Effective Date: 5/17/2016 Page 1 of 3

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

TECHNCIAL BASIS DOCUMENTS ISSUES MATRIX 

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

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

contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

6-1 1 Site Profile Issue # 1

Interpretation of external dosimetry 

data. SC&A could not find that NIOSH 

addressed the issue of recorded zeros (or 

other markings) in the records before 

1989 in the revised ORAUT-TKBS0013-6 (Revision 02). From reviewing 

OTIB-0086 (ORAUT 2015), SC&A 

recommends that the DR consider the 

worker’s job titles and dosimetry records 

in totality when evaluating recorded 

zeros (as well as blanks, dashes, and 

hash marks) for deciding whether to 

assign coworker, missed, or 

environmental external dose, because the 

electronic database may have inserted 

zeros for unmonitored workers after 

1976.

Based on NIOSH's research, beginning in 1988 

all personnel entering the controlled radiation 

areas were required to wear a personnel 

dosimeter. This was addressed with the 

publication of OTIB-0086 which specifies:

In such cases for years before 1988, NIOSH 

intends to apply (after consideration of the 

worker’s job title and the totality of the 

monitoring record), either: 1) Unmonitored 

dose based on external coworker data listed 

in OTIB-0086 and Tables A-1 through A-3 

of the Pantex External TBD, 2) Missed dose, 

or 3) Ambient dose.

For 1988 and later years, all personnel who 

entered the operational areas of the plant 

were required to wear a dosimeter as a 

condition for entry. The absence of a listed 

result, or the presence of a dash, slash, or 

hash mark for a given dosimeter exchange 

cycle in 1988 and later years, should be 

interpreted to mean that the worker was not 

monitored because he or she was not present 

in the operational areas. Therefore, ambient 

dose should be assigned for those exchange 

cycles.

5/2016

SC&A found that NIOSH’s response 

addressed the issue, except for: 

a) The fact the word “zero” was not 

specifically used when considering the 

worker’s monitoring records. This is 

important because the electronic database 

may have inserted zeros for unmonitored 

workers after 1976. 

b) TBD-6, page 13 states that the 

year when all personnel entering a rad area 

were monitored was 1989. Which year, 

1988 or 1989, is correct?
Effective Date: 5/17/2016 Page 2 of 3

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

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

contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

6-2 2 2.0 Data do not support assumption 

that 95th percentile neutron-to-photon 

ratio is bounding for all exposure 

scenarios. From reviewing the revised 

ORAUT-TKBS0013-6 (Revision 02) and 

the related document, OTIB-0086 

(ORAUT 2015), SC&A found that 

instead of using the n/p method, NIOSH 

recommends using the recorded neutron 

dose, with the NTA film results adjusted 

for energy response, angular response, 

and track fading. As previously 

summarized, and detailed in SC&A’s 

review of OTIB-0086 (SC&A 2015), 

SC&A does not find the neutron 

adjustment factors to be claimant 

favorable for Pantex workers.

NIOSH notes that the comments on the site 

profile document were similar in nature to those 

made during SC&A’s review of OTIB-0086 

(ORAUT 2015). NIOSH recently determined that 

the Pantex Plant ended its contract with Landauer 

for NTA film at the end of 1973, and likely 

transitioned to TLDs in 1974 for neutron 

monitoring. As a consequence of this recent 

determination, NIOSH intends to revise OTIB0086 and ORAUT-TKBS-0013-6 (Revision 02) 

to reflect the use of NTA film through 1973 and 

the use of TLDs for 1974 and subsequent years. 

NIOSH contends that the correction factors 

applied to the NTA film results to account for 

energy response, angular response, and track 

fading are favorable to claimants and are 

applicable through 1973. 

5/2016

SC&A will need to review the revised 

OTIB-0086 and TBD-6 to evaluate the 

changes made for the transition from NTA 

film to TLDs.

However, the NTA film correction factors

recommended by NIOSH has not been

justified and the issues raised by SC&A 

are still applicable. 

5-6 3 Site Profile Issue #3 

Completeness and interpretation of 

historic radiological exposure sources. 

SC&A found that sections had been added 

to ORAUT-TKBS-0013-5, Revision 04 

(2015), and ORAUTTKBS-0013-6, 

Revision 02 (2015), with information 

concerning Pantex’s history and workers at 

other AEC/DOE facilities that resolves this 

issue.

No response necessary. SC&A deems the issue 

resolved. 

5/2016

SC&A recommends closure.
Effective Date: 5/17/2016 Page 3 of 3

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

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

contractor. NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

TBD 

Number 

SC&A 

Number OTIB Issue NIOSH Response SC&A Response

5-4 4 Site Profile Issue #4 (SEC Issue #15): 

Exposure from tritium. SC&A found that 

Revision 04 to ORAUT-TKBS0013-5 

(mainly Table 5-3) provides for tritium 

dose assignments based on recorded MDA 

values and also simplifies tritium dose 

assignment for the DR and allows for 

consistence in dose assignments. SC&A 

found this issue to be addressed, except for 

the statement in the footnote to Table 53 of 

ORAUT-TKBS-0013-5, Revision 04 

(2015), concerning the maximum intake 

and dose, and the reason for using the 

period 1956–1990 instead of 1956–1991.

Although the sentence “Note that these values 

exceed any recorded doses or intakes the site 

reported for any year of operation, including 1989 

when a major tritium released occurred.” is 

misleading, the listed maximum and mode annual 

intakes are greater than those listed in the 

ORAUT-TKBS0013-5, Revision 01 (2007). The 

footnote in the next revision of ORAUTTKBS0013-5 will be revised to read “Note that these 

values exceed any recorded intakes the site 

reported for any year of operation, including 1989 

when a major tritium released occurred.” 

All doses reflected in Table 5-3 of ORAUTTKBS-0013-5, Revision 04 (2015) are based on 

the current ICRP Publication 68 tritium dose 

coefficients. Moreover, the ORAUT-TKBS-0013-

5, Revision 04 (2015) Table 5-3 missed and/or 

unmonitored doses are only applied for those 

claimants with recorded zero results or reasonable 

expectation that they should have been monitored 

and were not. In cases where workers have 

recorded doses in excess of “zero” TEDE, then 

the dose reconstructor will assign tritium dose in 

accordance with the instructions listed in 

Attachment C, ORAUT-TKBS-0013-5, 

Revision 04 (2015). 

The rationale for assigning doses through 1990 

based on an MDA of 0.500 uCi/L is based on a 

review of claimant records which showed that 

value to be the highest through 1990. For 1991 

and all subsequent years, the highest listed MDA 

in claimant records listed was 0.135 uCi/L. The 

SEC dates were not considered for the time 

periods listed in Table 5-3.

5/2016

SC&A agrees that the changing in 

wording would clarify the maximum 1989

dose and intake issue.

SC&A accepts the rationale for using the 

period of 1956–1990, instead of 1991. 

This issue can be closed after the revision 

is made in the wording for the maximum 

intake.