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

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

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

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

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

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

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

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

MEMORANDUM

TO: Argonne National Laboratory – East Work Group 

FROM: SC&A, Inc.

DATE: July 17, 2017 

SUBJECT: Current Status of ANL-E Site Profile Findings and Observations 

Introduction and Background

The most recent editions of the Argonne National Laboratory – East (ANL-E) site profile 

technical basis documents (TBDs) are as follows:

• ORAUT-TKBS-0036-3, Argonne National Laboratories – East – Occupational Medical 

Dose, Revision 01 PC-1, March 27, 2006 

• ORAUT-TKBS-0036-4, Argonne National Laboratory – East – Occupational 

Environmental Dose, Revision 00, February 9, 2006 

• ORAUT-TKBS-0036-5, Argonne National Laboratory – East – Occupational Internal 

Dose, Revision 00, March 1, 2006 (also referred to as “TBD-5”) 

• ORAUT-TKBS-0036-6, Argonne National Laboratory – East – External Dosimetry, 

Revision 01, October 16, 2014 (Revision 01 replaced ORAUT-TKBS-0036-6, 

Revision 00, of February 9, 2006) 

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

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

Board Review System (BRS) in February 2017. 

There was a telephone conference call between the members of the ANL-E Work Group (WG), 

the National Institute for Occupational Safety and Health (NIOSH), and SC&A on March 10, 

2017, to discuss the current status of the ANL-E issues. Members of the WG, NIOSH, and 

SC&A toured the ANL-E facilities on March 21, 2017. 

SC&A entered the ANL-E site profile observations (formally titled “secondary findings”), and 

also SC&A’s response to Primary Findings 3 and 13, into the BRS in April 2017. SC&A 

informed the ANL-E WG and NIOSH of these entries on the BRS in an email on April 11, 2017. 
Memo – Status of ANL-E Findings and Observations 2 SC&A – July 17, 2017

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

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

Current Status of Findings

The following is a brief summary of the current status of the ANL-E site profile findings. Further 

details are available on the BRS, including discussion of the finding and the resolution of 

findings that are recommended for closure by SC&A and NIOSH. 

Finding 1 – Potential Missed Dose from Lack of Definition of Radionuclide Compositions and 

Radionuclides Not Addressed in Site Profile 

NIOSH’s response in the BRS on March 8, 2017, indicates that bioassays were sufficiently 

specific to allow for correct assignment of internal dose from different radionuclides present at 

ANL-E. However, Research on uranium composition is still underway. 

SC&A finds that the current TBD-5, ORAUT-TKBS-0036-5, Revision 00, of March 2006, does 

not provide adequate coverage of the many different radionuclides that potentially were present 

at a research lab, such as the percent enrichment of uranium, accelerator-produced radionuclides, 

and exotic radionuclides. The ability and knowledge needed to monitor for the many possible 

radionuclides present, especially in the early years, is likely questionable for ANL-E, as it was 

for other research facilities in the U.S. Department of Energy (DOE) complex at that time.

Finding 2 – Potential Missed Dose from the Use of Gross Alpha Counting for Bioassay (1946 to 

1972) 

According to NIOSH’s BRS response of March 8, 2017, the finding that guidance is needed for 

interpreting results from the gross alpha analysis process is valid, and clearer direction will be 

provided in the next TBD revision. 

Finding 3 – Assumption of Default Inhalation Pathway May Not Be Claimant Favorable 

SC&A’s response of April 4, 2017, on the BRS indicates that this issue has been resolved and 

recommends closure. 

Finding 4 – Insufficient Information on the Calculation of Minimum Detectable Concentrations 

(MDC) and Uncertainties in Bioassay Methodology 

According to NIOSH’s BRS response of March 8, 2017, the recent records from ANL-E are 

being reviewed to determine if they may refine the current estimates of MDC in the TBD. 

Finding 5 – Lack of Guidance for Estimation of Missed Dose for Unmonitored Workers 

According to NIOSH’s BRS response of March 8, 2017, the potential need for assignment of 

unmonitored dose is still being assessed. 
Memo – Status of ANL-E Findings and Observations 3 SC&A – July 17, 2017

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

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

Finding 6 – Failure to Adequately Define and Assess Occupational Medical Exposures in the 

Pre-1988 Years and Potentially Misses Special Employment Exams 

According to NIOSH’s BRS response of March 8, 2017, ORAUT-OTIB-0006, Dose 

Reconstruction from Occupational Medical X-Ray Procedures, has been revised (to Revision 04 

in 2011) since the original SC&A review and the last revision of the TBD. The ANL-E medical 

TBD will be evaluated and revised as necessary to incorporate ORAUT-OTIB-0006, Revision 

04, recommendations regarding special screening exams. 

Finding 7 – Lacking Techniques and Protocols for Medical Examinations Prior to 1988 

Increases the Uncertainty of Dose Conversion Factors Listed in ORAUT-TKBS-0036-3 

SC&A’s BRS response of February 13, 2017, indicates that this issue has been resolved and 

recommends closure. NIOSH’s BRS response of March 8, 2017, concurs with this 

recommendation. 

