Effective Date: 5/17/2016 Page 1 of 2

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

SC&A’S EVALUATION OF REVISIONS TO PANTEX TECHNICAL BASIS DOCUMENTS RELEVANT TO SITE PROFILE AND SEC ISSUES: 

TECHNCIAL BASIS DOCUMENTS ISSUES MATRIX

TBD 

Number

SC&A 

Number OTIB Issue NIOSH response

6-1 1 Site Profile Issue # 1

Interpretation of external dosimetry data. SC&A could 

not find that NIOSH addressed the issue of recorded zeros 

(or other markings) in the records before 1989 in the 

revised ORAUT-TKBS-0013-6 (Revision 02). From 

reviewing OTIB-0086 (ORAUT 2015), SC&A 

recommends that the DR consider the worker’s job titles 

and dosimetry records in totality when evaluating recorded 

zeros (as well as blanks, dashes, and hash marks) for 

deciding whether to assign coworker, missed, or 

environmental external dose, because the electronic 

database may have inserted zeros for unmonitored workers 

after 1976. 

Based on NIOSH's research, beginning in 1988 all personnel entering the 

controlled radiation areas were required to wear a personnel dosimeter. 

This was addressed with the publication of OTIB-0086 which specifies: 

In such cases for years before 1988, NIOSH intends to apply (after 

consideration of the worker’s job title and the totality of the 

monitoring record), either: 1) Unmonitored dose based on 

external coworker data listed in OTIB-0086 and Tables A-1 

through A-3 of the Pantex External TBD, 2) Missed dose, or 3)

Ambient dose.

For 1988 and later years, all personnel who entered the operational 

areas of the plant were required to wear a dosimeter as a condition 

for entry. The absence of a listed result, or the presence of a dash, 

slash, or hash mark for a given dosimeter exchange cycle in 1988 

and later years, should be interpreted to mean that the worker was 

not monitored because he or she was not present in the operational 

areas. Therefore, ambient dose should be assigned for those 

exchange cycles.

6-2 2 2.0 Data do not support assumption that 95th percentile 

neutron-to-photon ratio is bounding for all exposure 

scenarios. From reviewing the revised ORAUT-TKBS0013-6 (Revision 02) and the related document, OTIB-0086 

(ORAUT 2015), SC&A found that instead of using the n/p 

method, NIOSH recommends using the recorded neutron 

dose, with the NTA film results adjusted for energy 

response, angular response, and track fading. As previously 

summarized, and detailed in SC&A’s review of OTIB-0086 

(SC&A 2015), SC&A does not find the neutron adjustment 

factors to be claimant favorable for Pantex workers. 

NIOSH notes that the comments on the site profile document were similar 

in nature to those made during SC&A’s review of OTIB-0086 (ORAUT 

2015). NIOSH recently determined that the Pantex Plant ended its 

contract with Landauer for NTA film at the end of 1973, and likely 

transitioned to TLDs in 1974 for neutron monitoring. As a consequence of 

this recent determination, NIOSH intends to revise OTIB-0086 and 

ORAUT-TKBS-0013-6 (Revision 02) to reflect the use of NTA film 

through 1973 and the use of TLDs for 1974 and subsequent years. NIOSH 

contends that the correction factors applied to the NTA film results to 

account for energy response, angular response, and track fading are 

favorable to claimants and are applicable through 1973.

5-6 3 Site Profile Issue #3 No response necessary. SC&A deems the issue resolved.
Effective Date: 5/17/2016 Page 2 of 2 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

TBD 

Number

SC&A 

Number OTIB Issue NIOSH response

Completeness and interpretation of historic radiological 

exposure sources. SC&A found that sections had been added 

to ORAUT-TKBS-0013-5, Revision 04 (2015), and ORAUTTKBS-0013-6, Revision 02 (2015), with information 

concerning Pantex’s history and workers at other AEC/DOE 

facilities that resolves this issue.

5 4 Site Profile Issue #4 (SEC Issue #15): Exposure from 

tritium. SC&A found that Revision 04 to ORAUT-TKBS0013-5 (mainly Table 5-3) provides for tritium dose 

assignments based on recorded MDA values and also 

simplifies tritium dose assignment for the DR and allows for 

consistence in dose assignments. SC&A found this issue to be 

addressed, except for the statement in the footnote to Table 5-

3 of ORAUT-TKBS-0013-5, Revision 04 (2015), concerning 

the maximum intake and dose, and the reason for using the 

period 1956–1990 instead of 1956–1991.

Although the sentence “Note that these values exceed any recorded doses 

or intakes the site reported for any year of operation, including 1989 when 

a major tritium released occurred.” is misleading, the listed maximum and 

mode annual intakes are greater than those listed in the ORAUT-TKBS0013-5, Revision 01 (2007). The footnote in the next revision of ORAUTTKBS-0013-5 will be revised to read “Note that these values exceed any 

recorded intakes the site reported for any year of operation, including 1989 

when a major tritium released occurred.” 

All doses reflected in Table 5-3 of ORAUT-TKBS-0013-5, Revision 04 

(2015) are based on the current ICRP Publication 68 tritium dose 

coefficients. Moreover, the ORAUT-TKBS-0013-5, Revision 04 (2015) 

Table 5-3 missed and/or unmonitored doses are only applied for those 

claimants with recorded zero results or reasonable expectation that they 

should have been monitored and were not. In cases where workers have 

recorded doses in excess of “zero” TEDE, then the dose reconstructor will 

assign tritium dose in accordance with the instructions listed in Attachment 

C, ORAUT-TKBS-0013-5, Revision 04 (2015). 

The rationale for assigning doses through 1990 based on an MDA of 0.500 

uCi/L is based on a review of claimant records which showed that value to 

be the highest through 1990. For 1991 and all subsequent years, the 

highest listed MDA in claimant records listed was 0.135 uCi/L. The SEC 

dates were not considered for the time periods listed in Table 5-3.