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 document 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: Hanford Work Group 

FROM: SC&A, Inc.

DATE: February 1, 2018 

SUBJECT: Review of “Site Profile for Pacific Northwest National Laboratory,” 

ORAUT-TKBS-0027, Revision 02, September 12, 2016 

SC&A was tasked on August 17, 2017, to review ORAUT-TKBS-0027, Revision 02, Site Profile 

for Pacific Northwest National Laboratory, issued September 12, 2016. As noted by the National 

Institute for Occupational Safety and Health (NIOSH), this revision was made to:

modify the scope of the PNNL site profile to reflect the decision to make no 

distinction between PNNL and Hanford until the year 2005. [It also combines] the 

six technical basis documents into one site profile document for the period from 

2005 to present. [NIOSH 2016, page 2]

Essentially, the U.S. Department of Energy (DOE) and U.S. Department of Labor determined 

that Pacific Northwest National Laboratory (PNNL) did not constitute a separate facility from 

the Hanford site for purposes of the Energy Employees Occupational Illness Compensation 

Program Act (EEOICPA) until 2005. However, the site profile revision further clarifies that for 

the 300 Area at Hanford, where specific PNNL operations were conducted: 

from 2005 forward, internal and external radiation doses received within the 300 

Area of the Hanford site are considered Hanford exposures, regardless if they 

were received in PNNL facilities in 300 Area. Nonetheless, any occupationally 

derived radiation dose received at Hanford from 2005 forward is valid for 

inclusion in a dose reconstruction for an energy employee who worked at PNNL. 

[NIOSH 2016, page 9]

Given this defined scope for the site profile, SC&A focused on the timeframe from 2005 to the 

present in terms of the adequacy and completeness of the revision. It should be noted that this 

timeframe encompasses the modern era of radiological control programs at DOE facilities, with 

PNNL having satisfied compliance with 10 CFR Part 835 regulatory requirements, as well as 

achieving Department of Energy Laboratory Accreditation Program (DOELAP) certification for 

its internal and external radiation dosimetry programs. 

For purposes of this review, SC&A reviewed a number of information sources (in addition to the 

site profile itself) relevant to PNNL’s radiological control program in the context of radiation 

protection monitoring and records: 
Memo – Review of ORAUT-TKBS-0027, Rev. 02 2 SC&A – February 1, 2018 

NOTICE: This document 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. 

• DOE Noncompliance Tracking System (NTS) – for instances of reported 

noncompliances with regulatory requirements. SC&A accessed and searched this tracking 

system for any instances of noncompliances with radiation exposure implications for the 

period from 2005 forward. 

• DOE Occurrence Reporting System (ORPS) – for reported incidents and accidents 

involving radiation exposure. SC&A accessed and searched this compilation for radiation 

exposure incidents and occurrences for PNNL for the period from 2005 forward. DOE

compiled and provided a report on January 23, 2018. 

• Hanford Issues Matrix – for outstanding Special Exposure Cohort (SEC) and site 

profile issues from the ongoing SEC review (currently addressing 1983–1990) that may 

have potential relevance for PNNL post 1995. This matrix was recently updated and 

jointly issued by NIOSH and SC&A to the Hanford Work Group in December 2017 

(NIOSH 2017). 

• DOE Nuclear Materials Management & Safeguards System (NMMSS) – for any 

onsite presence of certain radiological source terms during the period in question. SC&A 

accessed and reviewed this secure inventory system at DOE’s Germantown facility on 

January 24, 2018. 

• NIOSH’s Site Research Database – for site documents and data having relevance for 

PNNL for the period from 2005 forward. 

The purpose is to ascertain whether the revised site profile (1) is adequately complete for the 

time period in question and (2) adequately addresses key historical and operational information 

needed to guide dose reconstruction under EEOICPA. 

Observations

1. Enriched uranium: Based on a review of historical radiological inventories at PNNL 

facilities for the period from 2005 forward (via NMMSS), the only source term of any 

significance is enriched uranium. This figured in waste management, material 

stabilization, and, to a small extent, basic science research. The site profile acknowledges 

its presence in waste management activities, given its historical use at Hanford, but does 

not clearly acknowledge its ongoing, continued use and exposure potential for other 

activities. 

2. ORPS report, “Management Concern Regarding Missed Radiological Bioassays”: 

ORPS Report No. SC-PNSO-PNNL-PNNLBOPER-2009-0002 (DOE 2009) cites an 

occurrence reported by PNNL on February 25, 2009, that “required bioassays have not 

been performed for some staff performing radiological work.” This issue arose from 

improper staff use of a “bioassay waiver tool” that was erroneously used to allow 

required bioassays to be eligible for waiver. This error arose from a modification (in 

March 2008) to PNNL’s Automatic Radiological Access Control System (ARACS) that 

was not coupled with a corresponding modification to the Bioassay Scheduling and 

Waiving Tool (BSWT). Follow-up investigation of 28 workers whose bioassay had been 
Memo – Review of ORAUT-TKBS-0027, Rev. 02 3 SC&A – February 1, 2018 

NOTICE: This document 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. 

erroneously waived showed “no doses in excess of monitoring levels required by 10 CFR 

835 (100 mrem CEDE) were missed.” While there was apparently no consequence from 

these initially missed bioassays, the dose reconstructor should be aware of this 

reassessment and investigation affecting all PNNL workers on Radiation Work Permits.

3. 2007 Price-Anderson enforcement action (EA-2007-07): While the site profile 

observes that “there have been no known, large-scale radiological incidents at PNNL 

from 2005 to the present” (page 10), it does not acknowledge a Preliminary Notice of 

Violation issued on January 3, 2008, based on eight violations of 10 CFR 830 and 835, at 

Severity Level II, with a civil penalty (ultimately waived). These involved two incidents, 

one involving an airborne release of plutonium at the Radiochemical Processing 

Laboratory and the other involving the spread of contamination (including to the public) 

from a leaking sealed source. While these did not constitute “large-scale” radiological 

incidents, DOE viewed them as significant:

DOE views these violations as significant. Both radiological events

resulted in uptakes and exposures to personnel. [DOE 2008, page 2]

While these exposures can (and should) be addressed on an individual claimant basis, it is 

useful to identify significant exposure incidents in site profile radiological histories.

Conclusion

The revised PNNL site profile (ORAUT-TKBS-0027, Revision 02) is adequately complete and 

comprehensive, but it can be strengthened by the inclusion of some additional historical

information, as noted in our observations. 

References

DOE 2008. Correspondence from Arnold E. Guevara, Director, Office of Enforcement, U.S. 

Department of Energy, to Michael Kluse, Interim Laboratory Director, Battelle Memorial 

Institute, Pacific Northwest National Laboratory, EA-2007-07. January 3, 2008. Available at 

https://energy.gov/sites/prod/files/hss/Enforcement%20and%20Oversight/Enforcement/docs/eas/

EA-2007-07.pdf. 

DOE 2009. U.S. Department of Energy, Occurrence Reporting Program System (ORPS), Report 

No. SC-PNSO-PNNL-PNNLBOPER-2009-0002, “Management Concern Regarding Missed 

Radiological Bioassays.” February 25, 2009. 

NIOSH 2016. Site Profile for Pacific Northwest National Laboratory, ORAUT-TKBS-0027, 

Revision 02, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

September 12, 2016. 

NIOSH 2017. Email from Chuck Nelson, National Institute for Occupational Safety and Health, 

to James Melius, Chairman, Hanford Work Group, Subject: Hanford Issues Matrix. 

November 29, 2017.