Finding 8 – Frequencies and Types of X-Ray Exposures Are Uncertain

According to NIOSH’s BRS response of March 8, 2017, any new information collected from 

ANL-E since the original TBD was written will be incorporated into a revision. ORAUT-OTIB0006 has been revised (in 2011) since the original SC&A review and the last revision of the 

TBD. The x-ray information in the ANL-E claim file records constitutes a body of evidence that 

should be used in the TBD. ORAUT-OTIB-0006 should be used in the absence of such evidence. 

SC&A understands this statement to indicate that ORAUT-TKBS-0036-3 will be revised to 

incorporate the revisions in Revision 04 to ORAUT-OTIB-0006, and, until then, the dose 

reconstructor is to use the current version of ORAUT-OTIB-0006. 

Finding 9 – Uncertainty and Undocumented Aspects of the Film Dosimetry Need 

Reexamination 

According to NIOSH’s BRS response of March 8, 2017, further research into dosimeter 

characteristics will be performed to evaluate the similarity of ANL-E dosimeters to those used at 

Idaho National Laboratory and those used for Argonne National Laboratory–West workers and 

the validity of the under-response assumptions in the TBD. A simplifying table will be 

developed to aid dose reconstructors in application of dosimeter parameters. 

Finding 10 – Neutron Dosimetry Is Inadequately Addressed 

According to NIOSH’s BRS response of March 8, 2017, NIOSH concurs that improvement of 

the guidance on neutron monitoring and additional data evaluation are needed.

Finding 11 – Quantification of External Exposures to Unmonitored Workers Outdoors Is 

Inadequately Justified 
Memo – Status of ANL-E Findings and Observations 4 SC&A – July 17, 2017

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

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

According to NIOSH’s BRS response of March 8, 2017, for the period prior to 1972, use of the 

average values for other DOE sites in ORAUT-PROC-0060, Revision 01, Occupational Onsite 

Ambient Dose Reconstruction for DOE Sites (June 2006), may be applied as an overestimating 

assumption because the average doses in that document exceed those at ANL-E for concurrent 

time periods. 

SC&A finds that there should be more detailed information concerning the use of the average 

values for other DOE sites from ORAUT-PROC-0060 included in the ANL-E ORAUT-TKBS0036-4 TBD document to ensure consistent application in dose reconstruction. 

Finding 12 – Outdoor Inhalation Exposures Associated with Waste Disposal Operations in Area 

A and from Particulates Released During Accidents Are Not Adequately Addressed 

NIOSH’s BRS response of March 8, 2017, states that according to the TBD (ORAUT-TKBS0036-2, Section 2.2.2), waste disposal operations at Site A were conducted from 1943 through 

1949, with buried waste removed to Site D in 1949. Consequently, all waste disposal operations 

at Site A were conducted during the period prior to 1954 when the TBD assumptions were 

considered to be adequate. 

SC&A finds that NIOSH’s response was supported during the visit to ANL-E on March 21, 

2017, and recommends closing the issue. 

Finding 13 – Lack of Consideration of Occupational Radiological Exposure at Site A and 

Plot M

SC&A’s BRS response of April 4, 2017, indicates that this issue has been resolved and 

recommends closure. 

Current Status of Observations

The following is a brief summary of the current status of the ANL-E site profile observations. 

Further details are available on the BRS, including discussion of the observations and the 

resolution of observations that are recommended for closure by SC&A and NIOSH. 

Observation 1 – Potential Missed Dose from Skin and Clothing Contamination 

According to NIOSH’s BRS response of April 24, 2017, the TBD will be evaluated and revised 

to incorporate appropriate language to address dose reconstruction from skin and clothing 

contamination in accordance with ORAUT-OTIB-0017, Revision 01, Interpretation of 

Dosimetry Data for Assignment of Shallow Dose. 

Observation 2 – Other Potential Medical Exposures Have Not Been Identified

SC&A’s BRS response of April 11, 2017, indicates that this issue has been resolved and 

recommends closure. NIOSH’s BRS response of April 24, 2017, concurs with this 

recommendation. 
Memo – Status of ANL-E Findings and Observations 5 SC&A – July 17, 2017

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

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

Observation 3 – Additional Factors Contribute to Medical Dose Uncertainties 

SC&A’s BRS response of April 11, 2017, indicates that this issue has been resolved and 

recommends closure. NIOSH’s BRS response of April 24, 2017, concurs with this 

recommendation. 

Observation 4 – Internal Dose to Workers from Radon Exposures Is Not Considered 

According to NIOSH’s BRS response of April 24, 2017, no records have been identified that 

indicate worker monitoring for radon was routinely performed; however, no major sources of 

enhanced radon exposure have been identified for the ANL-E site. There were no large quantities 

of uranium or radium in ore stored or handled at ANL-E. 

SC&A finds that there were opportunities for exposure to radium-226 (Ra-226), actinium-227 

(Ac-227), and thorium. In fact, the ANL-E TBD acknowledges that the site used Ra-226 in 

Buildings 203 and 211 as part of the accelerator program. In Building 200, radon-200 was 

produced (ORAUT-TKBS-0036-2, Revision 00 PC-1, Table 2-2). Furthermore, there was a 

substantial incident involving rupture of an Ra-226 source that generated radon issues through 

time. Thorium was machined in the East Area and handled in research and development (R&D). 

