Working Draft 

FERNALD PLANT SITE PROFILE ISSUES MATRIX –

DRAFT PRELIMINARY SC&A ASSESSMENT 

Contract 211-2014-58081 

SCA-SP-IM2013-0045, Revision 2 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

September 2014

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.
Effective Date:

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Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/15/2013 Initial issue of a complete issues matrix incorporating information from previous 

versions, white paper issue reviews, memorandums, Work Group meetings, etc.

1 4/13/2014 Revision to incorporate NIOSH responses to Rev. 0 and SC&A responses to NIOSH 

responses.

2 9/01/2014 Revision to incorporate additional SC&A responses to NIOSH responses based on 

focused review of 2014 TBD revisions. An attachment has also been added.
Effective Date:

Updated September 1, 2014

Revision No.

2 (Draft)

Document No.

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Page No.

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versions of this issues matrix will require additional reviews for Privacy Act-protected information. 

INTRODUCTION

The attached updated “Fernald Plant Site Profile Issues Matrix – Draft Preliminary SC&A 

Assessment, Rev. 02” is a rebaselined issues matrix for use by the Work Group; it was originally 

provided in both Microsoft Word® and Excel® formats (Rev. 0) in October 2013. Revision 1 

incorporated NIOSH’s responses to Rev. 0 (in blue font) and SC&A’s responses to NIOSH’s 

responses. Revision 2 incorporates additional SC&A responses (red font) based on our focused 

review of new TBD revisions provided in 2014. Revision 2 also provides an attachment 

containing responses for those findings requiring a detailed description. SC&A notes that while 

a great deal of information and guidance is provided in the 2014 TBD revisions, we have not 

reviewed any of the TBD revisions beyond the level needed to close our findings from the 2006 

review. The matrix summarizes those issues that SC&A believes are still open following the 

addition of two classes of workers to the Special Exposure Cohort (SEC) at the July 2013 

Advisory Board meeting in Idaho Falls, Idaho. 

In developing the matrix, SC&A reviewed the transcripts from 16 successive Work Group 

meetings held from August 2007 to July 2013, as well as numerous white papers and 

memorandum reports related to SEC deliberations of the Work Group during that period. The 

matrix incorporates several unresolved findings from SC&A’s site profile review, delivered to 

the Advisory Board in November 2006; that report identified 33 original findings. It also 

considers issues that emerged from Work Group discussions of our review of the SEC-00046 

Evaluation Report (ER), which was delivered to the Advisory Board in June 2007. Our SEC ER 

review identified 30 original findings, which were eventually merged into six general categories 

as a result of Work Group deliberations. 

Because Fernald issues were some of the most difficult encountered under the EEOICPA and the 

issues resolution process spanned such a long period, we believe that the Work Group would be 

best informed by a full accounting of the original issues and how SC&A determined their current 

status. To that end, in October 2013, we provided to the Work Group the Excel file titled,

“Fernald Issues Matrix - 131015 FINAL.xlsx.” This “full matrix” captures the results of the site 

profile and SEC findings resolution process that SC&A used to determine the current open 

issues. It is our hope that the Work Group finds this helpful in charting a path forward on 

resolving the remaining Fernald issues.
Effective Date:

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

TBD

1

The list of facilities in 

which thorium-232 was 

processed, the time 

periods of thorium 

processing, and the 

thorium production data 

shown in the TBD have 

significant gaps. Entire 

periods of processing and 

plants in which the work 

was done have been 

missed. These gaps may 

affect the feasibility of 

dose reconstruction for 

workers for certain time 

periods and in certain 

plants.

This is identical to SEC Issue 4.3-5. NIOSH responded as 

follows: Additional thorium production documents have been 

located and interviews have been conducted with people 

knowledgeable of the thorium processes at FMPC. The 

knowledge gaps have largely been eliminated in the draft 

revision of ORAUT-TBKS-0017-5. The current default 

thorium intake recommendations are applicable to any 

location and time after 1954 in which thorium exposure is 

deemed reasonable... Knowledge of the process and locations 

of processes is now comprehensive, based on interviews, 

documents, and additional research... See the Thorium 

Timeline with AA 2-29-07.doc in the following directory 

O:\Document Review\AB Document Review\Fernald.

All plants for 1955 and 1966 and plant 6 for 1960 were 

identified by the work group as the buildings and the time 

periods that will be used to create the database and 

demonstrate its completeness and reliability for performing 

dose reconstructions. The work group agreed that it was not 

necessary to create such a compendium of data and analyses 

for all buildings and work years, given the magnitude of the 

effort, and that the selected years should provide the evidence 

that such a coworker model can, in fact, be developed and 

implemented.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of th-232 with sufficient 

accuracy from DWE data.

10/15/2013: SC&A suggests 

closing this finding because the 

NIOSH coworker model for 

1979–1988 does not employ air 

concentration data.

This finding pertained mainly to 

the availability of air sampling 

data pre-1968.

The NIOSH coworker model for 

Thorium-232 intakes based on 

activity measurements of the 

gamma–emitting progeny Pb-212 

and Ac-228 is under discussion 

by the Fernald WG, last 

discussed at the July 1, 2013, 

WG meeting.

This issue is no longer relevant to 

the post-1978 coworker model, 

which is based on bioassay data. 

SC&A Completeness and

Adequacy of Thorium In-Vivo 

Records (1979–1989), November 

2012:

It is clear from the 

completeness analysis that 

there are no significant 

temporal gaps in the in-vivo 

data reported in nCi Ac-227 

and Pb-212 that might 

preclude its use in a 

coworker model.

4/15/2014 – WG recommends 

closure (p. 69, 4/15/14 WG 

transcript)

Agreed.

closed
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Finding Text History SC&A NIOSH Response Status

TBD

2

Air concentration data for 

thorium in the TBD are 

sparse and incomplete, 

though considerably more 

data are available in the 

NIOSH Site Research 

Database. The TBD 

contains no Thorium-232 

bioassay or in-vivo data.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

10/15/2013: SC&A suggests 

closing this finding because the 

NIOSH coworker model for 

1979–1988 does not employ air 

concentration data.

4/15/2014 – WG recommends 

closure (pp. 71-72, 4/15/14 WG 

transcript)

Agreed.

closed

TBD

3

Thorium intakes due to 

fugitive emissions and 

resuspension in 

production areas may 

have been significant for 

some locations and 

periods. The TBD does 

not address the issue of 

fugitive emissions in 

production areas. 

Furthermore, the TBD 

does not provide a method 

to estimate resuspension 

intakes in the pre-1986 

period and for those 

workers without lapel air 

sampling in the post-1986 

period.

This is identical to SEC Issue 4.3-8. NIOSH responded as 

follows: Many thorium air samples, including GA samples 

from inside the plants, are available. These GA samples from

operating areas are sure to bound the concentrations in nonoperating areas. A series of contemporary time and motion 

studies are being considered. These studies characterize 

intakes for people in clerical areas inside the operating 

facilities. The Battelle model based on air sample data is also 

available. Dose reconstruction is possible, the best method is 

still being considered... An approach to thorium dose 

reconstruction has been devised using newly available 

thorium exposure assessments. See the DWE Reports white 

paper in the following directory: O:\Document Review\AB 

Document Review\Fernald.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

10/15/2013: SC&A suggests 

closing this finding because the 

NIOSH coworker model for 

1979–1988 does not employ air 

concentration data.

4/15/2014 – WG recommends 

closure (p. 72, 4/15/14 WG 

transcript)

Agreed.

closed
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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

TBD

4

The guidance in the TBD 

regarding exposures from 

redrumming thorium is 

not well founded and is 

not claimant favorable.

This is identical to SEC finding 4.3-7. NIOSH responded as 

follows: See comments in response to Finding 4.3-1 and 4.3-

6 above... Guidance will be claimant favorable and in the 

TBD.

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of th-232 with sufficient 

accuracy from DWE data 

10/15/2013: SC&A suggests 

categorizing this finding as "in 

abeyance." Redrumming was 

still an issue for the post 1978 

period. We discuss redrumming 

in SC&A’s Completeness and 

Adequacy of Thorium In-Vivo 

Records (1979–1989). Basically, 

we don't know who performed 

redrumming, which is why the 

coworker model must be applied 

to all potentially exposed workers 

at the 95th percentile. NIOSH has 

agreed to do this, but we have yet 

to see the formal implementation.

4/10/2014: The proposed method 

for 1990–1994 is new.

According to ORAUT-TKBS0017-02 Rev. 01, the site 

production mission has been 

terminated and the site underwent 

remediation and cleanup from 

1989 to 2006.

Table 2-2 indicates that thorium 

repackaging was going on from 

1990–1993. 

SC&A will need to review the 

implications for thorium DR 

during remediation and cleanup 

and report back at a later WG 

meeting.

4/15/2014 – WG recommends 

keeping this finding open (pp. 

72-73, 4/15/14 WG transcript)

For the 1979–1994 timeframe, 

if in vivo results exist, then 

they will be used to 

reconstruct thorium dose. 

For 1979–1989, if there are no 

in vivo results, then coworker 

doses will be assigned. (A 

coworker thorium study is in 

development.)

For 1990–1994, if there are no 

in vivo results, thorium doses 

can be assigned based on an 

intake of 10% of the derived 

air concentration (DAC) for 

the year, as appropriate.

open
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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

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Finding Text History SC&A NIOSH Response Status

8/25/2014: SC&A recommends 

keeping this finding open 

pending our formal review of 

the NIOSH white paper on 

post-SEC thorium methodology 

(mid-late October 2014).

TBD

5

The TBD has not 

evaluated exposures due 

to thorium fires. The 

TBD has also not 

evaluated other thorium 

incidents or failures of 

industrial hygiene.

(ABRWH 2007, pg. 220) And it’s well documented, and it’s 

also accepted by NIOSH that small fires, spills, explosions 

were commonplace. And yet it is unlikely that most of the air 

sampling data that you’re compiling will necessarily reflect 

them, those radiological incidents. 

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

10/15/2013: SC&A suggests 

closing this finding because the 

NIOSH coworker model for 

1979–1988 does not employ air 

concentration data.

4/10/2014: Preliminary review 

of ORAUT-TKBS-0017-02 Rev.

01 indicates possible relevance 

for 1990–1994 thorium 

redrumming operations. See 

response to Item 4.

