DISCLAIMER: This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A, for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its Working Groups 

or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working documents 

are not final NIOSH or ABRWH products or positions, unless specifically marked as such. This document prepared 

by SC&A represents its preliminary evaluation on technical issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

MEMORANDUM

TO: Argonne National Laboratory – East Work Group 

FROM: SC&A, Inc.

DATE: October 24, 2018 

SUBJECT: Update: ANL-E Site Profile Finding 12 

Introduction and Background 

The current edition of the Argonne National Laboratory – East (ANL-E) site profile technical 

basis document (TBD) for environmental dose is ORAUT-TKBS-0036-4, Revision 00, Argonne 

National Laboratory – East – Occupational Environmental Dose (NIOSH 2006). 

SC&A issued a review of the ANL-E TBDs in 2009 (SC&A 2009) and an updated report in 2016 

(SC&A 2016). SC&A entered the ANL-E site profile primary findings into the Board Review 

System in February 2017. 

During the June 27, 2018, ANL-E Work Group meeting, the chair of the Work Group tasked 

SC&A with drafting a memo to discuss information for the clarification and potential resolution 

of Finding 12: “Outdoor Inhalation Exposures Associated with Waste Disposal Operations in 

Area A and from Particulates Released during Accidents are Not Adequately Addressed” (SC&A 

2009, p. 22).

SC&A analyzed Finding 12 and requested that the National Institute for Occupational Safety and 

Health (NIOSH) provide additional information to address the finding. This memorandum is a 

summary of the relevant information obtained from NIOSH’s recent response (NIOSH 2018) and

SC&A’s current analyses of Finding 12. 

Summary of Finding 12 

A detailed description of SC&A’s original concerns expressed in Finding 12 is provided on 

pages 49 and 50 of SC&A’s original review (SC&A 2009). The first paragraph addressed

environment intakes for Area A, and the second paragraph addressed environmental intakes for 

ANL-E for the period through 1953. 

Area A Environmental Intakes

In SC&A’s 2009 review (SC&A 2009), SC&A found that NIOSH’s chronic environmental 

intake recommendations for Area A were reasonable. However, SC&A raised the issue of 

potential acute intakes from incidents and accidents for which long-term environmental analyses 

may not have indicated individual events. 
Memo – ANL-E Finding 12 2 SC&A – October 24, 2018 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

ANL-E Environmental Intakes 

In SC&A’s 2009 review (SC&A 2009), SC&A found that NIOSH’s chronic environmental 

intake recommendations for ANL-E were reasonable. However, SC&A raised the issue of 

potential acute intakes from incidents and accidents for which long-term environmental analyses 

may not have indicated individual events. 

NIOSH’s Response of September 25, 2018 

NIOSH provided a response to the ANL-E Work Group’s request for clarification on 

September 25, 2018. NIOSH addressed the following two areas (NIOSH 2018, p. 1): 

1. Potential for short-term (acute) inhalation exposures, including particulates, 

due to accidents associated with waste disposal operations at Site A and 

Plot M. 

2. Potential for short-term (acute) releases due to accidents at ANL-E during the 

entire covered period.

NIOSH provided a four-page discussion of the issues, with Site Research Database (SRDB) 

references, and a summary/conclusion that consisted of the following: 

As a reminder: this finding is specific to environmental internal doses and a 

summary for how incidents and accidents are addressed; for individuals on 

routine bioassay monitoring, intakes from such incidents would be accounted for 

in the bioassay sampling. 

To date, no record of short-term, large exposure events, which would significantly 

affect environmental monitoring data have been identified in SRDB documents, 

even with the level of detail found in the records for Site A and Plot M. Based on 

the documented ANL-E practices at Site A and Plot M, it is reasonable to assume 

that individuals not participating in the routine bioassay monitoring program or 

involved in an incident would not have been exposed to short-term, large 

exposure events, and that assignment of environmental levels of intake would be 

appropriate. Even if unidentified incidents occurred (which would have 

contributed to measured environmental results), NIOSH’s approach to 

calculating intakes from environmental monitoring yields reasonable internal 

dose estimates.

Additional discussion in the TBD incorporating portions of the rationale provided 

above will be implemented in the TBD revision. [NIOSH 2018, pp. 3–4]

SC&A’s Review and Status of Finding 12 

In SC&A’s 2009 review (SC&A 2009), SC&A concurred with NIOSH that the chronic 

environmental intake issues for the period through 1953 for Area A (including Plot M) and 

ANL-E had been satisfactorily addressed. Therefore, the remaining part of the original Finding 
Memo – ANL-E Finding 12 3 SC&A – October 24, 2018 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

12 to be addressed was the consideration of potential acute environmental intakes for 

unmonitored workers in Area A (including Plot M, which was a burial site) and ANL-E (also 

called Site D) for the period through 1953. 

SC&A reviewed ORAUT-TKBS-0036-4, the original Finding 12, NIOSH’s recent response 

(NIOSH 2018), and associated SRBD references. The most applicable SRDB documents for this 

review were:

• Health Physics Division, Report of Activities, Argonne National Laboratory (ANL 1948, 

PDF pp. 15–17). This document provides an example of the activities and health physics 

monitoring practices at Site A in 1948. 