Ac-227 was also handled in R&D (Manning 1950). Given the use of radium, actinium, and 

thorium at ANL-E, further investigation into potential occupational exposures to radon and 

possibly thoron and actinon are necessary. 

Observation 5 – Lack of Treatment Provided to the Monitoring of Contractors, Transferees, and 

Visitors 

According to NIOSH’s BRS response of April 24, 2017, there is no information in records from 

ANL-E suggesting that contractors, transferees, or visitors would not have been monitored in 

accordance with applicable procedures.

SC&A finds that the details of visitor and subcontractor monitoring are lacking. According to 

page 51 of ORAUT-TKBS-0036-6, rover dosimeters were pocket ionization chambers (PICs) 

that were not permanently assigned and were typically worn by visitors or personnel who were 

not normally assigned to an area. Would these PIC doses be recorded for visitors from other 

DOE facilities, and for the ANL-E workers? The Site Research Database (SRDB) references 

provided by NIOSH were for the early years at ANL-E, but the majority of the decontamination 

and decommissioning work would have occurred in later years, perhaps by subcontractors. Have 

radiation work permits, or similar job plans, been searched for monitoring compliance, especially 

for subcontractors? 

Observation 6 – Human Radiation Experiments Not Addressed 

According to NIOSH’s BRS response of April 24, 2017, doses received from participation in 

human radiation experiments are considered covered exposure under the Energy Employees 

Occupational Illness Compensation Program Act; however, they typically have not been 
Memo – Status of ANL-E Findings and Observations 6 SC&A – July 17, 2017

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

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

addressed in site TBDs. These doses would be assessed at an individual level based on the 

information that is available in the documentation (e.g., SRDB Ref. IDs 31911 and 33842). 

SC&A finds that while the ANL-E TBDs briefly mention human experiments, they do not 

explicitly instruct the dose reconstructor to include the doses and where to find the details of 

some of the human experiments. SRDB Ref. ID 33842, pages 127–147, provides a detailed list 

of 43 human experiments conducted at ANL-E and should be referenced in the internal dose 

TBD to provide further information for dose reconstruction. Additionally, SC&A has not seen 

verification that doses from the human experiments were calculated, recorded, and available in 

the participants’ records. 

Observation 7 – Incidents and Accidents Need to Be Reexamined

According to NIOSH’s BRS response of April 24, 2017, significant incidents and accidents are 

outlined in Section 2.4 of the site description TBD for ANL-E, with further detail provided in the 

1979 Draft Environmental Impact Statement (SRDB Ref. ID 17809), and additional records 

obtained indicate that radiological incidents are documented at least as early as 1950 in ANL-E 

program reports. 

SC&A finds that these reports only cover accidents during the early period at ANL-E; i.e., 

pre-1979. Similar research needs to be conducted for 1979 and forward. 

References

Manning 1950. W.M. Manning, Summary Report for January, February and March, 1950: 

Chemistry Division, Section C-1, Argonne National Laboratory. June 7, 1950. [SRDB Ref. 

ID 17735] 

ORAUT-OTIB-0006. 2011. Dose Reconstruction from Occupational Medical X-Ray 

Procedures, Revision 04, National Institute for Occupational Safety and Health, Cincinnati, 

Ohio. June 20, 2011. 

ORAUT-OTIB-0017. 2005. Interpretation of Dosimetry Data for Assignment of Shallow Dose, 

Revision 01, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

October 11, 2005.

ORAUT-PROC-0060. 2006. Occupational Onsite Ambient Dose Reconstruction for DOE Sites, 

Revision 01, National Institute for Occupational Safety and Health, Cincinnati, Ohio. June 28, 

2006. 

ORAUT-TKBS-0036-2. 2006. Argonne National Laboratory – East – Site Description, 

Revision 00 PC-1, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

July 24, 2006. 
Memo – Status of ANL-E Findings and Observations 7 SC&A – July 17, 2017

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

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

ORAUT-TKBS-0036-3. 2007. Argonne National Laboratories – East – Occupational Medical 

Dose, Revision 01 PC-1, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

March 27, 2006.

ORAUT-TKBS-0036-4. 2006. Argonne National Laboratory – East – Occupational 

Environmental Dose, Revision 00, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. February 9, 2006.

ORAUT-TKBS-0036-5. 2006. Argonne National Laboratory – East – Occupational Internal 

Dose, Revision 00, National Institute for Occupational Safety and Health, Cincinnati, Ohio.

March 1, 2006.

ORAUT-TKBS-0036-6. 2006. Argonne National Laboratory – East – External Dosimetry, 

Revision 00, National Institute for Occupational Safety and Health, Cincinnati, Ohio. February 9, 

2006.

ORAUT-TKBS-0036-6. 2014. Argonne National Laboratory – East – External Dosimetry, 

Revision 01, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

October 16, 2014.

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

SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. March 11, 2009.

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

Argonne National Laboratory–East, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. June 5, 2016.