4/15/2014 – WG recommends 

keeping this finding open (p. 73 

4/15/14 WG transcript)

8/25/2014: SC&A recommends 

keeping this finding open 

pending our formal review of 

the NIOSH white paper on 

post-SEC thorium methodology 

(late October 2014).

Agreed.

open

TBD

6

The approach suggested 

for estimating thorium 

intakes does not reflect 

the history of production 

This was resolved for 1954–1967 in primary SEC Issues 6a 

and 6b.

April 2012 – SEC voted based on inadequacy of the activity 

10/15/2013: SC&A suggests 

closing this finding because the 

NIOSH coworker model for 

1979–1988 does not employ air 

Agreed.

closed
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Finding Text History SC&A NIOSH Response Status

or the available thorium 

air concentration data. It 

is likely to result in 

significant underestimates 

of internal dose from 

thorium.

to mass conversion algorithm from 1968–1978.

1979–1988 – Implementation of a coworker model is an 

ongoing site profile issue.

.July 2013 – SEC voted for all workers 1954–1967 based on 

inability to reconstruct intakes of Th-232 with sufficient 

accuracy from DWE data.

concentration data.

4/15/2014 – WG recommends 

closure (pp. 73-74, 4/15/14 WG 

transcript)

TBD

7

The TBD does not specify 

a method for estimating 

doses in the raffinate

streams, which are 

uranium-poor, from ore 

processing in Plant 2/3. 

These doses may be very 

difficult to calculate, 

especially for high-grade 

ores, notably pitchblende 

ore from Congo.

This pertains to SEC finding 4.2-2 and Primary SEC Issue 

#4: “Review of radon breath data for adequacy for 

reconstructing doses due to the inhalation of Ra-226 and Th230.”

October 14, 2008 – NIOSH responded: “NIOSH has radon 

breath analyses for raffinate transfer operations and air sample 

data in the Plant 2/3 raffinate handling area sufficient to 

bound possible intakes and allow claimant-favorable dose 

reconstructions of sufficient accuracy.” The NIOSH approach 

is contained in ORAUT-RPRT-0052 (ORAUT 2011). Report 

52, pp. 24–25: Transfer of drummed K65 raffinate to Silos 1 

and 2 late 1952–June 53; radon breath data available. Q-11 

transfer 1954-1957; subsumed in SEC. 

The concern for the raffinate streams can be bounded by the 

extensive “radon breath analyses-to-radium deposition” 

performed during the K-65 raffinate drum disposal operation. 

In addition, confirmatory air monitoring data in Plant 2/3 

specific to the raffinate operations provides assurance that 

exposures are adequately bounded. The raffinates were wet 

(minimizing air contamination production) and enclosed in 

process piping.

Other uranium daughters in addition to Ra-226 intake can be 

adequately bounded by ratioing to Ra-226, using the isotopic 

analyses of the silo contents.

A detailed discussion of SEC Issue 4 took place at the April 

19, 2011, WG meeting (ABRWH 2011), where SC&A agreed 

that NIOSH's methods were bounding and sufficiently 

accurate.

10/15/2013: SEC recommends 

this issue be changed to "in 

abeyance" pending revised TBD.

4/10/2014: New revision of 

ORAUT-TKBS-0017-5 not yet 

available. October 2013 

recommendation holds.

8/25/2014: October 2013 

recommendation holds.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

provides a method for 

estimating raffinate streams, 

which will be incorporated 

into ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions. 

ORAUT-OTIB-25, 

“Estimation of Radium-226 

Activity in the Body from 

Breath Radon-222 

Measurements,” which is 

included in ORAUT-RPRT0052, provides a method for 

reconstructing doses from 

radon breath analyses results 

from 1952–1954 and this 

methodology will be included 

into the internal TBD 

revision. 

In 

abeyance
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Finding Text History SC&A NIOSH Response Status

TBD

8

Workers who may have 

worked with raffinates

may be missed by the 

protocol specified in Vol. 

5 of the TBD. The 

guidelines for determining 

which workers were 

exposed to raffinate dusts 

are too restrictive and 

place far too great a 

reliance on completeness 

of records for job 

assignments, or in the 

alternative, place the 

burden of proof on the 

claimant. They have not 

been adequately justified 

by measurements and are 

not claimant favorable.

See response to Finding #7. 10/15/2013: See response to 

Finding #7.

See NIOSH response #7.

In 

abeyance

TBD

9

The data on trace 

contaminants in RU in the 

Fernald TBD are 

incomplete and appear to 

be incorrect. Different 

official documents have 

very different values for 

various aspects of RU 

data, including production 

and contamination. The 

contradictions have not 

been sorted out in the 

TBD.

This finding is the same as SEC finding No. 4.1-6. NIOSH 

responded as follows:

Some production data are admittedly conflicting. 

Since dose reconstruction does not depend directly on 

production data, sufficient data are available to 

enable a bounding estimate based on the ratio of RU 

contaminates to the uranium intake determined from 

the uranium urinalyses. Recommended defaults have 

been chosen that adequately bound all of the 

operational data. The shipment(s) from Paducah 

Gaseous Diffusion Plant were of short duration, the 

increased hazards were recognized and adequately 

controlled, and recognized as doubling the total 

inventory of RU contaminants at FMPC, which in turn 

was factored into the default assumptions.

After many white paper exchanges and deliberations, 

NIOSH demonstrated that they could place a plausible 

upper bound on intakes from three principal RU 

10/15/2013: SC&A recommends 

finding be changed to “in 

abeyance" pending revised TBD. 

4/10/2014: New revision of 

ORAUT-TKBS-0017-5 not yet 

available. October 2013 

recommendation holds.

ORAUT-RPRT-0052 (April 

2011), Section 4.5, Table 18 does 

not reflect agreed upon 

constituent levels from WG 

discussions on February 9, 2012 

[See SC&A white paper titled 

“SC&A’S Response to NIOSH’s 

Subgroup 10A Impact Analysis 

Dated November 1, 2011 (SC&A

2012)].

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents, 

which will be incorporated 

into ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions. 

In 

abeyance
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Finding Text History SC&A NIOSH Response Status

constituents. Need to verify that what was 

agreed upon in WG meetings is 

in fact incorporated into TKBS0017-5 and any related guidance 

documents.

8/25/2014: SC&A recommends 

that this finding be kept in 

abeyance pending revision of 

ORAUT-TKBS-0017-5.

TBD

10

The radionuclide list for 

RU in the TBD is 

incomplete. Furthermore, 

the concentrations of trace 

radionuclides in the 

raffinates, which are much 

higher than those in the 

feed material, are not 

adequately discussed.

This finding is the same as SEC finding No. 4.1-5 and SEC 

Primary Issue 3. NIOSH responded as follows:

Adequate material flow information is available to 

perform bounding analyses – with the recommended 

defaults being at least an order of magnitude higher 

than the average observed contaminant concentration 

in the processed materials...

...Any external dose associated with U-232 and decay 

products would be adequately monitored by the 

external dosimetry device.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from three principal RU constituents.

Subsumed into SEC pre-1979. Coworker model applicable 

1979–1986 when WMCO took over M&O from NLO and for 

non-SEC claimants.

10/15/2013: SC&A notes that 

while NIOSH has provided a 

method for bounding intakes 

from Pu, Np-237, and Tc-99, 

other nuclides such as Am-241 

and thorium isotopes are not 

included in the model and were 

not discussed in WG meetings. 

SC&A recommends finding 

remain open and that WG discuss 

incorporating these other RU 

constituents into the coworker 

model.

4/10/2014: New revision of 

ORAUT-TKBS-0017-5 not yet 

available. ORAUT-RPRT-0052 

does not address these other 

constituents nor have they been 

discussed in the WG setting. 

October 2013 recommendation 

holds. 

8/25/2014: SC&A recommends 

keeping this finding open

pending upcoming revision to 

ORAUT-TKBS-0017-5. 

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents 

and has revised ratios for 

recycled uranium constituents 

that will be incorporated into 

ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.

Open
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Finding Text History SC&A NIOSH Response Status

TBD

11

The suggested approach 

for RU dose estimation in 

the TBD is claimant 

favorable for many RU 

workers, but not claimant 

favorable for others and 

for some periods; it is not 

based on an evaluation of 

the available data.

This is similar to SEC Primary Issue #3.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from RU constituents. 

Subsumed into SEC pre-1979. Coworker model applicable 

1979–1986 when WMCO took over M&O from NLO and for 

non-SEC claimants.

10/15/2013: SC&A recommends 

finding be changed to “in 

abeyance" until agreed upon 

method is incorporated into the 

TBD.

4/10/2014: See response to #9.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents 

for all workers, which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.

In 

abeyance

TBD

12

The TBD notes that 

uranium batches with 

enrichment greater than 

2% were processed at 

Fernald. NIOSH’s 

assumption of 2% 

enriched uranium is 

claimant favorable most 

of the time, but not for 

periods and batches when 

uranium of higher 

enrichments were 

processed.

This relates to SEC finding 4.1-4. NIOSH responded as 

follows:

The dose conversion factor for U-234 is applied to all 

uranium intakes. This results in a bias that is 

favorable to the claimant. The operational 

descriptions in the TBD are correct.

11/11/07 – SC&A to review sample case along with 

default approaches (1% prior to 1964 and 2% after 1964). 

NIOSH to provide documentation to support the statement 

that most of the ‘enriched’ material was very slightly 

enriched (slightly greater than 0.71% U-235).

3/18/08 – The following documents were provided to 

substantiate the assumptions: 8/7/2007 interview [redact] 

and [redact] (ORAUT 2007a); 9-11-07 interview with 

[redact] and [redact] (ORAUT 2007c); 8-30-07 interview 

with [redact] and [redact] (ORAUT 2007b).

10/15/2013: WG closed10/28/08 

(pp. 200–217).

4/15/2014 – WG agrees with 

WG10/28/08 closure 

recommendation (p. 74, 4/15/14 

WG transcript)

Agreed.

closed
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Finding Text History SC&A NIOSH Response Status

10/28/08 (pp. 200–217) – SC&A found documentation 

indicating enrichments of 3%–10%. NIOSH 

acknowledges that there were exceptions to normal work. 

SC&A agrees dose can be reconstructed if the enrichment 

handled is known, but questions if those workers can be 

identified. NIOSH proposed assigning everyone 2% 

unless there is documentation indicating otherwise. After 

lengthy discussion, the Board accepts the 2% position and 

closed the finding.

TBD

13

Female employees were 

not monitored for long 

periods at Fernald, even 

though at least some of 

them were at some risk of 

internal intakes of 

radionuclides.

