Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

1 of 22

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No 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.

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 pre1968.

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’s 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 invivo data reported in nCi Ac-227 

and Pb-212 that might preclude its

use in a coworker model.

Agreed. 
Effective Date:

Updated October 16, 2013

Revision No.

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Doc No 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.

SC&A suggests closing this

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air concentration

data.

Agreed. 

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 concentrationsin non- operating 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.

SC&A suggests closing this

finding because the NIOSH 

coworker model for 1979–1988 

does not employ air concentration

data.

Agreed. 
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

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Doc No 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

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.

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. 

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.

SC&A suggests closing this finding

because the NIOSH

coworker model for 1979–1988 

does not employ air concentration

data.

Agreed. 

TBD 6

The approach suggested

for estimating thorium 

intakes does not reflect 

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

and 6b.

SC&A suggests closing this

finding because the NIOSH 

coworker model for 1979–1988 

Agreed. 
Effective Date:

Updated October 16, 2013

Revision No.

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Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

the history of production 

or the available thorium 

air concentration data. It 

is likely to result in 

significant

underestimates of internal

dose from thorium.

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.

does not employ air concentration

data.

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 K-65 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 provide 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 rationing 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.

SEC recommends this issue be

changed to "in abeyance" pending

revised TBD.

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-TKBS-0017-4,, 

“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-RPT0052, 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.

TBD 8

Workers who may have

worked with raffinates 

may be missed by the 

protocol specified in Vol.

See response to Finding #7. See response to Finding #7. See NIOSH Response #7.
Effective Date:

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Doc No Finding Text History SC&A NIOSH

Response Status

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.

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 

constituents.

SC&A recommends finding be 

changed to "in abeyance" pending

revised TBD.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU 

constituents, which will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project 

(FEMP) – Occupational 

Internal Dose,” and ORAUTTKBS-0017-4,, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.

TBD 10

The radionuclide list for

RU in the TBD is 

incomplete.

Furthermore, the

concentrations of trace 

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

SC&A notes that while NIOSH

has provided a method for 

bounding intakes from Pu, Np237, and Tc-99, other nuclides 

such as Am-241 and thorium 

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics” 

provides an upper bound on 

intakes from RU constituents 

and has revised ratios for 
Effective Date:

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Revision No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

radionuclidesin the 

raffinates, which are

much higher than those in

the feed material, are not 

adequately discussed.

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.

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.

recycled uranium 

constituents that will be 

incorporated into ORAUTTKBS-0017-5, “Technical 

Basis Document for the 

Fernald Environmental 

Management Project 

(FEMP) – Occupational 

Internal Dose,” and ORAUTTKBS-0017-4,, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.

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.

SC&A recommends finding be 

changed to “in abeyance" until 

agreed upon method is 

incorporated into the TBD.

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 ORAUTTKBS-0017-4,, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.
Effective Date:

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Revision No.

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Doc No Finding Text History SC&A NIOSH

Response Status

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% U235).

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).

10/28/08 (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 accepted the 2% position and closed the finding.

Closed. Agreed.
Effective Date:

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Doc No Finding Text History SC&A NIOSH

Response Status

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.

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.

Closed Agreed.

ORAUT-OTIB-0073, 

“External Coworker 

Dosimetry Data for the 

Fernald Environmental 

Management Project,” will 

be incorporated into 

ORAUT-TKBS-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.
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Doc No Finding Text History SC&A NIOSH

Response Status

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.

SC&A recommends that this

finding be closed.

Agreed. 

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.

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 subcontractorsfrom 1951–1983. The thorium

coworker model post-1978 relies on chest count data, and ingestion modeling is

still an issue for discussion.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

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.
Effective Date:

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Doc No Finding Text History SC&A NIOSH

Response Status

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.

SC&A recommends finding be

classified "open" as a topic for

WG discussion

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. ORAUTOTIB-0017 was not 

available when ORAUTTKBS-0017-6, “Fernald Site 

– Occupational External 

Dose,” (04/20/2004) was 

approved.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No 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.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

The ORAUT-TKBS-0017-6, 

“Fernald Site – Occupational 

External Dose” revision 

references DCAS-TIB-13, 

“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. DCASTIB-13 was not available 

when ORAUT-TKBS-0017-

6, “Fernald Site –

Occupational External 

Dose,” (04/20/2004) was 

approved. 
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

12 of 22

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No 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 NLO 1959.

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. FEMP 1998, 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 1952; NLO 1965). Issue was not discussed

after this meeting.

SC&A recommends finding be

classified “open” as a topic for 

WG discussion. Contact beta dose

is currently under review in the

PRSC.

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.
Effective Date:

Updated October 16, 2013

Revision No.

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Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No 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. 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.

