973). 

Another example, Schaefer 1995 (pp. 4–6), shows plots of %Total REM as a function of Neutron 

Energy (MeV). In these plots, it can be seen that approximately 50% of the neutron dose 

equivalent falls below 1 MeV for 6 locations at the Alternating Gradient Synchrotron (AGS). An 

example of one of these plots, which includes the results for two locations, is presented below: 

Example of one of Schaefer’s plots 

Another example is shown in Figure 7 of G. Riel’s 1995 article (Riel 1995, pg. 10), where it can 

be seen that a large portion of the neutron flux lies below the 0.5–1.0 MeV NTA threshold (red 

arrow) in the BNL workplace. 
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Neutron Flux vs. Neutron Energy in the BNL workplace 

The site profile does not specifically address the subject of NTA film threshold. Section 6.4.1, 

page 91, contains a paragraph of general neutron dosimetry information. Section 6.7, page 94, 

lists recommended allotment of neutron energies, i.e., 0.1–2.0 MeV and 2–14 MeV, and states 

that NTA film was used through 1995. Bias and uncertainty values are listed for NTA film in 

Table 6-7 on page 97 with neutron uncertainty factors listed as 1.35 or 1.5, with a footnote that 

they are due to lack of knowledge of energy and geometry. The only mention made of the origin 

of these factors is on page 96, where there is a somewhat unclear statement concerning the fact 

that the values were taken from the Atomics International TBD (what SC&A found on page 12 

of that document is a reference to the Hanford Site TBD), and also because of the fact that the 

adjusted neutron energy values are similar to, and are based on, Y-12 data (ORAUT 2005b). 

From this, it is unclear exactly where the values were obtained, and there is no supporting 

evidence to link the BNL neutron energy spectra to the other sites. The lack of details on this 

issue may lead to a lack of understanding on the part of the dose reconstructor of how to address 

low-energy neutrons in dose reconstruction. For example, SC&A found that four out of five 

final dose reconstruction reports for BNL claimants, completed after the site profile was 

issued, did not include the neutron adjustment factors of 1.5 or 1.35 for low energy 

neutrons; only the ICRP factors of 1.91 or 2.00 were used. 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. 

Finding 7: NTA Track Fading Not Covered in Site Profile 

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

depend 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). While this issue is not addressed 

in the site profile, BNL was fully aware of the problem, as several BNL documents cite concerns 

or experiments conducted at BNL in this area. For example, in a 1973 BNL article (Phillips 
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et al. 1973), NTA film was tested in sealed and unsealed packages. The unsealed NTA film lost 

all tracks in only 1 week at 100% relative humidity (RH), as shown in the following plot:

A 1972 BNL article (Distenfeld and Klemish 1972) states the following:

Film neutron dosimetry suffers prohibitive fading. Attempts by American 

laboratories to package NTA film have never prevented excessive fading. 

Another 1974 article by L. Phillips (Phillips 1974, pg. 18) describes tests run at BNL to 

determine NTA track fading. The results, using a relatively high-energy PuBe neutron source, 

are shown in the following plot. 

Percent of original tracks vs. time 
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A 1975 article by L. Phillips describes a test in which two different types of packets were used to 

seal NTA films. The sealed NTA films were then exposed to neutrons and stored at 100% RH. 

The percent of the original tracks remaining (compared to the number at to) as a function of time 

is summarized in the following plot. 

Percent of tracks remaining after to vs. weeks stored at 100% RH 

At other DOE locations, such as the Mound site, NTA track fading was of sufficient concern that 

several experiments were conducted and exposure and reading procedures were modified to 

compensate for fading (ORAUT 2004a). 

From these examples, it can be seen that NTA track fading is of concern when considering the 

accuracy of recorded neutron doses. The site profile did not directly address NTA film track 

fading or describe any procedure necessary to compensate for it. 

From interviews with BNL health physics technicians who processed and read NTA films, it was 

learned that no apparent adjustments were made to account for fading: 

We didn’t do anything with the fading. The badges were developed and read 

within two weeks. There were 20–25 fields from the film read. BNL had about 

2–3 readers who would spot check each other. 

In summary, if a fading problem does not present an issue for dose estimation with sufficient 

accuracy at BNL, i.e., it was accounted for in the calibration/issue/read cycle or included in the 

uncertainty factor, it should be explained and supported in the site profile. If not, this area needs 

further development. 

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, CR-39, 

and Lexan neutron dosimeters. However, these neutron dosimeters were not without their own 

problems. From the site documents that SC&A has analyzed, the two major issues that were 

prevalent at BNL were (a) no single neutron detector sufficiently covered all the neutron energies 

encountered in the many different radiation environments; and (b) there were problems with the 

vendors of these detectors providing consistent and accurate neutron and photon dose results. To 
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facilitate the discussion of these issues, a very brief summary of personnel dosimeters and their 

advantages/limitations is provided.

Energy/dose response of different types of dose monitors/detectors. 

i. Film and TLD-700 beta/photon detectors – Photographic film and thermoluminescence 

dosimeters (TLDs) respond to low LET (Linear Energy Transfer) radiation, such as 

betas, x-rays, gammas, and muons. 

 

ii. NTA film – Neutron dose is determined by counting tracks in the emulsion produced 

by the (n,p) recoil proton. NTA film has a threshold of approximately 0.5 MeV, low 

sensitivity below 1.0 MeV, and the proton recoil tracks fade with time, but it has 

reasonable good response at higher neutron energy. NTA film will also respond to 

charged particles if they are able to penetrate the outer wrapper. The reading process is 

time consuming and prone to errors when compared to photon film dosimetry. 

iii. TLD-600 – Neutron sensitive TLDs do not suffer from the threshold affect that NTA 

film does; in fact, TLD response is greater at lower neutron energies. However, TLD 

response decreases rapidly as the neutrons go above 1–2 MeV in energy (ORAUT 

2005a). This makes TLDs suitable for use around moderated neutron fields (such as 

outside reactor shielding), but they under-respond to higher-energy neutron fields 

found around accelerators, which are prevalent at BNL. 

iv. CR-39 – CR-39 stands for Columbia Resin, type 39 (a trademark of the PPG 

Industries) and is a plastic foil track-etch dosimeter. It has a neutron energy threshold 

around 0.2 MeV and has sensitivity an order of magnitude greater than Lexan for fast 

neutrons (Schaefer 1995, pdf pages 2 and 3, Ref ID 22456). Although it has a 

threshold around 0.2 MeV, it will significantly under-respond to neutrons less than 1.2 

MeV (ORAUT 2005a). CR-39 characteristics make it useful for determining neutron 

doses around high-energy accelerators. 

v. Lexan – Lexan (an SABIC Innovative Plastics product) is a small plastic chip that is 

etched from exposure to neutrons, with the pits counted under magnification to 

obtained neutron dose. Lexan has a threshold between 1–2 MeV for neutrons. 