This is similar to SEC finding 4.5-5. NIOSH responded as 

follows:

The doses to those female workers who were not 

monitored during two operating periods can be 

reconstructed by at least three methods. They are: 

(1) If the worker in question is doing the same or very 

similar job during periods when she is monitored, that 

dose could be used to adjust the missing dose when 

she wasn’t monitored; (2) Workers who were doing 

the same job and were monitored at the time the 

female wasn’t, could have an equivalent dose assigned 

to the unmonitored worker, and (3) Assignment of the 

missed dose as stated in the TBD-Vol 6 of 500 

mrem/yr for the missing time periods, which is known 

to be extremely claimant favorable.

Discussed at 8/8/07 meeting – SC&A raised the concern that 

women who worked in the laundry were not monitored but in 

some cases handled highly contaminated laundry. NIOSH 

stated assigning them a 500 mrem dose exceeds recorded 

doses by operators which is claimant favorable. SC&A states 

default dose does not address the following: (1) the shallow 

dose to the skin, (2) the extremity dose to the forearm/hands, 

and (3) potential internal exposure from airborne 

contamination created by handling contaminated items.

Suggested linking the internal component to SEC Finding 4.1-

3.

10/15/2013: Closed

4/15/2014: WG decided to put in 

abeyance pending review of TBD 

revision (pp. 74-78 of 4/15/14 

WG transcript). Virtually 

identical to Finding #21.

8/29/2014: This finding 

predated the internal dose 

coworker models now in use 

for unmonitored workers –

SC&A recommends closure. 

Note that NIOSH’s response to 

this finding actually pertains to 

finding 21, which addresses the 

external dose to unmonitored 

female employees.

Agreed.

ORAUT-OTIB-0073, 

“External Coworker 

Dosimetry Data for the 

Fernald Environmental 

Management Project,” will be 

incorporated into ORAUTTKBS-0017-6, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project –

Occupational External Dose,” 

and will be used for 

unmonitored workers.

Due to changed project 

approaches towards 

unmonitored worker dose 

assignment, missed dose is no 

longer used to assign 

unmonitored doses and the 

500 mrem upper bound dose 

methodology will be removed 

during the TBD revision 

process since the coworker 

model will bound 

unmonitored workers.

In 

abeyance
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Finding Text History SC&A NIOSH Response Status

Discussed at 11/13/07 meeting. Decided this was an issue 

isolated to a few individuals and should be evaluated on a 

case-by-case basis in DR.

4/22/09 meeting: Issue closed. Decided three methods 

suggested are sufficient.

TBD

14

The TBD does not address 

the extremely high 

uranium dust 

concentrations, which 

were present at Fernald 

under a variety of 

circumstances, and their 

effect on dose 

reconstruction. Particle 

size and solubility 

assumptions for workers 

who experienced chip 

fires should be examined.

Related to Primary SEC Findings 1, 2a, 2b, which have been 

closed.

This finding was logged at a time when NIOSH had proposed 

using alpha air concentration data to reconstruct uranium 

intakes and before a U bioassay coworker model had been 

developed and the source data examined for completeness and 

adequacy.

This finding is no longer relevant, because the uranium 

coworker model, which has been accepted by the Board (for 

prime contractor employees and subcontractors post 1983) is 

based on bioassay data, not air concentration measurements.

10/15/2013: SC&A recommends 

that this finding be closed.

4/15/2014 – WG recommends 

closure

Agreed.

closed

TBD

15

Ingestion doses are not 

considered in the TBD.

Thorium ingestion is covered in SEC finding 4.3-9. NIOSH 

responded as follows:

 

Use of the intake model based on thorium air concentrations 

(the Battelle model) addresses this problem. Consequently, it 

is no longer an SEC issue. ...An approach to thorium dose 

reconstruction has been devised using newly available 

thorium exposure assessments. See the DWE Reports white 

paper in the following directory O:\Document Review\AB 

Document Review\Fernald.

3/26/2008 – Once a reliable estimate is made of the 

inhalation rate of uranium, Th-232, and the radionuclides 

associated with raffinates and RU, ingestion intakes and 

doses would be calculated using OCAS-TIB-009 Rev. 0 

(OCAS 2004). Hence, once the inhalation issues are 

resolved, the matter of ingestion exposures effectively 

becomes a review of TIB-009.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Findings associated 

with OCAS-TIB-009, 

“Estimation of Ingestion 

Intakes,” have been closed by the 

Procedures Review 

Subcommittee (PRSC). SC&A 

agreed that the NIOSH method is 

scientifically defensible and 

claimant favorable. 

8/25/2014: SC&A recommends 

keeping this issue in abeyance 

pending ORAUT-TKBS-0017-5 

revision.

OCAS-TIB-009, “Estimation 

of Ingestion Intakes,” 

provides an approach towards 

thorium ingestion doses and 

will be included in the 

ORAUT-TKBS-0017-5, 

“Technical Basis Document 

for the Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal Dose” 

revision. 

In 

abeyance
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Finding Text History SC&A NIOSH Response Status

This issue was partially resolved by the three SEC classes for 

which it was determined that thorium intakes cannot be 

reconstructed from 1954–1978 and U doses cannot be 

reconstructed for subcontractors from 1951–1983. The 

thorium coworker model post-1978 relies on chest count data, 

and ingestion modeling is still an issue for discussion.

TBD

16

Protocols for 

reconstructing shallow 

external dose during the 

operations at FEMP need 

to be further developed.

This relates to SEC finding 4.5-3, yet is not entirely covered 

by it. See TBD finding 18. SC&A last tasked to look at 

several procedures.

 

From SC&A TBD review, Section 5.6.1, External Dose 

Reconstruction Protocols (SC&A 2006):

As a prefatory remark to external dose findings, 

SC&A notes that Findings #16 through #20 are

largely concerned with skin/shallow dose. The 

findings are made as technical arguments, but

their impacts on potential claims may be modest. 

For example, while skin dose to the palm of the hand 

is likely to be underestimated, there may be few, if 

any, claims of skin cancer located in that area. 

However, since the procedure in the TBD is not 

adequate for estimating such doses, in case there are 

any claims, SC&A concluded that a technical review 

of the matter was necessary as part of this TBD 

review.

10/15/2013: SC&A recommends 

finding be classified "open" as a 

topic for WG discussion

4/10/2014: SC&A agrees that

ORAUT-OTIB-0017, 

“Interpretation of Dosimetry 

Data for Assignment of Shallow 

Dose,” largely puts this finding to 

rest. However, we have not yet 

reviewed ORAUT-TKBS-0017-6 

to verify that the revision 

adequately addresses our 

concerns. Recommend keeping 

open until we can verify.

8/25/2014: SC&A recommends 

closure (see attachment for 

detailed description).

ORAUT-OTIB-0017, 

“Interpretation of Dosimetry 

Data for Assignment of 

Shallow Dose,” is referenced 

in the ORAUT-TKBS-0017-6, 

“Technical Basis Document 

for the Fernald Environmental 

Management Project –

Occupational External Dose,” 

revision and provides the 

protocols for reconstructing 

shallow external dose. 

ORAUT-OTIB-0017 was not 

available when ORAUTTKBS-0017-6, “Fernald Site –

Occupational External Dose,” 

(04/20/2004) was approved.

open
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Finding Text History SC&A NIOSH Response Status

TBD

17

Extremity doses appear to 

be underestimated.

This is similar to SEC finding 4.5-2. NIOSH responded as 

follows:

Extremity doses were measured using “wrist dosimeters and a 

wrist to extremity ratio.” This ratio varied with changes in 

the dosimeter; it decreased with the introduction of TLDs. 

However, previous extremity dose records were not adjusted 

downward to account for the new lower ratio. Consequently, 

extremity doses are deemed to be sufficiently accurate for 

dose reconstruction or are biased to produce a result that is 

favorable to the claimant.

10/24/07 – SC&A will review data in HIS-20 to consider 

whether sufficient information is available to estimate 

extremity doses for individuals who did not have extremity 

data and who may have had significant extremity exposures.

11/12/07 – Extremity dosimeter not used till 1970. SC&A 

will review data in HIS-20 to consider whether sufficient 

information is available to estimate extremity doses for 

individuals who did not have extremity data and who may 

have had significant extremity exposures. And then 

additionally, SC&A will consider whether this should be 

considered in their review of data completeness.

10/28/08 – SC&A acknowledges that this is not an SEC issue, 

because extremity cancers are uncommon. Until the 1980s, 

energy employees (EEs) were not monitored for extremity 

dose. Extremity monitoring was extremely limited in early 

years; however, those that were monitored had substantial 

exposures. SC&A proposes ratio in write-up to apply to chest 

badge beta readings. NIOSH did not comment on adding this 

ratio to TBD.

This issue was not discussed after this meeting.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: SC&A notes that 5 of 

6 findings associated with 

DCAS-TIB-0013 (DCAS 2010) 

have been closed under the 

PRSC. However, we have not 

yet reviewed ORAUT-TKBS0017-6 to verify that the revision 

adequately addresses our 

concerns. Recommend keeping 

this finding open until we can 

verify.

8/25/2014: SC&A recommends 

that this issue remain open

pending related investigations 

at INL (see attachment for 

detailed description).

The ORAUT-TKBS-0017-6, 

“Fernald Site – Occupational 

External Dose,” revision 

references DCAS-TIB-0013, 

“Selected Geometric 

Exposure Scenario 

Considerations for External 

Dose Reconstruction at 

Uranium Facilities,” and 

provides geometry factors for 

uranium dose and adjustments 

for wrist to hand, so that 

extremity doses are not 

underestimated. DCAS-TIB0013 was not available when 

ORAUT-TKBS-0017-6, 

“Fernald Site – Occupational 

External Dose,” (04/20/2004) 

was approved. 

open
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Finding Text History SC&A NIOSH Response Status

TBD

18

Beta dose to the rest of the 

body would also be 

underestimated, based on 

the TBD guidance.

This is similar to SEC finding 4.5-3. NIOSH responded as 

follows: It is true that only contamination in close proximity 

to the dosimetry device will be recorded, because the dose 

rate associated with surface contamination is small—

probably much less than 1 mrem/hour. In this case, the 

underlying physics limits the dose rate. The beta dose rate on 

contact with an unshielded infinitely thick slab of uranium 

metal is 233 mrem per hour. Knowing this fact, it is feasible 

to bound the dose from surface contamination. Thus, the 

finding assertion, given the complex processes and the many 

different tasks performed at FMPC, it is inconceivable that 

credible 'ball-park' and bounding estimates can be derived" 

can only be viewed as an error or exaggeration.