• Draft Environmental Impact Statement, Argonne National Laboratory (ANL 1979). 

Major accidents and incidents prior to 1954 are described on PDF pages 246–247. This 

information indicates that any exposures resulting from accidents and incidents were 

confined to the local operating area.

• Formerly Utilized MED/AEC Sites Remedial Action Program, Radiological Survey of 

Site A, Palos Park Forest Preserve, Chicago, Illinois, DOE/EV-0005/7 UC-70, Final 

Report, U.S. Department of Energy (DOE 1978). This document provides the results of 

the 1978 environmental surveys of Site A and Plot M (PDF pp. 16–93). PDF page 16 

states that, “By the summer of 1956, all demolition and restoration work was complete at 

both Site A and Plot M. A radioactivity survey of the site indicated no detectable surface 

contamination.” This indicates a low potential for prior environmental contamination. 

• Environmental Review for Site A/Plot M, Palos Forest Preserve, Cook County, Illinois, 

ANL/EAIS/TM-99, Argonne National Laboratory (ANL 1993). Air monitoring was 

conducted and indicated that respirators were not needed during cleanup of Site A (PDF

p. 18), indicating low potential for contamination to the environment. Examples of 

Plot M activity and cleanup during the period 1944 – 1948 are provided on PDF pages 

111–124. 

According to the information in the SRBD references, the handling of the removal of the waste 

from Plot M and the decontamination and decommissioning of Area A was documented and 

included heath physics coverage and monitored workers, including monitoring of non-Argonne 

personnel (ANL 1993, PDF p. 19). Spread of contamination was minimal and air monitoring 

showed little air contamination that would result in exposure to unmonitored workers outside the 

immediate operating area. The SRBD documents did not note any major incidents or accidents 

that would result in the release of relatively large amounts of radioactive material that would 

have presented an acute intake potential for unmonitored workers. 

While, in general, it cannot be absolutely ascertained that there were no occurrences that would 

lead to acute environmental intakes for unmonitored workers, a review of the available 

documents indicates that incidents and accidents at both Area A (including Plot M) and ANL-E 

were fairly well documented, even in the early years of operations through 1953. Most of the 

incidents and accidents involving radioactive material were isolated to a local area of operation, 

where personnel would have been monitored, and the operations would not have impacted wide 
Memo – ANL-E Finding 12 4 SC&A – October 24, 2018 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

areas of the environment where unmonitored workers could have received measurable acute

intakes. Residual environmental contamination would have been expected if significant incidents 

or accidents had occurred prior to 1954. However, data from environmental monitoring 

beginning in 1954 did not indicate significant radionuclides present in the environment at Area A

(including Plot M) or ANL-E. 

Conclusion 

SC&A did not find indications of the potential for significant unmonitored acute intakes in Area 

A (including Plot M) or ANL-E through 1953. 

References 

ANL 1948. Health Physics Division, Report of Activities, Argonne National Laboratory, Health 

Physics Division, Argonne, IL. December 1948. [SRDB Ref. ID 16426, PDF pp. 15–17] 

ANL 1979. Draft Environmental Impact Statement. Argonne National Laboratory, Argonne, IL. 

March 1979. [SRDB Ref. ID 17809] 

ANL 1993. Environmental Review for Site A/Plot M, Palos Forest Preserve, Cook County, 

Illinois, ANL/EAIS/TM-99, Argonne National Laboratory, Environmental Assessment and 

Information Sciences Division, Argonne, IL. June 1993. [SRDB Ref. ID 40591] 

DOE 1978. Formerly Utilized MED/AEC Sites Remedial Action Program, Radiological Survey 

of Site A, Palos Park Forest Preserve, Chicago, Illinois, DOE/EV-0005/7 UC-70, Final Report, 

U.S. Department of Energy, Washington, DC. April 1978. [SRBD Ref. ID 17289] 

NIOSH 2006. Argonne National Laboratory – East – Occupational Environmental Dose, 

ORAUT-TKBS-0036-4, Revision 00, National Institute for Occupational Safety and Health, 

Cincinnati, OH. February 9, 2006. 

NIOSH 2018. ORAUT Follow-up Response to SC&A Finding 12 – Outdoor Inhalation 

Exposures Associated with Waste Disposal Operations in Area A and from Particulates Released 

During Accidents Are Not Adequately Addressed, National Institute for Occupational Safety and 

Health, Cincinnati, OH. September 25, 2018. 

SC&A 2009. Review of the NIOSH Site Profile for the Argonne National Laboratory – East, 

SCA-TR-TASK1-0023, Revision 0, SC&A, Inc., Vienna, VA, and Saliant, Inc., Jefferson, MD. 

March 11, 2009. 

SC&A 2016. SC&A Recommendations Regarding Issues Resolution for the Site Profile for 

Argonne National Laboratory–East, SCA-TR-2016-SP005, Revision 1, SC&A, Inc., Vienna, 

VA, and Saliant, Inc., Jefferson, MD. June 5, 2016.