Two issues, one concerned with the fact that no single neutron detector sufficiently covered all 

the neutron energies and the other one related to problems with the results from the vendors, are 

interrelated because the properties of the neutron detectors were such that several types of 

detectors had to be used to cover the neutron energy range found at BNL; and if the readings 

from the vendors were not consistent, the obvious question is which detector results should have 

been used as the dose of record? From the BNL documents reviewed by SC&A and from 

interviews conducted with contemporary health physicists, it appears that there was a problem in 

this area, as found in several documents dating from 1987–1995, which are discussed below. 
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1987 – Several 1987 BNL letters/memorandums (see Casey 1987) refer to problems with the 

results from the vendor at that time, Landauer, Inc. There was apparently a difference in the 

dose readings for identical detector types evident by the statement on page 2, “Large 

discrepancies between duplicate badges with identical dosimeter types...”, and between CR-39 

and NTA film results as evident by the statement, “The reason for discrepancies between 

dosimeter types (CR39 and NTA) are also of significant interest, since they have impact in the 

field use of a particular dosimeter.” To complicate the neutron dose issue, there also appears to 

have been a problem with monitoring for gamma-muon doses at this time, as indicated by the 

statement on page 3, “In another memorandum (February 24, 1987), one sees that the badges are 

not responding to gamma-muon doses of about 47 mrem.” The details of this latter 

memorandum are contained on pages 9–10 of Casey 1987. As of yet, SC&A has not been able 

to locate documentation concerning the resolution of these problems. 

1988 – In a 1988 BNL memorandum (see Musolino 1988), some of the problems with dosimetry 

at the accelerators were outlined. The BNL staff undertook experiments to help resolve some of 

these dosimetry problems. These experiments consisted of exposing different types of 

dosimeters and survey instruments to radiation fields around the AGS accelerator and comparing 

their results. There were several tests (runs) conducted; these included runs in June 1986, 

December 1986, May 1987, and February 1988. Additionally, NTA film was replaced by Lexan 

in December 1987, for use as the dose of record, but NTA film was retained in the badges for 

study and some comparisons were made. The following is a summary of the results of these 

runs: 

a. Main points of Musolino’s cover memorandum of April 18, 1988: In short, 

approximately 10 times the expected collective neutron dose was reported by the 

recently adopted Lexan dosimeter, much of which was reported on persons that 

did not use their badge at all, persons not at BNL in February, or persons that did 

not use their badge in neutron fields. The old NTA system, which was retained in 

the badge for studies, indicated expected values. 

Because Landauer and S&EP have found no plausible technical explanation for 

the recent events, I question how much confidence BNL should have in the 

Landauer neutron dosimetry system. 

b. Excerpts from June 1986 run – The results of the first study, which was 

performed from 6/13/86 to 6/27/86, was reported in the attached memo to Rohrig 

dated 11/17/86 [Musolino 1988, pg. 6, Table 1]. The response of NTA relative to 

Lexan was inconclusive in much of the NTA (and CR-39) data, when replicate 

measurements, shown in the aforementioned memo, returned widely varying 

results. 

c. Excerpts from December 1986 run – During the next SEB run beginning on 

12/4/87, close inspection of the neutron dosimetry total of AGS personnel 

indicated continued problems in the NTA data. This was reported in the attached 

memo to Schopfer dated 2/24/87 [Musolino 1988, pg. 7, Table 2]. It was of great 
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concern at this point, due to the lack of dose reported with respect to active 

instrumentation. [Note that 12/4/87 should read 12/4/86, as evident from other 

contents of the article.]

To date, this question has not been satisfactorily answered by Landauer nor has 

the reason for the wide variances been explained. Copies of my memos had been 

provided to Landauer so that they could analyze this data. 

d. Excerpts from May 1987 run – 1. Wide variances in the NTA results continued 

thereby reinforcing the lack of credibility in the results. 2. Lexan data was much 

more consistent with no catastrophic failures and much lower percent standard 

deviation. 3. For the second time the Lexan results were lower than the NTA 

values. 

The apparent reproducibility improvement and monthly exchange cycle would 

justify switchover to Lexan, because the under response would be offset by the 

lack of fading and the sensitivity for gamma-muon would improve by the doubling 

of exposure time. 

e. Excerpts from February 1988 run – The personnel results were altogether 

different. The anomalies and/or failures in the data are: 1. A collective neutron 

dose of approximately 16,000 mrem for about 150 persons when 1000–

2000 mrem was expected. 2. Doses of 60, 40, 200, 40, 110 and 80 mrem neutron 

on control badges but minimal on the replicate and the NTA. 3. High neutron 

doses were even reported for individuals who were not at BNL in February or did 

not use their badge in pulsed radiation fields. 4. For the first time, Lexan yielded 

higher values than NTA. 

There is no correlation between the dose reported by Lexan and NTA; that is, 

high Lexan doses did not map to high NTA values. 

Based on these considerations, the primary personnel neutron monitor at the AGS 

was switched from NTA to Lexan in December 1987, but the NTA was retained 

for studies. [Emphasis added.]

Based on this information, it is recommended that the NTA results should be the 

dose of record for February. [Emphasis added.]

This information was sent by Carl Schopfer of BNL in a letter to Landauer, Inc., on May 5, 1988 

(Schopfer 1988)), expressing concerns with the “...unreliable response by the Lexan system” 

and the fact that BNL needed to be assured “...that the Lexan dosimeter system is under 

control...” As of yet, SC&A has not been able to locate documentation concerning the 

resolution of these problems. 
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1995 – On April 19, 1995, Miltenberger of BNL expresses his concern with not having the 

Lexan doses included in the total dose (Miltenberger 1995).

However, as the AGS has been operating at higher intensities (50 to 60 TP), the 

fact that the 1exan dose is not being recorded has evolved into a significant 

problem.

We believe that this situation needs to be corrected immediately by adding the 

three doses together. [Miltenberger 1995] Emphasis added.]

However, in a July 26, 1995, memorandum by Schaefer of BNL, he noted the following problem 

with the Lexan neutron detectors and recommended that it be discontinued (Schaefer 1995). 

A review of the AGS neutron dose equivalent results for the first five months of 

1995 as reported on the Landauer printouts shows that CR-39 responds with an 

overall sensitivity which is 7.4 times as great for AGS neutrons as Lexan. Given 

these results, and the fact that CR-39 has a reported sensitivity for fast neutrons 

which is an order of magnitude larger than Lexan, I strongly recommend the 

discontinuation of Lexan as the badge of record for neutrons, and the immediate 

implementation of CR-39 in its place. [Schaefer 1995, pg. 2-3] [Emphasis added.] 

Interviews with BNL health physics monitoring staff corroborated these documented concerns: 

The discrepancies were the most critical at the low level doses. There was a wide 

discrepancy between the NTA, CR-39, and the Lexan system. We could see 

disparity up to at least 150 mrem. As the dose increased, the disparity narrowed. 

In general, the CR-39 read lower for low dose. The stated LLD was frequently 

missed. There were numerous times these issues were brought to the attention of 

Landauer, but there wasn’t ever a consistent improvement. 

As can be seen from this brief snapshot of dosimetry problems, 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. 

The above-cited statements (as bolded for emphasis) illustrate that there were numerous 

recommendations to switch back and forth between neutron detectors for the dose of record. In 

summary, for nearly a decade (and perhaps longer), the reliability of the dosimeter system at 

BNL, especially for the accelerators areas, appears to have been in question, with numerous 

problems and with no single reliable neutron dose detector. Considering that these major 

problems existed during the 1980s–1990s era, a relatively recent period when radiation detectors 

were considerably advanced, then there is a good probability that prior doses of record did not 

account for all the neutron doses received. The problems with the neutron dosimetry were 

significant; they were not in the dose range of the lower limits of detection (LOD) or within the 

values of the + percent uncertainty. For example, in a 1986 BNL letter to Landauer (Schopfer 

1986), it is stated that identical NTA detectors placed side-by-side in the same location gave 

drastically different dose readings of “2,390 mrem” and “minimal;” and that CR-39 detectors 
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exposed under the same conditions gave completely different results of “340 mrem” and 

“minimal.” 