Any amount of uranium contamination capable of producing 

a dose rate in excess of a negligible level is likely to be easily 

visible and be removed during the frequent showers and 

clothing changes taken by those workers who may be subject 

to conditions leading to possible contamination, thereby 

limiting the dose.

10/24/07 – NIOSH will examine whether an adjustment is 

necessary to account for this potential unmonitored dose.

3/18/08 – See the 1958 radiation survey on clothing reported 

in Ref ID 4136. These data are interpreted to be mrad per 

hour for clothing that was in use. Except for exposed skin, 

clothing is assumed to attenuate dose to skin and will lower 

the actual dose... All clothing dose rates are in mrad/hr and 

most measurements of attenuation yield values between 15% 

and 20% reduction by the clothing. SRDB 4330, pp. 177–

204, provides insight to extremity doses and includes a 

statement that measured workplace values should be reduced 

by some 14%.

10/28/08 (pp. 356–365) – SC&A will review the procedures 

NIOSH placed on O Drive (NLO document, several SOPs and 

SRDB 3173, 33975).

Issue was not discussed after this meeting.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion. 

Contact beta dose is currently 

under review in the PRSC.

4/10/2014: SC&A’s position 

summary on localized skin 

exposure, “SC&A Position 

Regarding Skin Exposures 

Associated with the Direct 

Deposition of Fine Particles and 

Flakes of Uranium Oxide onto 

Skin and Clothing,” January 

2014, has been discussed under 

the PRSC and is slated for 

discussion at the 4/16/2014 

PRSC meeting. Recommend 

keeping this finding open until 

PRSC discussions are completed.

.

8/25/2014: SC&A recommends 

closure – virtually identical to 

finding #16 

The majority of these issues 

are global issues which are 

being addressed through the 

Procedures Review 

Subcommittee.

For known skin 

contaminations, VARSKIN is 

used. Unknown skin 

contaminations cannot be 

addressed.

open
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Finding Text History SC&A NIOSH Response Status

TBD

19

The TBD does not 

analyze the special 

problems associated with 

geometry of the source 

relative to the exposed 

organ and dosimeter in 

thorium handling and 

production.

This topic has not previously been discussed. 10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

Dosimeter geometry has been 

discussed at length in other WGs 

that may serve to inform this 

finding. 

8/29/2014: SC&A recommends 

that this issue remain open.

There are basically two issues 

with applying TIB 13 to 

Fernald 

1. First, NIOSH has agreed 

that the correction factors 

apply to photons but not to 

electrons (betas), which are a 

significant source of exposure 

at Fernald. Consequently, the 

beta-dose correction to the film 

badge readings needs to be reevaluated.

2. Notwithstanding the above 

comment, TIB 13 is "in 

progress." The last revision 

posted on the DCAS Web site is 

dated 2010. There have been 

several reviews, discussions, 

and correspondence from that 

date until February 2013, when 

the last NIOSH response was 

received. However, nothing 

has been done since then. 

Consequently, it is probably 

inappropriate to cite TIB 13 as 

The revision to ORAUTTKBS-0017-6, “Fernald Site –

Occupational External Dose” 

references DCAS-TIB-0013, 

“Selected Geometric 

Exposure Scenario 

Considerations for External 

Dose Reconstruction at 

Uranium Facilities.”

Since the factor was 

determined by an analysis of 

photon fluence (not dose 

computation), the 

recommendations of the TIB 

would apply to workers 

exposed to thorium as well.

Open
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Finding Text History SC&A NIOSH Response Status

a methodology for DR at 

Fernald when it has not been 

accepted by SC&A or by the 

ABRWH Subcommittee on 

Procedures Review.

TBD

20

Correction factors used 

during an initial period of 

use of thermoluminescent

dosimeters (TLDs) at 

Fernald are not 

scientifically appropriate.

It was discussed specifically during the August 8, 2007, 

meeting (ABRWH 2007, pp. 321–331). Action Item: NIOSH 

will follow up on the doses assigned during beginning years 

with the use of TLD from 1983 to 1985.

It was not discussed in meetings afterwards.

A note in the October 2008 draft matrix indicates: A "Status 

Report - NLO Health Physics Appraisal" dated 7-10-84 (to 

Thiessen from Adams) has been found indicating that changes 

to recorded doses may have made. Interviews are continuing 

to discover if additional corrections were applied. (SC&A 

2008)

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: SC&A will need to 

check the cited references and 

TBD revision to verify. October 

2013 Recommendation holds –

keep open.

8/29/14: SC&A has reviewed 

the process and believes the 

methodology is not without 

error; however, it is consistent 

with other NIOSH assumptions 

that have been accepted (e.g., 

LOD/2 for external dose and 

MDA/2 for internal dose).

The appropriate TLD 

correction factors (based on 

the Gesell algorithm) were 

retroactively applied to 

dosimetry records from the 

beginning of TLD 

implementation (i.e., the 

period 1983–1985) as 

described in “Feed Materials 

Production Center, Final 

Phase-In Report, Volume 4 of 

15, Environment, Safety, and 

Health” (SRDB 3247) and 

“Status Report - NLO Health 

Physics Appraisal, July 10, 

1984” (SRDB 12405). 

Both references describe the 

deficiencies found in the 

original TLD algorithm 

developed by Plato, and the 

studies, comparisons, and 

field work undertaken to 

develop a more precise 

algorithm (the Gesell 

algorithm).

The deficiencies of the Plato 

algorithm affected the 

precision of electron dose 

measurements and resulted in 

overestimates of electron 

dose.

Open
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Finding Text History SC&A NIOSH Response Status

TBD

21

The method for estimating 

external dose to 

unmonitored female 

employees is incomplete 

and its claimant 

favorability has not been 

appropriately 

demonstrated.

This is similar to SEC finding 4.5-5. NIOSH responded as 

follows:

The doses to those female workers who were not 

monitored during two operating periods can be 

reconstructed by at least three methods. They are: 

(1) If the worker in question is doing the same or very 

similar job during periods when she is monitored, that 

dose could be used to adjust the missing dose when 

she wasn’t monitored; (2) Workers who were doing 

the same job and were monitored at the time the 

female wasn’t, could have an equivalent dose assigned

to the unmonitored worker, and (3) Assignment of the 

missed dose as stated in the TBD-Vol 6 of 500 

mrem/yr for the missing time periods, which is known 

to be extremely claimant favorable.

Discussed at the August 8, 2007, meeting – SC&A raised the 

concern that women who worked in the laundry were not 

monitored, but in some cases handled highly contaminated 

laundry. NIOSH stated assigning them a 500 mrem dose 

exceeds recorded doses by operators, which is claimant 

favorable. SC&A states default dose does not address the 

following: (1) the shallow dose to the skin, (2) the extremity 

dose to the forearm/hands, and (3) potential internal exposure 

from airborne contamination created by handling 

contaminated items.

Suggested linking the internal component to SEC Finding 4.1-

3.

Discussed at the November 13, 2007, meeting. Decided this 

was an issue isolated to a few individuals and should be 

evaluated on a case-by-case basis in DR.

April 22, 3009, meeting: Issue closed. Decided three 

methods suggested are sufficient.

10/15/2013: SC&A recommends 

finding be changed to " in 

abeyance" until agreed upon 

method is incorporated into the 

TBD

4/10/2014: October 2013 

recommendation holds – keep in 

abeyance pending review of 

ORAUT-TKBS-0017-6 to verify 

that the revision adequately 

addresses our concerns.

4/15/2014: WG decided to put 

#13 and #21 (internal and 

external dose aspects, 

respectively) in abeyance (pp. 

74-78 of 4/15/14 transcript)

8/29/2014: SC&A has reviewed 

pertinent sections of ORAUTTKBS-0017-6 Rev. 1 and 

Attachment A and confirmed 

NIOSH’s statements that 

missed dose is no longer used to 

assign unmonitored external 

doses and the 500 mrem upper 

bound dose methodology has 

been removed. Further, 

Section 6.6.2 of the TBD 

revision refers to ORAUTOTIB-0017, Technical 

Information Bulletin: 

Interpretation of Dosimetry 

Data for Assignment of Shallow 

Dose (10/11/2005). The section 

titled Non-Uniform Exposure 

of the Skin has been further 

clarified at numerous work 

See NIOSH Response #13.

In 

abeyance
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Finding Text History SC&A NIOSH Response Status

group meetings. See SC&A 

response to Finding 16 in the 

attachment for additional 

detail.

Recommend closure.

TBD

22

The source term for 

atmospheric uranium 

emissions from Fernald is 

significantly 

underestimated.

This was discussed briefly in the November 24, 2007, meeting 

(pg. 247), but was not discussed further.

10/15/2013: SC&A recommends 

that this finding remain “open” as 

a topic for WG discussion.

4/10/2014: October 2013 

recommendation holds – keep 

open. SC&A will need to review 

ORAUT-TKBS-0017-4 Rev. 02

to determine whether our 

concerns are adequately 

addressed.

8/25/2014: SC&A recommends 

closure (see attachment for 

detailed description).

From October 24, 2007,

meeting, NIOSH believes that 

stacks were functional and 

that the majority of source 

material was released from 

here, by design, therefore; the 

emissions are not 

underestimated. 

The stack emission data was 

used in the ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose” revision 

for the operational period.

open

TBD

23

The TBD has not 

adequately considered 

various aspects of internal 

environmental dose, 

including the applicability 

of the Gaussian model, 

episodic releases, and 

particle size.

Episodic releases were discussed at the August 8, 2007, 

meeting (pg. 38). NIOSH used RAC Report Number CDC-5 

to establish the source term. The new model incorporates 

evaluations for episodic releases that occurred. NIOSH 

indicates that assuming a chronic exposure based on positive 

bioassays is more claimant favorable than reconstructing 

individual acute intakes.

It does not appear that Gaussian model and particle size have 

been discussed outside the K-65 radon issue (Primary SEC 

Issue 5).

10/15/2013: SC&A recommends 

that this finding remain “open” as 

a topic for WG discussion.

4/10/2014: October 2013 

recommendation holds – keep 

open. SC&A will need to review 

ORAUT-TKBS-0017-4 Rev. 02

to determine whether our 

concerns are adequately 

addressed.