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

– Occupational External 

Dose” references DCASTIB-13, “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.

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 (sic) made. 

Interviews are continuing to discover if additional corrections were applied. 

(SC&A 2008)

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

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 

Open
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

measurements and resulted 

in overestimates of electron 

dose.

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.

SC&A recommends finding be

changed to " in abeyance" until 

agreed upon method is 

incorporated into the TBD

See NIOSH Response #13.
Effective Date:

Updated October 16, 2013

Revision No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

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.

SC&A recommends that this

finding remain “open” as a

topic for WG discussion.

(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 ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose” 

revision for the operational 

period.

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 (RAC 1995) to 

establish the source term. The new model incorporates evaluationsfor 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).

SC&A recommends that this 

finding remain “open” as a topic

for WG discussion.

ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose” revision uses a 

standard annualized 

Gaussian model including 

assumption 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 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. SC&A recommends that this

finding remain “open” as a

topic for WG discussion.

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 offnormal events. NIOSH is 

unaware of any additional 
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

16 of 22

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

significant sources.

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. SC&A suggests this finding be

subsumed into SEC Primary Issue

#5 (moved to TBD issues April

2011).

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.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No 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

(Pinney et al. 2008). 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 Pinney 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.

SC&A suggests this finding be

subsumed into SEC Primary Issue

#5 (moved to TBD issues April

2011).

The ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose” revision includes 

effluent from Q11 silos.

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. SC&A recommends finding be

classified “open” as a topic for

WG discussion.

The “Exposure Areas” 

concept is also applied to 

external dose consistent 

with the NIOSH position on 

Item 22 for the ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose” 

revision.
Effective Date:

Updated October 16, 2013

Revision No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

TBD 28

External environmental

dose for workers near the 

K-65 silos needs to be 

better evaluated.

This relates to SEC Primary Finding #5 which is still

unresolved as a site profile issue.

2/9/2011 – 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 report.

NIOSH to identify which cases might be impacted by SC&A’s findings

regarding the applicability of the atmospheric dispersion model and the veracity

of the source term.

SC&A suggests this finding be

subsumed into SEC Primary Issue

#5 (moved to TBD issues April

2011).

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.

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.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

Radon from the material 

stored in drum 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 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.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

No evidence of PFG has yet 

turned up for Fernald. This 

includes no evidence in 

claim files, no historical 

documentation of PFG 

equipment, & no evidence in 

several reviews of actual film 

folders of Fernald workers 

that have been performed 

over the years.

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. SC&A recommends finding be 

classified “open” as a topic for 

WG discussion.

The reference for this piece 

of information was not found 

in the historical information, 

and so it was removed from 

the revision of ORAUTTKBS-0017-3, Fernald 

Environmental Management 

Project – Occupational 

Medical Dose.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

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Page No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

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.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

The current version of the 

ORAUT-TKBS-0017-3, 

Fernald Environmental 

Management Project –

Occupational Medical Dose 

assumes poor collimation 

prior to 1970. 

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.

SC&A recommends finding be

classified “open” as a topic for

WG discussion.

It is very clear that the few 

lumbar spine x-rays in claim 

file records ( 9727, 16972, 

27894, 31741) 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 1790 work 

periods/claims were 

reviewed and there were 0 

non-dispensary lumbar 

spines in this random 

sample.

SEC P 3

Default concentrations

(on U mass basis) of Pu239, 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.

SC&A recommends issue be 

placed “in abeyance” until 

implemented in Site Profile.

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 ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” 

revisions.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

SEC P 4

Use of radon breath data

for reconstructing doses 

from inhalation of Ra226 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 ORAUT- RPRT-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.

SC&A recommends issue be

placed “in abeyance” until

implemented in Site Profile.

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 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.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

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ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

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.

Open site profile issue. 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 

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.

Implementation of a coworker

model is an ongoing site profile 

issue for 1979–1988.

A thorium coworker model is 

in development.
Effective Date:

Updated October 16, 2013

Revision No.

1 (Draft)

Document No.

SCA-SP-IM2013-0045

Page No.

22 of 22

NOTICE: This October 16, 2013, Issues Matrix has been reviewed for potential Privacy Act-protected information and redacted accordingly. Future versions of this issues

matrix will not be freely distributed until further reviews for Privacy Act-protected information are conducted. DRAFT ORAUT/NIOSH responses 3/14/14

ISSUES RESOLUTION MATRIX FOR FERNALD SITE PROFILE AND SEC PETITON

Doc No Finding Text History SC&A NIOSH

Response Status

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 (Parker 1945) 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.

This issue is apparently open

for WG deliberation.

SRDB Reference ID # 2921, 

“Health Protection Program 

Review,” from November 

1962, concurs with the 

proposal to issue a 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.