This brings up a very important question: What dosimeter was used for the dose of record 

during this period; and regardless of the type of dosimeter, how can the dose of record be 

considered to be accurate? Based on interviews with the BNL health physics personnel 

monitoring staff, the apparent policy at the time was to assign the highest dose to the dose of 

record from that measured by the CR-39 and TLD-6, respectively, as noted in the statement 

below: 

The process was to assign the highest dose to the dose of record. The CR-39 has 

a threshold of 500 keV. The TLD-6 would see the 500 keV and below. There was 

a memorandum generated telling them how to assign the dose. Sometimes you 

took the results from the CR-39 and the TLD. The Landauer badges had a Lexan 

portion and an NTA film portion to cover all energies. 

 

Another example is illustrated by the Miltenberger BNL memorandum of 1995 (pg. 7) 

(Miltenberger 1995), where the neutron dose is not included from the Lexan reading resulting in 

missing approximately 40% of the total (photon + neutron) AGS personnel dose for Jan–Feb 

1995 (i.e., missing 8,950 mrem Lexan out of a total of 8,950 Lexan + 12,620 mrem beta/gamma 

+ 1,000 mrem CR-39) and 90% of the total neutron dose (i.e., 8,950 mrem out of 8,950 + 1,000 

mrem). The BNL site profile did not mention these dosimetry problems, if they were solved, or 

make any recommendation on the use of the neutron dose records, given these significant issues.

Finding 9: Potential Exposures at Accelerators Not Sufficiently Covered 

High-energy accelerators, such as those at BNL, present the standard health physics problems, as 

well as often unexpected dosimetry challenges unique to each type of new accelerator. In the 

design and construction of new accelerators (especially in the early years before experience was 

gained and shielding calculation codes developed), there was a period of beam and dose 

measurements and construction changes before the machine was found acceptable for routine 

operation, both from an operational perspective and from a safety standpoint. After this initial 

phase, usually lasting several years, the machine began routine operations (in a general sense 

only, because an accelerator used for experiments does not have routine operating conditions like 

reactors or irradiators). This comes with an attendant increase in experimenter usage, 

accompanied by facility modifications, and sometimes increased beam current that requires 

additional shielding and sometimes creates potential exposure concerns. This state of 

operational flux creates a parallel challenge for the health physics program to address new 

challenges, and needed measurements, and procedures.2

 

2 These types of concerns are discussed in considerable detail in Health Physics Manual of Good Practices 

for Accelerator Facilities by W.R. Casey, A.J. Miller, J.B. McCaslin, and L.V. Coulson, SLAC--327, DE88-010816, 

Stanford University, Stanford, California, April 1988. 
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To assist in evaluating the dose monitoring techniques and doses of record for BNL personnel, a 

brief and general outline of some of the typical health physics issues that need to be addressed at 

accelerators are as follows: 

a. General work areas – After routine operations have settled in, exposure in the general 

working environment of an operating accelerator with adequate shielding is composed 

mostly of low Linear Energy Transfer (LET) radiation (photons, bremsstrahlung, and in a 

few cases, perhaps muons) with a Quality factor (QF) ~ 1.0, and low to mid-energy 

neutrons in the range of thermal to 20 MeV, with average energy around 1–5 MeV; 

usually having a higher LET, and hence QF > 1. This radiation exposure can generally 

be measured satisfactorily using photon film/TLD and neutron NTA film/TLD badges. 

Sometimes Lexan and/or CR-39 neutron detectors are added to the badges if there is a 

potential for higher energy neutron exposure. 

b. Experimental areas – However, in experimental areas, where the beam has been extracted 

from the main beamline, exposures can consist of high-energy radiation, such as protons, 

neutrons, heavier nuclear fragments, pi-mesons and K-mesons, high-energy electrons, 

bremsstrahlung, etc., resulting from cascades created by evaporation and spallation 

reactions of high-energy protons on a target in the main beamline, or in the extracted 

beamline. Personnel will most likely not be exposed to the charged particles outside the 

primary or secondary beamlines, because of the structural materials and shielding. 

However, if a person crosses, or looks into, a secondary beamline in an experimental area 

when the beam is on, large doses could result in a very short time (i.e., rad/sec), 

consisting of both low and high LET radiation. Dosimetry for persons potentially 

working around the experimental areas usually consists of some combination of 

NTA/TLD/Lexan/CR-39 neutron detectors to cover the wide spread of potential neutron 

energies. Generally, surveys with Bonner spheres (for examples, see Preisig 1992 and 

Preisig 1997) and threshold detectors (plastic scintillators, etc.) are used to obtain a 

measure of the neutron energy spectra and help determine the appropriate personnel 

monitoring device(s) and their calibration. Additionally, permanently mounted and 

portable neutron and gamma-ray survey instruments are used to measure area exposure 

levels (with live-time dose rate data fed back to the control room, in some cases). 

c. Extremity exposure – One of the most difficult doses to evaluate in this area is from an 

accidental exposure to a relatively small portion of the body in an operating secondary 

beamline. Unfortunately, badge readings are of little use in this situation because of their 

single location on the body and lack of calibration/response to the radiation components 

of the high-energy beam. 

d. Residual activation – One of the largest long-term exposure potentials for an established 

accelerator facility is the residual radiation fields (usually consisting of gammas and 

betas) resulting from activation of magnets, targets, beamstops, and structure materials. 

For example, the water-cooled target at the AGS reads >50 rem/[hr] at contact 

immediately after shutdown (ORAUT 2006, pg. 26). The dose rate usually decreases 

rapidly at first, in minutes/hours after shutdown, but then the remaining field decreases 
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more slowly. Delayed entries help to decrease accumulated doses, but use up valuable 

time. 

e. Skyshine – Distenfeld and Klemish, Jr. provided a general definition of air scatter, 

usually called skyshine, in a 1972 article: 

Neutrons emerging from the relatively thinner roof shielding of the heavily 

shielded biological enclosure radiate away from the ground. A large 

fraction of this population is energetically able to transfer energy to 

oxygen and nitrogen nuclei to cause an isotropic release of evaporation 

neutrons and protons. This neutron rain is termed skyshine. The 

evaporated neutrons and/or protons produce an energy spectrum that 

abruptly peaks about 1 to 2 MeV and tails down in energy to about 

10 MeV where the population approaches zero. The range in air of a 

10 MeV proton is about 150 mg/cm2

, or roughly 150 cm. Therefore the 

protons "inhabit" the immediate area of their formation while the neutrons 

have a much longer range. Skyshine is thus composed of neutrons above 

1 MeV. [Distenfeld and Klemish, Jr. 1972] 

Skyshine has the potential of creating exposures to persons located away from the 

immediate accelerator areas, including members of the general public, as well as 

accelerator personnel. 

f. Ground and entryway scatter – Usually the concrete shielding is not as thick in the floor 

as it is in the walls; therefore, radiation can penetrate the flooring and scatter off the 

lighter natural materials below the floor of the accelerator, creating ground scatter. 