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision uses a 

standard annualized Gaussian 

model including assumptions

regarding atmospheric 

stability that are claimant 

favorable.

Short-term episodic releases 

are modeled using the "Puff" 

model instead of the 

continuous release model. A 

factor to account for 

respirable fraction of particles 

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Finding Text History SC&A NIOSH Response Status

8/25/2014: SC&A recommends 

closure (see attachment for 

detailed description).

is included. 

TBD

24

Diffuse emissions of 

uranium and thorium may 

have produced significant 

internal exposures for 

some personnel.

This topic has not previously been discussed. 10/15/2013: SC&A recommends 

that this finding remain “open” as 

a topic for WG discussion.

4/10/2014: October 2013 

recommendation holds – keep 

open. SC&A will need to review 

ORAUT-TKBS-0017-4 revision 

to determine whether our 

concerns are adequately 

addressed

8/25/2014: SC&A recommends 

keeping this issue open for 

discussion (see attachment for 

detailed description).

See NIOSH response to #22. 

In addition to stack effluent 

for the operational period, 

NIOSH has identified releases 

of thorium and uranium that 

emerged from building 

exhaust, waste pits, UF6

release from storage 

containers and six specifically 

identified off-normal events. 

NIOSH is unaware of any 

additional significant sources.

Open

TBD

25

NIOSH’s modeling of 

radon dose is not claimant 

favorable and does not 

take actual working 

conditions into account.

This topic has not previously been discussed. 10/15/2013: SC&A suggests this 

finding be subsumed into SEC 

Primary Issue #5 (moved to TBD 

issues April 2011).

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-4 Rev. 02 to determine 

whether our concerns are 

adequately addressed.

8/29/2014: See response to SEC 

Issue 5.

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision incorporates 

radon intake modeling which 

has been included in Gaussian 

dispersion calculations. 100% 

of radon and progeny are 

assumed to respirable. 

An assumption regarding the 

equilibrium between radon 

and progeny has been made 

that is favorable to the 

claimant and likely to exist 

only indoors under stagnant 

air flow conditions.

Open
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Finding Text History SC&A NIOSH Response Status

TBD

26

NIOSH has not 

considered a major source 

of radon dose—the 

storage source of 

pitchblende ore onsite 

near Plant 1.

This was discussed at the August 8, 2007, meeting. 

Pitchblende ore storage from the Q-11 silos was identified in 

the Pinney Report (O drive). They were added to the radon 

source term. It appears that the bins were located on the south 

side of Plant 1.

10/24/07 – Research compiled by Susan Penny of U of C took 

into consideration in addition to the K-65 silos other potential 

source terms of radon. And those included some of those 

specific bins outside of the refinery, in which the Q-11 ore 

was contained.

10/28/08 (pg. 258) – Discussion again on how the Pinney 

Report included Q-11 silos as a contributor to radon 

exposures.

4/22/09 – Discussions on Q-11 became blended with 

discussions on SEC Issue 4.2-1. NIOSH indicated that they 

are already updating the TBD to include the Pinney report, 

which includes the Q-11. It was debated changing 4.2-1 to a 

TBD issue, but no decision was reached.

1/29/10 – The Q-11 source term is separate from the K-65 

source term in the Pinney report and should be discussed 

separately when modeling dose. Q-11 appears to be the 

dominate source term in the beginning years. SC&A will 

look at the report NIOSH prepared.

11/09/10 – More discussions on the pulmonary and skin 

implications in a DR of Q-11. SC&A to produce white paper 

on disagreements in source term and if SC&A can buy off on 

the NIOSH suggested approach.

2/8/11 – Anigstein states our opinion is that NIOSH has not 

demonstrated that the ranges can be bounded, though SC&A 

thinks they can be. But to do that they have to have a model 

that is validated and scientifically robust. Board decides this 

should be considered a TBD issue and was no longer 

discussed.

10/15/2013: SC&A suggests this 

finding be subsumed into SEC 

Primary Issue #5 (moved to TBD 

issues April 2011).

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-4 Rev. 02 to determine 

whether our concerns are 

adequately addressed.

8/29/2014: See response to SEC 

Issue 5.

The ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision includes 

effluent from Q11 silos. 

Open
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Finding Text History SC&A NIOSH Response Status

TBD

27

The TBD does not 

consider outdoor diffuse 

emissions in production 

areas as a source of 

external environmental 

dose.

This topic has not previously been discussed. 10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-4 Rev. 02 to determine 

whether our concerns are 

adequately addressed.

8/25/2014: SC&A recommends 

closure (see attachment for 

detailed description).

The “Exposure Areas” 

concept is also applied to 

external dose consistent with 

the NIOSH position on Item 

22 for the ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose” 

revision. 

Open

TBD

28

External environmental 

dose for workers near the 

K-65 silos needs to be 

better evaluated.

Finding 28 is discussed in Section 5.9.2 of SC&A’s 2006 

review of the Fernald site profile. The full text of this issue is 

relatively brief and is repeated here:

The TBD is silent on how external doses to workers from the 

silos were derived for persons that may have spent time in the 

area of Fernald containing the silos (i.e., EA-6). This is of 

particular concern for the early years before additional 

shielding was provided for the silos. It is also of concern for 

those unmonitored workers who may have taken breaks near 

the silos. For instance, it may especially affect female 

employees during the years when they were not monitored.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-4 Rev. 02 to determine

whether our concerns are 

adequately addressed.

8/29/2014: SC&A recommends 

closure (see attachment for 

detailed description).

The external environmental 

dose for workers near the K65 silos is addressed in the 

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision. 

Open

TBD

29

Occupational internal 

exposure to radon is 

estimated based on just 

two radon data points 

from 1953. This is an 

inadequate basis to 

reconstruct occupational 

radon dose.

This issue is not related to radon emanating from the silos, but 

to the radon and radon progeny inhaled during drum 

unloading when Silos 1 and 2 were being filled. It is not clear 

whether this issue was discussed and/or resolved in the WG. 

Need more research.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-4 Rev. 02 to determine 

whether our concerns are 

adequately addressed.

8/29/2014: NIOSH’s 

Radon from the material 

stored in drums at Plant 1 is 

now a source term for 1951, 

1952, and 1953 before the 

material was moved into the 

K65 silo in the ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revision. NIOSH has 

recommended that 1953 radon 

Open
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Finding Text History SC&A NIOSH Response Status

recommendation that 1953 

radon exposure be added to the 

SEC would make this finding 

moot. However, SC&A has 

seen no description of the 

proposed class or mention of it

other than in this issues matrix 

entry. We recommend keeping 

this finding open for discussion 

in the Work Group setting.

exposure be added to the SEC.

TBD

30

The possible use of 

photofluorography (PFG) 

at Fernald in the early 

years was ruled out in the 

TBD without adequate 

documentation. This is 

contrary to NIOSH 

general guidance and is 

not claimant favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-3 Rev. 01 to determine 

whether our concerns are 

adequately addressed.

8/29/2014 – see attachment for 

detailed response for Findings 

30–32).

No evidence of PFG has yet 

turned up for Fernald. This 

includes no evidence in claim 

files, no historical 

documentation of PFG 

equipment, and no evidence in 

several reviews of actual film 

folders of Fernald workers 

that have been performed over 

the years.

Open

TBD

31

The assumption that there 

was a 15% retake rate for 

x-rays is not adequately 

documented or analyzed.

This topic has not previously been discussed. 10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue be held in abeyance until

SC&A verifies the stated change 

to ORAUT-TKBS-0017-3 Rev.

01.

8/29/2014 – see attachment for 

detailed response for Findings 

30–32)

The reference for this piece of 

information was not found in 

the historical information, and 

so it was removed from the 

revision of ORAUT-TKBS0017-3, “Fernald 

Environmental Management 

Project – Occupational 

Medical Dose.”

In 

Abeyance
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TBD

32

The assumption that there 

was collimation is not 

technically justifiable 

based on the evidence 

provided in the TBD and 

is not claimant favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review ORAUT-TKBS0017-3 Rev. 01 to determine 

whether our concerns are 

adequately addressed.

8/29/2014 – see attachment for 

detailed response for Findings 

30–32)

The current version of the 

ORAUT-TKBS-0017-3, 

“Fernald Environmental 

Management Project –

Occupational Medical Dose,”

assumes poor collimation 

prior to 1970.

open

TBD

33

NIOSH has prematurely 

concluded that lumbar 

spine x-rays for laborers 

and construction workers 

were not conditions of 

employment. Based on 

the evidence provided, 

this assumption is not 

sufficiently documented 

and is not claimant 

favorable.

This topic has not previously been discussed. However, the 

same issue has been discussed in other WG meetings which 

may inform the resolution of this finding.

10/15/2013: SC&A recommends 

finding be classified “open” as a 

topic for WG discussion.

4/10/2014: Recommend that this 

issue remains open. SC&A will 

need to review the stated claim 

file records to determine whether 

our concerns are adequately 

addressed.

8/29/2014: SC&A has also 

reviewed more than 30 cases 

focusing on Laborers and other 

trades workers whose job 

duties might include heavy 

lifting and came to the same 

conclusion NIOSH did. Any 

sort of lumbar or spinal x-ray 

was designated as 

“dispensary.” Pre-employment 

physicals only ever included a 

chest x-ray. The preemployment questionnaire and 

It is very clear that the few 

lumbar spine x-rays in claim 

file records ([redact], 

[redact], [redact], [redact]) 

are indicated as having been 

performed for “dispensary” 

and not “annual,” “pre,” or 

“term”; very strongly 

suggesting that lumbar spine 

x-rays were performed for 

back pain (a common 

ailment), or for workplace 

injuries, not for screening. 

31 claims out of 1,790 work 

periods/claims were reviewed 

and there were 0 nondispensary lumbar spines in 

this random sample.

Open
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Finding Text History SC&A NIOSH Response Status

medical evaluation (present in 

some reviewed claim) contains 

a section on x-rays with only a 

checkbox for “chest.”

SEC P

3

Default concentrations (on 

U mass basis) of Pu-239, 

Np-237, and other 

isotopes associated with 

RU at Fernald may not be 

bounding for some classes 

of worker activities, 

buildings, and time 

periods.

After many white paper exchanges and deliberations, NIOSH 

demonstrated that they could place a plausible upper bound on 

intakes from the three principal RU constituents.

10/15/2013: SC&A recommends 

issue be placed “in abeyance” 

until implemented in Site Profile.

