Working Draft 

FERNALD PLANT SITE PROFILE ISSUES MATRIX –

DRAFT PRELIMINARY SC&A ASSESSMENT 

Contract 200-2009-28555 

SCA-SP-IM2013-0045, Revision 1 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

April 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.
Effective Date:

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Revision No.

1 (Draft)

Document No.

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INTRODUCTION 

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

Assessment, Rev. 01” 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 

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

responses (red font). 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.
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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.

Agreed.
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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.

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 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.

Agreed.
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

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.

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.
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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

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.

Agreed.

TBD

6

The approach suggested 

for estimating thorium 

intakes does not reflect 

the history of production 

or the available thorium 

air concentration data. It 

is likely to result in 

significant underestimates 

of internal dose from 

thorium.

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.

Agreed.
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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

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.

ORAUT-RPRT-0052, “Feed 

Materials Production Center 

Internal Dose Topics,” provides a 

method for estimating raffinate 

streams, which will be 

incorporated into ORAUT-TKBS0017-5, “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. 

ORAUT-OTIB-25, “Estimation of 

Radium-226 Activity in the Body 

from Breath Radon-222 

Measurements,” which is included 

in ORAUT-RPRT-0052, 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. 
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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.

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-TKBS0017-5, “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. 
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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 

TKBS-0017-5 and any related 

guidance documents.

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-RPRT0052 does not address these 

other constituents nor have 

they been discussed in the WG 

setting. October 2013 

recommendation holds. SC&A 

will need to revisit this issue 

prior to new WG discussion.

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-TKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” revisions.
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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 ORAUTTKBS-0017-4, “Fernald 

Environmental Management 

Project – Occupational 

Environmental Dose,” revisions.

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).

10/28/08 (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 

10/15/2013: Closed. Agreed.
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Finding Text History SC&A NIOSH Response Status

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.

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.

10/15/2013: Closed Agreed.

ORAUT-OTIB-0073, “External 

Coworker Dosimetry Data for the 

Fernald Environmental 

Management Project,” will be 

incorporated into ORAUT-TKBS0017-6, “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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Finding Text History SC&A NIOSH Response Status

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.

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 subcontractors from 1951–1983. The 

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. 

Recommend closure.

OCAS-TIB-009, “Estimation of 

Ingestion Intakes,” provides an 

approach towards thorium 

ingestion doses and will be 

included in the ORAUT-TKBS0017-5, “Technical Basis 

Document for the Fernald 

Environmental Management 

Project (FEMP) – Occupational 

Internal Dose” revision. 
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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-TKBS0017-6 to verify that the 

revision adequately addresses 

our concerns. Recommend 

keeping open until we can 

verify.

ORAUT-OTIB-0017, 

“Interpretation of Dosimetry Data 

for Assignment of Shallow Dose,” 

is referenced in the ORAUTTKBS-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 ORAUT-TKBS-0017-6, 

“Fernald Site – Occupational 

External Dose,” (04/20/2004) was 

approved.
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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.

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-TIB-0013

was not available when ORAUTTKBS-0017-6, “Fernald Site –

Occupational External Dose,” 

(04/20/2004) was approved. 
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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).

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.

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.
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Issue was not discussed after this meeting.
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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. 

4/10/2014: Angle of incidence 

issues have been resolved in the 

Procedures Review 

Subcommittee. Also See 

response to #17. 

The revision to ORAUT-TKBS0017-6, “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.

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.

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 

Open
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algorithm affected the precision of 

electron dose 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.

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.

See NIOSH Response #13.
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Finding Text History SC&A NIOSH Response Status

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

methods suggested are sufficient.

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.

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-TKBS-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 

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 is 

included. 
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Finding Text History SC&A NIOSH Response Status

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

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 

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. 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 ORAUTTKBS-0017-4 Rev. 02 to 

determine whether our 

concerns are adequately 

addressed.

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.
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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 ORAUTTKBS-0017-4 Rev. 02 to 

determine whether our 

concerns are adequately 

addressed.

The ORAUT-TKBS-0017-4, 

“Fernald Environmental 

Management Project –

Occupational Environmental 

Dose,” revision includes effluent 

from Q11 silos. 
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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 ORAUTTKBS-0017-4 Rev. 02 to 

determine whether our 

concerns are adequately 

addressed.

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. 

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 reports.

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.

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 ORAUTTKBS-0017-4 Rev. 02 to 

determine whether our 

concerns are adequately 

addressed.

The external environmental dose 

for workers near the K-65 silos is 

addressed in the ORAUT-TKBS0017-4, “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.

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 ORAUTTKBS-0017-4 Rev. 02 to 

determine whether our 

concerns are adequately 

addressed.

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 exposure be added to 

the SEC.
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Finding Text History SC&A NIOSH Response Status

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 ORAUTTKBS-0017-3 Rev. 01 to 

determine whether our 

concerns are adequately 

addressed.

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.

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-TKBS0017-3 Rev. 01.

The reference for this piece of 

information was not found in the 

historical information, and so it 

was removed from the revision of 

ORAUT-TKBS-0017-3, “Fernald 

Environmental Management 

Project – Occupational Medical 

Dose.”

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 ORAUTTKBS-0017-3 Rev. 01 to 

determine whether our 

concerns are adequately 

addressed.

The current version of the 

ORAUT-TKBS-0017-3, “Fernald 

Environmental Management 

Project – Occupational Medical 

Dose,” assumes poor collimation 

prior to 1970.
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Finding Text History SC&A NIOSH Response Status

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.

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 non-dispensary 

lumbar spines in this random 

sample.

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.

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 

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. 
Effective Date:

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Finding Text History SC&A NIOSH Response Status

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 Th-230 

which will be incorporated into 

ORAUT-TKBS-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.

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

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 

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. 

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 
Effective Date:

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Finding Text History SC&A NIOSH Response Status

of the atmospheric 

dispersion factors at 

receptor locations (still 

does not compensate for 

underestimated source 

term).

TBD Issues. recommends that the radon

effluent values stated in ORAUTTKBS-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.

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.

A thorium coworker model is in 

development.

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.

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.

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.
Effective Date:

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Finding Text History SC&A NIOSH Response Status

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.
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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.
Effective Date:

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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.