Additionally, radiation can scatter out of the labyrinths used for personnel and utility 

entries. Usually this consists of soft neutrons and photons and is a diffused radiation 

source. Radiation from ground, building, roof, and equipment scatter often combines 

with skyshine to create somewhat of an isotopic external exposure field, which is 

sometimes difficult to characterize. 

g. Activated cooling water – High-energy proton beams can cause radioactive products in 

the flowing cooling water of the magnets, targets, and beamstops. This cooling water is 

generally piped outside to be cooled and then recirculated. This presents a potential 

exposure to workers during operations, and after shutdown for some of the radionuclides. 

Below is an example of some of the radionuclides created in cooling water at BNL 

(Casey 1975): 
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Table 1 

High Energy Proton Spallation Products in Water 

Isotope Cross section Half life 

Decay const. 

(sec) 

Production rate 

⎟

⎠

⎞ ⎜

⎝

⎛

− uA

mCi

sec

3

H 38 mb 12.3 y 1.7 × 10-9 9.1 × 10-6

7

Be 10 mb 53 day 1.58 × 10-6 2.1 × 10-3

10C 6 mb 27 sec 3.46 × 10-2 29.3 11Be 10 mb 19.6 s 3.54 × 10-2 49.9 11C 15 mb 20 min 5.78 × 10-4 1.2 13N 10 mb 10 min 1.15 × 10-3 2.4 15O 5.6 × 10-3 60 mb 2 min 47.4 

h. Activated air – Air can become radioactive from activation by high-energy 

protons/neutrons, especially in the experimental caves or other enclosed areas, and can be 

a source of exposure during operations and immediately after shutdown. The discharge 

stacks can emit radioactive air, which can be another source of exposure to workers, as 

well as the off-site population. Generally, activated air poses more of an internal dose, 

rather than an external dose hazard. 

i. Intense light sources – Intense light sources, such as the NSLS (National Synchrotron 

Light Source), accelerate electrons to high energies (in the GeV range) to produce intense 

x-ray, UV, and IR sources for experimental purposes. These high-energy x-rays create 

neutrons through photoneutron reactions, resulting in the usual photon and neutron 

radiation fields with wide spectra of energies outside of the shielding. Compared to other 

accelerators, electron accelerators used for intense light sources are relatively clean 

machines and more manageable from a health physics perspective, with some photon and 

neutron exposures. 

Note that neutrinos and antineutrinos are abundant at accelerators, but do not pose an exposure 

problem, because of their extremely low interaction probability with any type of matter. 

Considering these possible exposure areas, SC&A searched the BNL documents to determine 

conditions/situations where there may have been the potential for unreported or 

underreported exposures, dosimetry systems that did not match the radiation fields, and/or 

lack of correct monitoring methods because of unrecognized conditions at the time. These 

situations could lead to the dose of record not correctly reflecting the actual received dose. 

Potential areas of concern are as follows: 

a. Cosmotron 1953 – Cowan wrote the following in 1953: 

Compared with previous accelerators, the Cosmotron represents a major 

extension in energy and poses difficult problems in exposure measurement 

and evaluation. Only a start has been made toward solving these problems; 

in fact work along these lines will certainly continue for many years. (Cowan 

1953, pg. 6)
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b. Cosmotron 1952–1959 – The Cosmotron was an undershielded experimental facility in 

the beginning. The path and shielding of the beamline were not initially designed for 

sufficient protection of the accelerator workers, other BNL personnel, or those in the 

surrounding areas as it went through accelerator, the workplace, and across the 

countryside (Cowan 1965, pp. 3 and 4). 

c. AGS 1963 – Cowan, Phillips, and King states the following: 

Evaluation of radiation hazards at GEV proton synchrotrons such as the 

Brookhaven AGS is difficult since the composition of the mixed radiation 

fields varies widely depending on location, and substantial high-energy 

components are often present. In addition, the machines are usually pulsed 

and very large work areas are involved (Cowan et al. 1963, pg. 5). 

Shortly after the Alternating Gradient Synchrotron commenced operation, it 

was found that a considerable flux of mu-mesons was penetrating 16 feet of 

heavy concrete and emerging into the experimental area. We were then faced 

with determining whether dosage due to this flux was being properly 

evaluated, particularly since high energy muons are minimum ionizing 

particles and the NTA film used for personnel monitoring doesn't record 

tracks due to such particles (pg. 10). 

Since beam intensities of 6 × 1011 protons per pulse are now obtained, we 

have dose rates up to 1000 mrad/hr in the exclusion area and 1 to 10 mrad/hr 

over a considerable portion of the adjacent work area...The mu-mesons are 

mostly minimum ionizing particles for which a QF of 1 is appropriate (pg. 

11). 

d. AGS 1965 – Cowan states the following in a 1965 paper: 

Exposure control at the AGS has become increasingly difficult as a result of 

increased intensity and multiplication of facilities. Locations of Health 

Physics interest are the experimental halls including an area where mu-meson 

dosage predominates, the accelerator ring where dosages during shutdown 

are presently a major problem, the linac injector, the 80" bubble chamber, 

and the southwest or neutrino experiment area, as well as nearby areas and 

buildings. A major rebuilding of the AGS is anticipated. (Cowan 1965, pg. 3)

e. 1980s–1990s dosimetry at accelerators – As indicated earlier in previous findings, there 

is a lack of dosimetry consistency in the BNL accelerator areas (especially for neutron 

exposures). The site profile does not address these problem areas or indicate for what 

time periods they were prevalent, what dose values were used for the dose of records, if 

the problems were resolved, or make any recommendations for dose reconstruction 

concerning these issues. 
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f. RHIC – Originally named “Isabelle” (Intersecting Storage Accelerator), later called the 

Colliding Beam Accelerator (CBA), and still later built and operated (starting in 2000) as 

RHIC (Relativity Heavy Ion Collider). Because of its large diameter, the RHIC is a 

“thinly” shielded accelerator at some points, and heavily shielded (including muon 

shielding lobes) at the intersecting points of the two counter-circulating proton beams 

(Gollon and Casey 1984). While the health physics concerns at the RHIC are similar to 

other high-energy accelerators, there are several unique issues. These concerns include 

routine beam losses and the possibility of a catastrophic beam loss. As stated by Gollon 

and Casey (pg. 3), “The energy and intensity of the stored proton beams play a dominant 

role in determining the extent of the prompt radiation hazard.” Therefore, not only are 

the standard HP concerns (i.e., prompt and residual radiation) present, but there is the 

potential for the loss of a large amount of stored beam. The maximum beam loss at linear 

or circular particles accelerators, without storage capability, is limited by the injection 

rate. However, at a beam storage facility, such as the RHIC, the injected beam can be 

accumulated for up to 24 hours or more, resulting in very large amounts of energy that 

can be instantaneously lost in a catastrophic event creating large, short-term, radiation 

fields. According to Gollon and Casey (pg. 7), a 20% circulating beam loss could result 

in a radiation field equal to 5 months of radiation doses from normal operations. The 

high energy of the RHIC also creates forward-directed muons fields that are not normally 

prevalent at other accelerators. These operating parameters create potentially unique 

health physics problems at the RHIC and corresponding dosimetry challenges. 

g. Uncommon types of radiation – 

• Spallation products: Page 91 of ORAUT 2006 mentions spallation products and 

the fact that the doses from them were small. Spallation products resulting from 

the breaking apart of nuclei by high-energy particles are highly unlikely outside of 

heavy shielding or secondary beamlines, because the spallation products are 

highly charged. The cascades of radiation resulting from the spallation/ 

evaporation reactions of the proton beam can be encountered outside the 

beamlines, but generally not the spallation products themselves. Perhaps what 

was being referenced by the site profile is the fact that high-energy particles can 

cause stars (a type of spallation) in emulsions such as are used in NTA film. 