4/10/2014: Recommend that 

related site profile issues be 

placed in abeyance. SC&A will 

need to review relevant TBD 

revisions to determine whether 

our concerns are adequately 

addressed. See response to 

Finding #9.

8/25/2014: SC&A recommends 

that this finding be kept in 

abeyance pending revision of 

ORAUT-TKBS-0017-5.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

provides an upper bound on 

intakes from RU constituents 

for all workers, which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” and ORAUT-TKBS0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions. 

In 

Abeyance

SEC P

4

Use of radon breath data 

for reconstructing doses 

from inhalation of Ra-226 

and Th-230.

SC&A agrees – radon breath analysis is a scientifically valid 

method for reconstructing the intake of Ra-226 and Th-230 

when the intake ratios of the two radionuclides are known and 

the impacted worker population can be identified.

April 15, 2011: NIOSH posted a response [in ORAUTRPRT-0052 (ORAUT 2011)] to SC&A’s white paper, Review 

of the NIOSH “White Paper on Fernald Th-230 and Other 

Associated Radionuclides – Rev. 7,” (SC&A 2010) that 

summarizes their position.

10/15/2013: SC&A recommends 

issue be placed “in abeyance” 

until implemented in Site Profile.

4/10/2014: Recommend that 

related site profile issues be 

placed in abeyance. SC&A will 

need to review relevant TBD 

revisions when they become 

available to determine whether 

our concerns are adequately 

addressed.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides a method for use of 

radon breath data for 

reconstructing doses from 

inhalation of Ra-226 and Th230 which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

In 

Abeyance
Effective Date:

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Finding Text History SC&A NIOSH Response Status

8/29/2014: SC&A recommends 

that this finding be kept in 

abeyance pending revision of 

ORAUT-TKBS-0017-5.

Dose.” 

For ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revisions, intake rates 

for Ra-226 and Th-230 have 

been modeled based on a 

source term associated with 

the uranium stack effluent 

from Plant 2/3. This material 

may have included Ra-226 

and Th-230 impurities that 

were not removed in the ore 

milling process that occurred 

at different vendor facilities. 

Otherwise, radon breath 

analysis is not pertinent to 

environmental intake rates.

SEC P

5

Radon release rate from 

the K-65 silos as 

estimated by NIOSH 

substantially 

underestimated. Method 

to derive the atmospheric 

dispersion factors, given 

the source term, is 

scientifically flawed, but 

results in an overestimate 

of the atmospheric 

dispersion factors at 

receptor locations (still 

does not compensate for 

underestimated source 

term).

Numerous white papers have been exchanged; Both sides 

‘agree to disagree.’

NIOSH to consider rescinding its technical guidance 

regarding the K-65 silos based on what SC&A believes is a 

flawed source term and atmospheric dispersion model and its 

conclusions regarding the validity of their model based on the 

Pinney reports.

April 19, 2011 – Board agrees to remove from SEC issues to 

TBD Issues.

10/15/2013: Open site profile 

issue.

4/10/2014: See response to 

Finding #28. Open issues will 

need to be taken up in a site 

profile context. – Topic for future 

WG deliberations. 

8/14/2014: Subsumes related 

SP findings (25, 26). These 

issues have not been discussed 

since April 2011. SC&A 

recommends that this issue and 

related SP findings be resolved 

in the Work Group setting. 

SC&A has prepared a series of 

white papers that have been 

discussed in several Work 

ORAUT-RPRP-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” 

presents what NIOSH 

believes is the best available 

analysis of annual radon 

effluent from the K-65 silos. 

The result of that analysis is 

70.4 Ci/year. In the interest of 

being claimant favorable, 

ORAUT-RPRP-0052 

recommends that the radon 

effluent values stated in 

ORAUT-TKBS-0017-5,

“Technical Basis Document 

for the Fernald Environmental 

Management Project (FEMP) 

– Occupational Internal 

Dose,” be used. 

This value of 5,000 to 6,000 

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Finding Text History SC&A NIOSH Response Status

Group meetings. While we 

acknowledge that the number 

of affected claimants is likely 

small, given that the SEC for 

all workers extends from 1954 

1978, we nonetheless stand by 

the positions articulated in 

those white papers.

The SC&A white papers are 

available on the O-drive at:

ABRWH\AB Document 

Review\Fernald\SC&A Work 

Products for SEC Issues 

Resolution\Issue #5 K-65 Silo 

radon emissions

Ci/y is similar to the value of 

6,700 Ci recommended in the 

RAC report. 

SEC P

6b

Use of chest counts to 

reconstruct Th-232 

exposures (1968–1988).

1968–1978 – Reported in milligrams thorium. SEC voted 

April 2012 based on inadequacy of the activity to mass 

conversion algorithm (now SEC class).

1979–1988 – Reported in activity (nCi) Pb-212 and Ac-228.

10/15/2013: Implementation of a 

coworker model is an ongoing 

site profile issue for 1979–1988.

4/10/2014: Ongoing – topic for 

future WG deliberations.

8/25/2014: This issue has been 

discussed extensively in Work 

Group meetings and SC&A is 

in general agreement with 

NIOSH on their methodology 

for using the chest count data 

reported in activity (nCi) 

Pb-212 and Ac-228 for 1979-

1988. 

Nonetheless, SC&A 

recommends keeping this 

finding open pending our 

formal review of the NIOSH 

A thorium coworker model is 

in development.

Open
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Finding Text History SC&A NIOSH Response Status

white paper on post-SEC 

thorium methodology (mid-late 

October 2014).

SEC

4.5-1

Absence of Performance 

Standards/Quality 

Assurance for Personnel 

Dosimeters. This issue 

goes toward the 

availability of approved 

standardized procedures 

for performing external 

dosimetry and adequacy 

of the training and 

qualifications of personnel 

performing external 

dosimetry.

NIOSH responded:

The Oak Ridge film dosimeter, which was the 

dosimeter used at FMPC, was included in external 

dosimeter intercomparison studies and did 

compare with other AEC sites’ dosimeters very 

well. Discussions held with former FMPC 

employees involved with the early dosimetry 

program from startup through 1985 have revealed 

that written instructions did exist, but to date none 

could be identified. ... NIOSH will attempt to 

recover QA intercomparison studies or internal 

studies (Herb Parker report and other reports). 

NIOSH will also attempt to identify procedures 

and/or QA reports from the early time period (53–

85).

11/13/2007 – The Parker report (SRDB 433) showed that the 

three dosimeters performed very well in the measurement of 

exposures to uranium. The OR dosimeter was used at FEMP 

for several years and modifications were made to it.

3/26/08 – SC&A raises concerns about qualifications of badge 

technicians.

10/28/08 – NIOSH will attempt to make more information 

available on O drive from data capture.

It is not evident that this issue was closed by the WG.

10/15/2013: This issue is 

apparently open for WG 

deliberation.

4/10/2014: – Open – topic for 

future WG deliberations. SC&A 

will need to review the cited 

SRDB references.

8/25/2014: SC&A has carefully 

reviewed the referenced SRDB 

reports #2921, #4330, #4618, 

#4204, #439, and #8599

provided by NIOSH and 

conclude these reports bear

little relevance to Finding 4.5-1.

Finding 4.5-1 specifically 

discussed several limitations 

identified in a document 

entitled, “Response to 

Dosimetry Assessment Fact 

Sheet,” submitted by NLO, Inc. 

on September 11, 1981, in 

response to a DOE inquiry. As 

stated in the summary of our 

original finding (SCA-SECTASK5-0056, Section 4.5, page 

112), SC&A did not question 

the merits/use of the dosimetry 

data, but implies the need to

consider the quality of these 

data in context with stated 

limitations. It is SC&A’s 

recommendation to account for 

these limitations by expanding 

the range of uncertainty that is 

SRDB Reference ID #2921, 

“Health Protection Program 

Review,” from November 

1962 concurs with the 

proposal to issue an FMPC 

Nuclear Safety Guide. This 

Guide and the Industrial 

Hygiene and the Radiation 

Department Procedures 

Manual should provide 

sufficient criteria to permit 

operating groups to accept 

health and safety 

responsibility without 

excessive audit.

Several other references exist 

in the SRDB that support the 

adequacy of the external 

dosimetry program at Fernald, 

some of which include 4330, 

4618, 4204, 439, 8599.

Open
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Finding Text History SC&A NIOSH Response Status

normally afforded to personnel 

dosimeters that were used at 

the time.
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REFERENCES 

ABRWH 2007. Transcript: Working Group Meeting, Advisory Board on Radiation and Worker 

Health, Fernald, held in Cincinnati, Ohio, on August 8, 2007. 

ABRWH 2011. Transcript: Advisory Board on Radiation and Worker Health, Work Group on 

Fernald, held in Cincinnati, Ohio, on April 11, 2011. 

DCAS 2010. Selected Geometric Exposure Scenario Considerations for External Dose 

Reconstruction at Uranium Facilities, Rev. 1, DCAS-TIB-0013. Division of Compensation 

Analysis and Support, NIOSH, Cincinnati, Ohio. November 23, 2010. 

FEMP 1998. External Dosimetry Program Development History, Fernald Environmental 

Management Program, Cincinnati, Ohio. January 22, 1998. SRDB Ref ID 4330. 

NLO 1952. Personnel Film Badge Data. National Lead of Ohio, Cincinnati, Ohio. 1952. 

SRDB Ref ID 3173. 

NLO 1959. Internal memorandum: 1958 Annual Report, Radiation & Effluent Control Section. 

National Lead of Ohio, Cincinnati, Ohio. February 27, 1959. SRDB Ref ID 4136. 

NLO 1965. Procedure Manual – Industrial Hygiene and Radiation Department, Health and 

Safety Division. Includes Standard Operating Procedure for Information Reports. National Lead 

of Ohio, Cincinnati, Ohio. September 28, 1965. SRDB Ref ID 33975. 

OCAS 2004. Estimation of Ingestion Intakes, OCAS-TIB-009, Rev. 0. Office of Compensation 

Analysis and Support, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

April 13, 2004. 

ORAUT 2004. Feed Materials Production Center – Occupational Internal Dose, Rev. 00, 

ORAUT-TKBS-0017-5. Oak Ridge Associated Universities Team, Cincinnati, Ohio. May 28, 

2004.

ORAUT 2005a. Interpretation of Dosimetry Data for Assignment of Shallow Dose, Rev. 01, 

ORAUT-OTIB-0017. Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 11, 

2005.