Cowan 1953 (pg. 34) states, “It should be noted that when stars are observed in 

the emulsion, each prong is counted as a track. This practice takes some account 

of the large amount of energy released in such events.” However, this article was 

written in 1953 at the beginning of the operations of the Cosmotron, and a 

complete reading of the document indicates that there were still a lot of 

unanswered questions concerning the dosimetry of high-energy radiation. At that 

time, they were mainly concerned with having a large enough dose-to-dose 

equivalent conversion factor [Radiological Biological Effectiveness (RBE), or 

later, the Quality Factor (QF)] to not exceed the regulatory dose limits (this was 

sometimes called a “Safety factor”). The subject of prong counting, what caused 

them, their conversion to dose, and their significances in the doses of record need 
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elaboration in the site profile to enable the dose reconstructor to correctly interpret 

the neutron entries in the doses of record. 

• Muons – Although pi-mesons (272 times the mass of an electron) resulting from 

the spallation reactions of high-energy protons on material do not usually exist in 

the occupied areas around an accelerator, their decay product, muons (previously 

called mu-mesons), with a mass 207 times the mass of an electron, can exist 

outside heavy shielding, because of their penetrating power (resulting from their 

lack of Bremsstrahlung emission, because of their large mass compared to 

electrons). The BNL AGS was one of the first proton accelerators in which 

muons would dominate the radiation concerns (Patterson and Thomas 1973, 

pg. 146). This is supported by a statement by Cowan in 1963: 

There is one area at the Alternating Gradient Synchrotron (AGS) 

which is extremely interesting from the dosimetric point of view. This 

is an area where a flux of mesons, with attendant secondaries, 

emerges from a 16-ft thick heavy concrete shield (see Figure 1) and 

results in substantial dose rates (Cowan 1963, pg. 5). 

Muons exposures and dosimetry were not addressed in the site profile. 

• High energy protons – Although high-energy protons do not normally exist 

outside the shielding, they can be present in the experimental areas where 

beamlines emerge. In earlier years, sometimes personnel were present in these 

experimental areas and could accidentally be exposed to radiation from the 

beamline, or in an experimental cave (see Merkle 1952 for an incident in 1952 at 

BNL). In more recent years, accidental exposures may result from an 

experimenter assuming that a beamline is off, when it is actually on (see 

Distenfeld 1970 for a 1970 incident at BNL). These types of exposures are 

hazardous because of the large instantaneous doses that can be received, i.e., 

580 rad/pulse in a 1-in diameter focused beam (Cowan 1960, pg. 3). Other 

factors include the fact that the beamlines are generally at chest or head level, the 

beam area is small compared to the whole body, and a monitoring badge most 

likely will not be in direct line of the beam exposure and not necessarily 

calibrated to the radiation components/energies of the radiation contained in the 

beamline. Additionally, there is a tendency to sight down a beamline during 

experimental setups, and if the beamline is accidentally on, this can lead to 

exposures that can greatly increase the probability of eye cataracts (Cowan 1960, 

pg. 3). The site profile did not cover the potential for high-energy proton (and 

accompanying radiation byproducts) exposures, any incidents of these exposures, 

or the dosimetry/dose assignments associated with such exposures. 

As can be seen from this brief summary, there are many situations at high-energy accelerators 

that have the potential for unconventional exposures leading to unrecorded or under-recorded 

doses. The current BNL site profile does not address key dosimetry problems associated with 
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high-energy accelerators, the adequacy of dosimetry systems during start-up periods, or if the 

dosimetry systems were sufficiently encompassing to accommodate operational changes. The 

site profile, likewise, does not discuss adjustment factors for neutron doses and if adjustments are 

needed to compensate for the limitations of the dosimetry systems used as a function of time at 

different accelerator facilities (as illustrated in a discussion in this report concerning problems 

with NTA/TLD/Lexan/CR-39 neutron dosimetry systems). The site profile does not address if or 

where or when muon doses were of health physics concern, or how and if they were monitored 

and recorded, and the interpretation of those doses, if recorded. Hazards from extracted highenergy proton beams and their dosimetry were also not addressed. The main body of the 

Occupational External Dosimetry section of ORAUT-TKBS-0048 (ORAUT 2006) consists of 

only six pages; this obviously cannot contain sufficient information to cover the important 

aspects of dosimetry at the many diverse BNL facilities for an operating period of approximately 

60 years. Such a limited space could not cover the many health physics aspects of accelerator 

dosimetry (a few of which are outlined above), in addition to those of reactors, isotope 

production, medical research, hot cells, the NSLS, and other facilities with potential radiation 

exposures at the BNL. 

Finding 10: External Coworker Dose Data Not Addressed 

 

Section 6 of the site profile did not address or provide any coworker data for use in assigning 

external doses to workers who should have been monitored, but were not. Coworker data is 

needed in cases where the worker had the potential to receive greater than environmental doses, 

but by the criteria of the time, was not considered a radiation worker and was not badged, or the 

monitoring results cannot be located. In a dose reconstruction report that SC&A recently audited 

it was found that the dose reconstructor needed external coworker dose data for BNL to perform 

the dose reconstruction, because the worker was potentially exposed but not monitored. In this 

case, the dose reconstructor was required to use data derived from studies performed for other 

DOE sites to complete the dose reconstruction. 

This indicates that external coworker dose data are needed, but not present, in the BNL site 

profile. 

Finding 11: Incidents and Unanticipated Events Not Addressed 

The site profile does not sufficiently address incidents or unusual events that could affect 

external dose reconstruction. Some examples of incidents available in the BNL documents are 

listed below: 

• Several incidents of persons being in the experiment caves/areas when the beam was on 

were reported: 

o A person was trapped in an experimental cave with the beam on at the Cosmotron in 

1952 (Merkle 1952). 

o A person was working near a beam stop with beam on in 1970 (Distenfeld 1970). 

o Two operators were trapped inside an experimental area in 1988 (Rohrig 1988). 
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• Potential exposures outside of controlled areas could have exposed unmonitored workers, 

such as stated by Musolino in a BNL 1987 memorandum (Musolino 1987): 

Twice in May excessive beam losses caused high radiation levels in 

uncontrolled areas. Up to 1200 mrem/hr and 125 mrem/hr were present due 

to transport losses in the A and D lines respectively. In both cases, the losses 

were not anticipated and were found during the S&EP daily survey. Also, 

both times isolated thin shielding contributed to the problem. [Emphasis 

added.] 

• A number of potential exposure incidents (which resulted in both internal doses and 

external doses) that took place during 1950–1967 were described in BNL (1967); most of 

them were concerned with the BGRR. These incidents could have exposed unmonitored, 

or sporadically monitored, workers without their doses being recorded. 