ORAUT 2005b. Estimation of Radium-226 Activity in the Body from Breath Radon-222 

Measurements, Rev. 00, ORAUT-OTIB-0025. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. April 5, 2005. 

ORAUT 2007a. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. August 7, 2007. SRDB Ref ID 41661.

ORAUT 2007b. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. August 30, 2007. SRDB Ref ID 38124.
Effective Date:

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ORAUT 2007c. Transcribed interviews with [redact] and [redact]. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. September 11, 2007. SRDB Ref ID 38132.

ORAUT 2008. External Coworker Dosimetry Data for the Fernald Environmental Management 

Project, Rev. 00, ORAUT-OTIB-0073. Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. September 22, 2008. 

ORAUT 2011. Feed Materials Production Center Internal Dose Topics, ORAUT-RPRT-0052, 

Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. July 12, 2011.

ORAUT 2014a. Fernald Environmental Management Project – Occupational Medical Dose, 

Rev. 01, ORAUT-TKBS-0017-3. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

January 2, 2014. 

ORAUT 2014b. Feed Materials Production Center – Occupational Environmental Dose, 

Rev. 02, ORAUT-TKBS-0017-4. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

March 13, 2014. 

ORAUT 2014c. Feed Materials Production Center – Occupational External Dose, Rev. 01, 

ORAUT-TKBS-0017-6. Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 25, 

2014.

ORAUT 2014d. Feed Materials Production Center – Site Description, Rev. 01, ORAUTTKBS-0017-2. Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 31, 2014. 

Parker, H.M., 1945. Comparison of Film Badge Readings. Memo to file. (Document marked 

“Publicly Available”). December 7, 1945. SRDB Ref ID 439.

Pinney, S., R. Hornung, J. Lodwick, G. Killough, D. Brewer, and J. Nastua, 2008. “Estimation 

of radon exposure to workers at the Fernald Feed Materials Production Center,” Journal of 

Exposure Science and Environmental Epidemiology, 2008.

RAC 1995. The Fernald Dosimetry Reconstruction Project, Tasks 2 and 3 Radionuclide Source 

Terms and Uncertainties, RAC Report No. CDC-5. Radiological Assessments Corporation, 

Neeses, South Carolina, 1995. 

SC&A 2006. Review of the NIOSH Site Profile for the Fernald Environmental Management Project 

(Feed Materials Production Center), SCA-TR-TASK1-0010, Rev. 0. SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. November 10, 2006.

SC&A 2008. Memo to the Fernald Work Group from J. Mauro (SC&A), Subj: Matrix for use at 

the Fernald Work Group Meeting Scheduled for October 28th, 2008. SC&A, Inc., Vienna, 

Virginia, and Saliant, Inc., Jefferson, Maryland. October 14, 2008. 
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SC&A 2010. Review of the NIOSH “White Paper on Fernald Th-230 and Other Associated 

Radionuclides – Rev. 7,” Rev. 0. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. May 2010.

SC&A 2012. SC&A’S Response to NIOSH’s Subgroup 10A Impact Analysis Dated November 1, 

2011, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. February 6, 2012.

SC&A 2014. Memo from J. Mauro (SC&A) to the Procedures Review Subcommittee. Subject: 

SC&A Position Regarding Skin Exposures Associated with the Direct Deposition of Fine 

Particles and Flakes of Uranium Oxide onto Skin and Clothing, SC&A, Inc., Vienna, Virginia, 

and Saliant, Inc., Jefferson, Maryland. January 7, 2014.
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Attachment – Detailed SC&A Updates to Selected Findings

Finding 16

Section 6.6.2 of the Fernald site profile (ORAUT-TKBS-0017-06, March 25, 2014) refers to 

ORAUT-OTIB-0017, Technical Information Bulletin: Interpretation of Dosimetry Data for 

Assignment of Shallow Dose (October 11, 2005). The section titled “Non-Uniform Exposure of 

the Skin” addresses this subject, which has been further clarified at numerous work group 

meetings. The section explains that, when only a portion of skin is exposed and there is reason 

to believe that a diagnosed skin cancer occurred within that location, the localized dose should be 

used as input to IREP (i.e., do not dilute the exposure over the entire surface area of the skin). 

OTIB-0017 does not explicitly address the direct deposition of particles onto the surface of the 

skin, but the natural extension of OTIB-0017 guidance would indicate that this strategy also 

applies to exposures of the skin directly beneath a particle deposited on the skin, if there is 

affirmative evidence that such exposures might have occurred, as might be indicated in the 

Computer-Assisted Telephone Interview (CATI) or the worker’s records. This latter 

interpretation of OTIB-0017 has been confirmed at meetings of the Procedures Review and Dose 

Reconstruction Subcommittees and at site profile work group meetings. (see SC&A Position 

Regarding Skin Exposures Associated with the Direct Deposition of Fine Particles and Flakes of 

Uranium Oxide onto Skin and Clothing, January 2014, and the resolution of this specific issue 

during the Procedures Review Subcommittee meeting held on February 13, 2014, page 42–52). 

Hence, SC&A recommends closure of this issue. However, we also recommend that dose 

reconstructors remain diligent in implementing this unique aspect of OTIB-0017.

Finding 17

Section 6.11 of the site profile, titled “Geometric Correction Factors,” cites DCAS-TIB-0013, 

Selected Geometric Exposure Scenario Considerations for External Dose Reconstruction at 

Uranium Facilities (NIOSH 2010), as a means to address extremity doses. TIB-0013 is limited 

to the development of correction factors for photon exposures of the abdomen or extremities 

based on recorded photon exposures on lapel dosimeters and for specific geometries, such as 

cleaning up a spill on the floor, working with a uranium ingot, drum, or denitration pot. The 

correction factors, which range from about 1.5 to 3.5n were derived using models and also 

empirical data where both wrist and lapel dosimeters were used.

This procedure has been previously reviewed by the procedures subcommittee and its issues 

have been largely resolved. However, this procedure is silent regarding non-penetrating doses to 

the skin of the extremities. This issue is currently being reviewed as part of the site profile 

review for the Idaho National Laboratory (INL). In that review, NIOSH identified 62 skin 

cancer extremities, and SC&A is currently investigating the methods used to reconstruct those 

doses. SC&A recommends that this issue remain opened while the INL investigations proceed.

Finding 22

As indicated in the matrix, on April 10, 2014, SC&A recommended that this issue should remain 

open so that SC&A has an opportunity to evaluate this finding as now addressed in ORAUT-
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TKBS-0017-4, Fernald Environmental Management Project – Occupational Environmental 

Dose, Revision 3, March 13, 2014 (referred to here as the Fernald 2014 site profile).

By way of background information, this issue was first raised in SC&A’s November 6, 2006 

initial review of the Fernald site profile dated April 6, 2004. We thought it prudent to reiterate 

the original issue and summarize how it is now addressed in the March 13, 2014, version of the 

Fernald site profile, within the context of all that has transpired with respect to issues resolutions 

on other matters and Special Exposure Cohorts (SECs) that have been granted.

Inspection of Finding 22 located in Section 5.7.1 of SC&A’s November 6, 2006, site profile 

review raises an issue with the estimated atmospheric release of uranium based on a series of 

reports that reveal that estimates of the atmospheric release of uranium were revised a number of 

times, and that the site profile at that time did not take into consideration the most recent 

estimates. The specific concern raised by SC&A was that the site profile uses data compiled by 

Boback et al. (1987) as updated by Dolan and Hill (1988)1and RAC (1995) as the bases for the 

estimated annual atmospheric releases. However, SC&A was critical of the site profile because 

it makes no mention of work by Clark et al. 1989.

2

A number of developments have transpired on this project since the preparation of the first 

Fernald site profile and SC&A’s review of the site profile in 2006, which makes this issue 

somewhat moot. First, the vast majority of internal uranium dose reconstructions for workers at 

NIOSH are based on bioassay samples because over 90% of the workers were under a bioassay 

program after the early 1950s. In addition, three classes of Fernald workers have been added to 

the SEC, including subcontractors at Fernald who were not adequately covered by the bioassay 

program (1951–1983). However, there is still a need to perform partial dose reconstructions for 

workers who are not covered by the SEC and/or who do not have bioassay data. Therefore, there 

are circumstances where internal doses associated with the atmospheric releases of uranium 

might be required. Section 4.4 of the March 13, 2014, site profile presents the methods NIOSH 

plans to use to reconstruct internal exposures to uranium in atmospheric effluents. Section 

4.4.1.1 states that:

For the purpose of environmental dose reconstruction, this TBD uses the larger of 

the emissions quantities from either Voillequé et al. (1995) or Boback et al. 

(1987). The values for routine and nonroutine uranium discharges from 

operations and episodic releases during the operating years are from Voillequé 

et al.

This is the same language used in the original site profile, and any issues with these data as 

provided by Clark et al. 1989 are still not addressed.

 

 

1 The TBD erroneously refers to this publication as Dolan and Dolan 1988 (TBD Vol. 4, p. 9). The 

reference list for this publication should also be corrected from “Dolan, L.C. and C.A. Dolan...” to “Dolan, L.C. and 

C.A. Hill...”

2 Clark, T.R., L. Eiikan, C.A. Hill, and B.L. Speicher, 1989. History of FMPC Radionuclide Emissions: 

Revised Estimates of Uranium and Thorium Air Emissions from 1951 to 1987, Addendum to FMPC-2082, Special 

UC-702, Westinghouse Materials Company of Ohio, Cincinnati, Ohio. March 1989.
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In order to help close out this issue, we reviewed the Clark et al. 1989 report to determine if the 

source term information is somehow incompatible with the current source terms used in the 2014 

version of the Fernald site profile. Table 4-5 of the 2014 site profile presents estimates of the 

total atmospheric release of uranium by year from 1951 through 1988 for each of 12 different 

sources of emissions. The grand total is 308,495 kg. The question is, is the information 

provided in the Clark et. al. 1989 report incompatible with the values used in the site profile in 

Table 4-5.

 

As described in the introduction of Clark et al. 1989:

The review for additional radionuclide air sources required a re-creation of the 

history of operations at the FMPC. This was done by reviewing plant records and 

interviewing long term employees. While these efforts enabled the authors to prepare 

a revised estimate, the 37-year history of FMPC radionuclide air emissions cannot be 

prepared without some degree of uncertainty. The factors which introduce 

uncertainty into the historic air emission estimate include:

 Documentation of all operations and events did not exist or could not be found.

 Personal recall of events was useful, but is incomplete and was not always 

consistent.

 Some measurements necessary to calculate emissions were not recorded or 

archived. 

The summary of the report states the following:

This study results in estimated uranium air emissions of 179,000 kg and an 

estimated thorium air emission of 6500 kg for the years of 1951 through 1987.

It certainly appears that the estimate of the total uranium emissions to the atmosphere used in the 

2014 Fernald site profile of 308,495 kg is substantially larger than the estimate provided by 

Clark et al, 1989. Hence, SC&A recommends that this issue be closed.

As a postscript to this finding, SC&A believes that any internal doses associated with uranium 

atmospheric releases for workers who do not have bioassay data and are not covered by the SEC 

are best performed using a coworker model constructed using bioassay data and not atmospheric 

releases and dispersion modeling, especially considering the large uncertainties associated with 

reconstructing such doses; i.e., you need some knowledge of the location of the worker at the 

time of the releases, information that is generally not available. In addition, if, the source terms 

are needed for dose reconstructions, such as for workers outdoors, without bioassay data, and are 

not covered by the site profile, the source term data provided in the 2014 version of the site 

profile certainly appears to be scientifically sound and claimant favorable. 

Finding 23

Section 5.7.2 of SC&A’s 2006 review of the Fernald site profile explains that many of the source 

terms are episodic, and we expressed concern that standard Gaussian modeling using annual joint 
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frequency data to derive average annual chi/Q values at receptor locations to reconstruct doses to 

workers without bioassay data might not be claimant favorable. Section 4.4.1.3.6 of the Fernald 

2014 site profile explicitly addresses the methods that NIOSH plans to use to reconstruct outdoor 

exposures to episodic releases (presumably for workers without bioassay data and not covered by 

the SEC). Table 4-6 of the 2014 site profile lists 6 significant episodic releases that occurred 

over a period of less than 1 day (we agree that these are the types of releases that were of concern 

to SC&A in our original review of the site profile in 2006). Equation 4-7 of the 2014 site profile 

presents the atmospheric diffusion equation that will be used to model the atmospheric 

dispersion factors for these releases. This model was taken from Slade (1968), which is 

recognized as one of the seminal documents on atomic energy and meteorology. The model 

specifically takes into consideration the wind speed, direction and stability class at the time of 

the episodic release, using conservative values for these parameters if the joint frequency data 

are not available for the specific time of a given episodic release. SC&A believes that this 

material is fully responsive to our original concerns and recommends that this finding be closed.

Finding 24

This issue is discussed in Section 5.7.3 of SC&A 2006 review of the Fernald site profile. 

SC&A’s concern at the time was that, though the site profile addressed the diffuse emissions 

from the waste pits caused by wind erosion, it did not address potentially important sources of 

diffuse emissions at Fernald, many of which are described in SC&A’s review of this issue, such 

as:

 “Outside Williams Mill” (General Air, 44.3 MAC)

 “Breaking Salt at outside mill” (Breathing Zone, 30.8 MAC)

 “Shovelling onto conveyor at outside mill” (Breathing Zone, 137.80 MAC)

 “Changing drums at outside mill” (Breathing Zone, 122.90 MAC)

These are issues separate from episodic releases because they are highly localized, ground level 

releases that cannot be readily modeled. What is needed is an upper-bound estimate of the 

localized airborne concentrations (such as the above bulleted items) of these types of windblown 

fugitive emissions, and then use these concentrations and appropriate exposure durations to 

derive intakes and doses. Of course, this would only apply to workers that were not on a routine 

bioassay program for the radionuclides of interest and were not covered by the SEC. 

The 2014 site profile does not explicitly address this issue, but explains in the matrix that:

In addition to stack effluent for the operational period, NIOSH has identified 

releases of thorium and uranium that emerged from building exhaust, waste pits, 

UF6 release from storage containers and six specifically identified off-normal 

events. NIOSH is unaware of any additional significant sources.

It is not apparent that identifying the quantities of releases from building exhaust, waste pits, UF6

release from storage containers and six specifically identified off-normal events adequately 

addresses this issue, because we can envision a worker located near these localized fugitive 

emissions for protracted periods of time, and the atmospheric modeling methods, even the 
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episodic release protocols, do not address this unique set of potential conditions. We suspect that 

this level of granularity is not possible, because it would require placing specific workers at 

specific locations for known periods of time. Nevertheless, we recommend leaving this issue 

open, so that we can discuss it a little more at the next work group meeting. 

Finding 27

Issue 27 is discussed in Section 5.9.1 of SC&A’s 2006 review of the Fernald site profile. The 

full text of this issue is relatively brief and is repeated here:

Given the documentation regarding high diffuse emissions and high uranium and 

thorium concentrations outdoors (discussed above), it is possible that the external 

environmental dose, other than that from the K-65 silos, may have derived mainly 

from deposition of uranium and thorium dust on workers. For thorium dust, this 

could involve considerable deep dose as well as shallow dose, while for uranium 

it would mean mainly the latter. NIOSH should evaluate the extent of the 

problem, which may have been significant in some outdoor production areas.

NIOSH’s response to this issue as provided in the issues matrix is as follows:

The “Exposure Areas” concept is also applied to external dose consistent with the 

NIOSH position on Item 22 for the ORAUT-TKBS-0017-4, “Fernald 

Environmental Management Project – Occupational Environmental Dose” 

revision.

Section 4.5 of the 2014 Fernald site profile addresses external exposure from ambient radiation. 

This issue applies to unmonitored workers that might have been externally exposed outdoors to 

deposited radionuclides and are not covered by the SEC. Section 4.5 of the 2014 site profile 

explicitly addresses outdoor radiation fields and exposures to the K-65 silos, thorium residues in 

various warehouses throughout the site, and the radionuclides in the Production Plants and other 

onsite facilities. To a lesser extent, the radioactive waste pit area was another direct radiation 

source for unmonitored personnel who worked in that area. Table 4-19 of the 2014 site profile 

presents the results of thermoluminescent dosimeter (TLD) measurements at 10 locations at the

site boundary from 1976 to 1995. Table 4-20 presents the results of TLD measurements at other 

locations, and Figure 4-11 presents the locations of TLD measurements in the vicinity of the 

waste pits from 1996 to 2005. Figures 4-14 and 4-15 present external dose rate contour maps for 

1976 and 1985. Section 4.5.4 presents onsite ambient dose rate estimates, 1952 to 1975. This 

section explains that, since there are no usable external dose rate measurements before 1976, a 

protocol is provided to reconstruct external outdoor exposures due to residual radioactivity 

outdoors at the site. 

Taken in its entirely, it appears that the 2014 site profile provides guidance that can be used to 

reconstruct external exposures outdoors from all sources of stored and residual radioactivity at 

the site. We recommend that this issue be closed with one proviso; we recommend that a 

statement be made in the site profile that exposures to skin will be reconstructed in accordance
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with OTIB-0017 and the commitments agreed to by NIOSH and the Board on how localized 

doses to skin from direct deposition will be reconstructed.

Finding 28

Issue 28 is discussed in Section 5.9.2 of SC&A’s 2006 review of the Fernald site profile. The 

full text of this issue is relatively brief and is repeated here:

The TBD is silent on how external doses to workers from the silos were derived 

for persons that may have spent time in the area of Fernald containing the silos 

(i.e., EA-6). This is of particular concern for the early years before additional 

shielding was provided for the silos. It is also of concern for those unmonitored 

workers who may have taken breaks near the silos. For instance, it may 

especially affect female employees during the years when they were not 

monitored.

NIOSH’s response to this issue as provided in the issues matrix is as follows:

The external environmental dose for workers near the K-65 silos is addressed in 

the ORAUT-TKBS-0017-4, “Fernald Environmental Management Project –

Occupational Environmental Dose,” revision. 

Section 4.5.1 of the 2014 Fernald site profile addresses external exposure from ambient radiation 

associated with the K-65 silos and production plants from 1976–2005, based on TLD 

measurements taken at various locations on the site and at the fence line boundary. Section

4.5.4.1 of the 2014 Fernald site profile address external exposure from ambient radiation 

associated with the K-65 silos prior to 1976. Prior to 1976, average direct dose rates at the K-65 

silo fence line was modeled based on a combination of interpreted historic description of the 

K-65 silo radiation levels and the application of measured dose rate values.

It appears that the 2014 site profile provides guidance that can be used to reconstruct external 

exposures outdoors from the K-65 silos. We recommend that this issue be closed.

Findings 30–32

The Fernald technical basis document (TBD) or site profile for Occupational Medical Dose 

(ORAUT-TKBS-0017-3, Revision 1) was issued on January 2, 2014. We have reviewed this 

TBD and other NIOSH guidance to assess the degree to which these three issues can be closed at 

this time.

The three issues deal with matters that have been of concern on numerous occasions since the 

inception of this program; i.e., under what conditions is it appropriate to assume that workers at a 

given facility should be assigned occupational medical dose, including chest AP and lateral 

x-rays, lumbar spine x-rays, and PFG examinations, and what should be taken into consideration 

when assigning a given dose, such as type of equipment, retakes, collimation, uncertainty, etc. 

A review of the Fernald 2014 site profile reveals that a comprehensive set of instructions are 
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provided on how to reconstruct occupational medical exposures at Fernald. Section 3.2 of the 

TBD explains that pre-employment, annual, and termination examinations were required as a 

condition of employment from the beginning of operations in 1952, but evolved over time. The 

instructions also state, lacking information to the contrary, it should be assumed that all workers 

received annual chest x-rays from 1952–2006. The year 2006 is established as the end date 

because all x-ray equipment was removed from the site in that year.

Information is provided on the different types of x-ray equipment that were used and, based on 

that information and guidance in ORAUT-OTIB-0006 (Revision 4, June 20, 2011), which was 

previously favorably reviewed by SC&A, x-ray exposures are assigned to different organs and as 

a function of time. A review of OTIB-0006 reveals that collimation is addressed in Section 3.4 

and retakes are addressed in Section 7.0 in making these assignments.

Tables 3-3 through 3-8 in the TBD provide convenient look-up tables for doses to various organs 

as a function of time from 1952–2006. Since the records reviewed by NIOSH are quite detailed 

with respect to the types of equipment and examinations performed, we conclude that there is no 

basis to assume that either lumbar spine or PFG examinations were performed, and that the three 

issues identified above have been adequately addressed. On this basis, SC&A recommends 

closing these findings.