With respect to unplanned environmental releases, BNL 1967 provides a list of incidents for 

1950–1967, mostly concerned with the BPRR, which could lead to environmental doses to 

unmonitored workers. The following is reproduced from BNL 1967, page 5: 

BUILDING MONTH YEAR REFERENCE LOCATION/ROOM ID ITEM ACTIVITY/OCCURENCE 

7/01/703 5 1956 BGRR Health Physics 

Logbook # 2 (5/1/56 – 

6/11/58) 

bldg 703 – front yard: 

old drainage line 

rad 

activity

Rad levels could be seen on the old drainage ditch and pipe line 

through 3 foot of earth. Rad levels could also be detected through 

the ground covering as far as the road in front of the reactor. 

These types of incidents/records should be taken into consideration when evaluating 

occupational environmental doses, especially to unbadged personnel. The present site profile 

does not address any specific environmental-related incidents and their impact on external doses 

to unmonitored workers. 

Finding 12: Potential Environmental Exposures from Igloo Area Not Addressed 

Nothing is mentioned in Section 4 of the site profile concerning the Igloo storage area in the 

Hazardous Waste Management Facility and its impact on localized environmental doses. In 

1992, this was of concern to workers in the area and perhaps outside the area, considering that 

dose rates and skyshine were addressed in a BNL memorandum by Karr (1992), which indicated 

items in the Igloo area had readings of greater than 100 mrem/hr, and that skyshine was of 

concern and needed to be reduced. Attachment 4 of that article indicates that dose rates outside 

the fence could range as high as 200 microR/hr, equivalent to 400 mrem/yr for 2,000 hr/yr 

occupancy. This exceeds the assumed maximum public dose limit of 100 mrem/yr, as stated in 

Section 4.4.1 and Table 4-1 for the period 1967–present. Average yearly site parameter 

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 waste facility areas. 
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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, page 50, states that BNL had machines capable of photofluoroscopic/ 

fluoroscopic exams in 1951 and 1960, but also 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 the reasons to conclude that 

only the diagnostic unit was used routinely for examinations. SC&A located the Brodsky 

document and found it difficult to read, because it was the minutes of a long meeting and lacked 

clarity and continuity, along with many missing/incorrect words; however, SC&A read and 

performed keyword searches on this document and did not locate any statements indicating that 

photofluoroscopic/fluoroscopy exams were not performed at BNL. Statements concerning x-ray 

units and resulting doses were found on pages 35 and 36, but these do not necessarily eliminate 

the occurrence of photofluoroscopic (PFG) exams. It would be helpful to have the page number 

in the Brodsky document that the authors of the site profile used to reach the conclusion that 

PFG exams were not conducted; and hopefully at least one official reference besides these 

meeting notes to support this claim. 

Furthermore, Sunderman (1947) summarized the health program used for BNL employees 

effective September 1947. The medical department at BNL was activated as of July 1, 1947, and 

based its examination program on those that were in operation at other Atomic Energy 

Commission laboratories at the time. 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, A-P and lateral 

roentgenograms of the spine and roentgenogram of one forearm.” During Health Maintenance 

exams of employees, an annual fluororoentgenogram of the chest was completed. There were 

special examinations for workers exposed to special hazards, such as estimations of uranium in 

urine for those exposed to uranium. Radon breath analysis was completed on workers handling 

radium. Complete records of exposure to radioactive materials were collected as a part of the 

exam. Employee termination exams included “fluororoentgenograms of the chest, A-P and 

lateral roentgenograms of the spine and roentgenogram of one forearm” (Sunderman 1947). 

The site profile mentions lumbar spine x-rays on page 52 of the site profile, although Tables 3-1 

through 3-4 are limited to 14-in by 17-in PA and lateral chest radiography. The statement by 

Sunderman (1947) contradicts the statement that PA chest PFG, AP lumbar spine, and lateral 

lumbar spine exams were unlikely. In addition, on page 55 of the site profile, it is assumed that 

any radiograph that was not a PA chest or LAT chest was diagnostic and should not be included 

in dose reconstruction. The lumbar spine and forearm x-rays were required during the preemployment and termination exams, and should not be excused as diagnostic exams. 

In summary, the site profile has failed to consider pertinent information on the number and types 

of exams required as a condition of employment. Further investigation of medical exam protocol 
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is warranted. Dose assignments for PFG exams should reflect the assumptions in ORAUT 2005c 

and ORAUT 2004b, unless site-specific data suggest more claimant-favorable assumptions. 

3.1 SECONDARY FINDINGS 

Finding 14: Section 4 Table 4-1 Values Need Further Development 

The external gamma doses listed in Table 4-1, page 63, of the site profile are recommended for 

use in assigning ambient dose to unmonitored workers. It is not obvious how these values were 

obtained, or if they are applicable for that use. To illustrate, in terms of time periods: 

• 1947–1949 – Meinhold and Meinhold (2001) state on page 9 that the activities for 1947 

were mostly organizational. Therefore, it can be assumed that the ambient external doses 

were near zero, as listed in Table 4-1 of the site profile. However, there has been no 

documentation found to support zero doses for 1948 and 1949 as they are listed in 

Table 4-1 of the site profile. The only reference for this period is in the footnotes to 

Table 4-1, where it is stated that, “Data prior to 1950 are assumed based on site activities 

in those years.” 

• 1950–1965 – The document by Meinhold and Meinhold (2001) contains a discussion of 

external environmental doses on pages 61–63 (includes Table 6) and pages 97–98 

(includes Tables IA-5 through IA-8). The values in these tables do not match those listed 

in Table 4-1 of ORAU 2006. For example, Table IA-5 lists the Boundary Stations 

average as 24 mR/year and the maximum as 46 mR/year for 1959, but Table 4-1 of the 

site profile lists an average of 27 mrem/y and a maximum of 39 mrem/y for 1959; most 

of the values for the other years could not be reconciled either. Note that taking 23% of 

the Monitoring Stations values (see the issue with 2,000 hours/year addressed below) 

would not correct this situation, but would only make it worse. 

• 1967–present: Monitoring results – ORAU 2006, page 62, Section 4.1, states the 

following: 

Monitoring results from up to four onsite stations are available for some 

years between 1967 and 1984. When available, these data are included in 

the average dose estimates. Beginning in 1985, the perimeter and onsite 

monitoring program was expanded to approximately 20 onsite stations

and has steadily increased to over 50 onsite stations as of 2004. 

[Emphasis added.] 

These statements indicate that there are onsite monitoring results available, and that some 

“are included...” However, in Section 4.4.1, page 62, it recommends using the public 

dose limit of 100 mrem/yr, because the “on-site monitoring results were no longer 

reported...” This appears to be a contradiction. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

• 1967–present: Use of 100 mrem/yr – For this period, the site profile recommends the use 

of 100 mrem/year ambient dose, because this was the public exposure limit, and had only 

been exceeded once in prior years. During this period, BNL may have limited the dose at 

the boundary, so that no member of the public would receive greater than 100 mrem/year; 

however, this does not necessarily mean that areas within the site fence could not exceed 

100 mrem/year. Therefore, it is not clear how the site boundary average doses for the 

public can be used to assign unmonitored on-site workers’ doses (who could be closer to 

the radiation areas), and furthermore, to consider it a limiting (maximum) value. 

• Issue of 2,000 hrs/yr – The site profile states on page 62 that the values in Table 4-1 have 

been adjusted to reflect 2,000 hours per year occupancy. However, if this is true, the 

values in the table would be only about 23% (2,000/(365 × 24) = 0.23) of the 

environmental station values (if the reported station values were for 24/7 sampling), and 

the value for 1967–present would only be 100 mrem/year × 0.23 = 23 mrem/year, instead 

of 100 mrem/year. 

It appears that the data used in Table 4-1 on page 63 of the site profile need further development 

and/or clarification to support its recommendations. 

Finding 15: Onsite Wells 

Page 68 of the site profile states that potable water from onsite wells was used, but that no 

ingestion of radionuclides by this path was found. The site profile needs to address the tritium 

leak from the HFBR in the contents of the wells (i.e., whether they were tested and found to not 

contain tritium, their present status, etc.). 

Finding 16: Non-Penetrating (NP) Included in Whole-Body Dose 

Table 6-4 on page 94 of the site profile contains a summary of recorded dose practices. The 

third column, rows 2 and 3, states that the whole-body (WB) dose = nonpenetrating (NP) + 

photon (P) + fast neutron (FN) + tritium. However, using the generally accepted definition of 

these terms (and supported by the site profile’s definition of these terms in the Glossary on pages 

100–106), WB dose is the dose at a depth of 10 millimeters and NP dose is from beta and lower 

energy photons; therefore, it appears that the NP dose should not be included in determining the 

WB dose. 

Finding 17: Adjustments to Recorded Dose Not Supported 

An adjustment to the photon dose of 10% is recommended on page 95 of the site profile to 

compensate for penetrating low-energy photon doses not accounted for. It is only stated that, “It 

is estimated that a correction equal to 10% of the <250-kev values be made.” No supporting 

documentation is provided for this recommended adjustment factor. Additionally, SC&A could 

not locate the statement that most of the photons at the NSLS facility are below 250 keV, and 

that measurements indicate a peak at 75 keV in the reference listed in the site profile, which is 

Preisig 1997. SC&A did find a statement in Sengupta 2000 (pg. 23) that reads, “Measurements 
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of NSLS indicate a photon peak about 75 KeV.” However, no reference to the statement that 

photons are <250 keV at the NSLS was made. 

Finding 18: Potential Exposures at LMFR Research and Development Facility Not 

Addressed 

There were three operating reactors at BNL, plus an experimental liquid-metal fuel reactor 

(LMFR) research and development (R&D) facility (not actually a reactor, but an experimental 

sodium loop). The site profile provides some information concerning the design, operations, 

fuels, radioisotopes, radiation fields, etc., of the three major reactors; the BGRR (Brookhaven 

Graphite Research Reactor), the HFBR (High Flux Beam Reactor), and the BMRR (Brookhaven 

Medical Research Reactor). It also mentioned the LMFR on page 35 as a support and R&D 

facility: 

Research and Development on Liquid Metal Fuel Reactor (LMFR) technology 

took place in Building 820 from 1957 to 1975. A simulated reactor with a core of 

uranium dissolved in bismuth was studied. 

However, this is all the information provided. There is no information concerning the 

amount/types/chemistry of uranium present; the design and components of the core; if critical 

masses were present; internal, external, and contamination radiation hazards; number of workers 

involved; etc. To date, SC&A has not been able to locate any relevant documents on the Site 

Research Data Base (SRDB) or the BNL website concerning the LMFR. SC&A did locate some 

BNL Nuclear Engineering Department LMFR reports for 1957, but they were mostly concerned 

with engineering designs, not radiation hazards. More information is needed on the LMFR 

facility to allow the dose reconstructor to properly assign dose to claimants who worked there, 

which could have been a significant portion of their employment period (up to 19 years). 

Finding 19: Human Radiation Experiments 

Human Radiation Experiments were conducted at BNL from 1950 through 1976. Radiation 

experiments included total body irradiation, neutron beam exposures, and in-vitro exposures to 

H-3, tritiated thymidine, C-14, Na-24, Mg-28, Cl-38, K-42, Sc-46, Ca-47, Cr-51, Mn-54, Co-57, 

Co-58, Co-60, Fe-59, Zn-65, Ga-72, Kr-79, Br-82, Sr-85, Tc-99m, I-123, I-124, I-131, Xe-127, 

and Cs-137 (DOE 1995). Although a majority of these studies involved individuals not 

employed at BNL, there were BNL workers who voluntarily participated in tracer study 

experiments. Information on the exposure of BNL employees who participated in human 

radiation experiments is not currently provided to NIOSH. Information on exposures of this type 

is typically maintained separate from the medical and radiological files maintained by 

researchers. Worker participation in human radiation experiments requires further investigation 

to determine the number of claimants affected. Any files containing additional information on 

radiation exposures should be requested by NIOSH as a part of the claimant response. 
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3.1.1 Factual or Editorial Observations 

Occupational Medical Dose (Section 3) 

Section 3 references not available on SRDB 

• NCRP Report No. 102 is listed in the Reference list, page 61, as being in the SRDB 

[Ref ID 126], but it is not on the SRDB. 

• ICRP Publication 34 is listed in the Reference list, page 61, as being in the SRDB 

[Ref ID 107], but it is not on the SRDB. 

Decreased AF by 10% not documented in Section 3 

On page 54, it is stated that the absorption factor (AF) was decreased by 10%; while this 

is claimant favorable, there is no readily apparent support in the site profile for this 

decrease. 

Environmental Dose (Section 4) 

Section 4 clarifications needed and reference not listed 

• The second paragraph in Section 4.5.2, page 64, is confusing or contains a repeat of 

the first part of the paragraph in the second half of the paragraph. This needs to be 

corrected/clarified. 

• The reference (NIOSH 2002, pp. 15–16) listed at the end of page 64 is not listed in 

the Section 4 Reference list (but is listed on page 89 of the Section 5 Reference list). 

Internal Dose (Section 5) 

 Water intake conflict 

Uncertainty in “average water intake” is listed as a variable in Section 4.7 on page 68; 

however, in Section 4.6, it is stated that water is not a pathway for intake. This is an 

apparent conflict. 

External Dose (Section 6) 

• On page 92 of the site profile, an incorrect reference date is listed in the second sentence, 

(it should be Patterson 1994, not 1964). 

• On page 92, Section 6.5, of the site profile in the first paragraph, the last sentence should 

read “It appears that all radiation workers were...” to be consistent with Section 6.5.1, 

first paragraph, last sentence where it reads “All radiation workers were....” 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

• On page 92 of the site profile in the last paragraph, the term “Missed doses...” is the 

incorrect term to use here, in view of NIOSH’s standard use of the term missed dose to 

mean doses that are too low to be detected by the dosimeter. The lack of recorded dose 

for unmonitored employees should be called unmonitored dose, not missed dose. By 

definition, a worker cannot have a missed dose if the worker was not wearing a 

dosimeter. 

• Page 94 of the site profile contains Table 6-3. This table is busy and confusing and needs 

to be redone. For example, the neutron energy (MeV) column contains weighting factors 

also. The fourth column, row 3, contains two 100% default dose neutron energy ranges; 

this does not make sense. The fourth column, row 4, contains too much information. 

This table needs more columns and rows to allow for only one entry per cell. The 

footnotes need to contain more explanations and references for the derivation/source of 

the weighting and correction factors; i.e., ICRP-60, Quality Factor (QF), resulting 

correction factors, etc. 

• Page 94 of the site profile contains the statement, “Recorded neutron doses include both 

thermal and fast neutrons generated by the various accelerators with energies >100 MeV 

...” This could be interpreted to mean that if the accelerators had energies less than 

100 MeV, neutron doses were not recorded. This statement needs to be reworded for 

clarification. 

• On page 94 of the site profile, the footnote to Table 6-4 states that Harshaw 8806 TLDs 

are issued only when higher energy neutrons might be present. This statement may refer 

to CR-39, because a neutron TLD has a higher response at lower energies and CR-39 has 

a higher response at high neutron energies. This needs to be reviewed for technical 

correctness and clarified. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

4.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for a “vertical” assessment of a site profile for purposes of evaluation 

of specific issues of adequacy and completeness, as well as a “horizontal” assessment pertaining 

to how the profile satisfies its intended purpose and scope. This section addresses the latter 

objective in a summary manner by evaluating (1) how, and to what extent, the site profile 

satisfies the five objectives defined by the Advisory Board for ascertaining adequacy; (2) the 

usability of the site profile for its intended purpose, i.e., to provide a generalized technical 

resource for the dose reconstructor when individual dose records are unavailable; and (3) generic 

technical or policy issues that transcend any single site profile that need to be addressed by the 

Advisory Board and NIOSH. 

4.1 SATISFYING THE FIVE OBJECTIVES 

The SC&A review procedures, as approved by the Advisory Board, require that each site profile 

be evaluated against five measures of adequacy—completeness of data sources, technical 

accuracy, adequacy of data, site profile consistency, and regulatory compliance. The SC&A 

review found that the NIOSH Summary Site Profile for BNL falls considerably short in 

providing the dose reconstructor with key information related to bioassay records, neutron 

dosimetry issues, accelerator program history, and assessing unmonitored worker dose. 

Section 1.1 summarizes the key issues. A detailed evaluation of these issues can be found in 

Section 3.0 (Vertical Issues) of this report. 

 

4.1.1 Objective 1: Completeness of Data Sources 

The breadth of data sources used as a basis for the BNL Summary Site Profile is evident in the 

number of reports available in the SRDB, as well as in the number of reports cited in the site 

profile references. Oak Ridge Associated Universities Team’s (ORAUT) use of the available 

sources indicates an understanding of site operations, radionuclide usage, and personnel 

monitoring data. 

However, for internal dose assessment, the site profile fails to address the adequacy and 

completeness of BNL bioassay data to support dose reconstruction. From a preliminary review 

of available BNL records and interviews with BNL health physics staff members, there is 

sufficient reason to question the completeness, accuracy, and accessibility of bioassay records for 

BNL from the late 1940s through the mid-1980s, or perhaps into the mid-1990s, when the 

centralized electronic HPRS recordkeeping system became operational. 

4.1.2 Objective 2: Technical Accuracy 

In general, the BNL Summary Site Profile favorably reflects the depth of knowledge and 

technical understanding of the various authors and experts who developed the documents. The 

analyses and recommendations are generally consistent with NIOSH guidance and the available 

data from the site. Some exceptions are noted below. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

As stated in Section 5.10 of the site profile, 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 applies to Table 2-2 also. Also, interviews 

with BNL workers indicate that Tables 2-2 and 2-3 do not correctly reflect the radioisotopes 

present at some of the BNL facilities. 

4.1.3 Objective 3: Adequacy of Data 

The present BNL Summary Site Profile document does not address key dosimetry problems 

associated with high-energy accelerators, the adequacy of dosimetry systems during start-up 

periods, or if the dosimetry systems were sufficiently encompassing to accommodate operational 

changes. It does not discuss adjustment factors for neutron doses and if adjustments are needed 

to compensate for the limitations of the dosimetry systems used as a function of time at different 

accelerator facilities (as illustrated in a discussion in this report concerning problems with 

NTA/TLD/Lexan/CR-39 neutron dosimetry systems). The site profile does not address if or 

where or when muon doses were of health physics concern, or how and if they were monitored 

and recorded, and the interpretation of those doses, if recorded. Hazards from extracted highenergy proton beams and their dosimetry were also not addressed. 

The site profile does not specifically address the subject of NTA film threshold, nor directly 

address the issue of NTA film fading. 

In addition to the MDA values for common radioisotopes, the MDA values for, or procedure for 

identifying, other less common (but potentially present) radioisotopes should be provided, so that 

the dose reconstructor can consider and assign missed dose in specific cases where other 

radioisotopes could be present. For example, one can compare the relatively few radioisotopes, 

and associated time periods listed in Table 5-3, page 80, that the dose reconstructor has to work 

with, with the many radioisotopes listed in Tables 2-2, 2-3, and 5-5 occurring over more than a 

50-year period. Some MDA values are obtainable from BNL documents, one example from 

Miltenberger (1978) being the BNL WBC MDL for U-235, which was 800 pCi (370 ug) in 1978. 

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

the bioassay reporting period from the 1950s–1990s. 

 

The site profile does not mention the availability or applicability of coworker internal or external 

dose data. Therefore, the dose reconstructor is not provided with any recommendations 

concerning what doses to assign when a worker’s information indicates that the worker should 

have been monitored, but was not, or where bioassay records are unavailable. 

No background information is provided for D&D workers at BNL that would be important for 

dose reconstruction, such as the following: 

• Were these BNL employees or outside contractors? 
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• Were the bioassay monitoring requirements the same, or different, than those of regular 

BNL employees? 

• Was cohort or individual sampling performed? 

• What types of bioassays were performed? 

• Where are the bioassay records located and are they accessible? 

More information is needed for the D&D worker bioassay program to adequately support 

accurate and complete dose reconstruction for that activity. 

4.1.4 Objective 4: Consistency among Site Profiles 

SC&A compared the guidance, proposed methods, and information base provided in the BNL 

Summary Site Profile with site profiles for other national laboratories and found some disparities 

of note, as follows. 

Dosimetry information and dose estimation guidance typically provided for early neutron doses, 

i.e., the NTA film energy threshold and NTA film track fading, is lacking in the BNL Summary 

Site Profile. 

The provision of coworker dose data and methods that are provided for sites where unmonitored 

worker exposure has been established (which is most evident for internal exposures at BNL, but 

also in some external exposure cases) is lacking in the case of the BNL site profile. 

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 1940s–1990s, such as is found in some of the other DOE site profiles [i.e., ORAUT-TKBS0012-5 (ORAUT 2007), Table 5-9, pg. 16]. 

The site profile does not sufficiently address incidents or unusual events that could affect 

external dose reconstruction, as is typically done in other site profiles. Some examples of 

incidents were found in the BNL documents; however, the site profile did not address such 

incidents or if the doses of record were correct under these exposure conditions. 

4.1.5 Objective 5: Regulatory Compliance 

SC&A reviewed the site profile with respect to Objective 5, which requires SC&A to evaluate 

the degree to which the site profile complies with stated policy and directives contained in 

42 CFR 82. In addition, SC&A evaluated the site profile for adherence to general Quality 

Assurance policies and procedures utilized for the performance of dose reconstructions. No 

issues were found in this regard that require attention, albeit, SC&A has raised questions 

regarding the validity of the neutron adjustment factors used in dose reconstruction, as well as 

other questions surrounding neutron dosimetry at BNL. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

5.0 REFERENCES 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT: SUMMARY OF SITE EXPERT INTERVIEWS 

(To be provided)