Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

 

Idaho National Laboratory (INL) 

Site Profile Review 

Status Update, Revision 1 

Contract No. 200-2009-28555 

SCA-SP-IM2013-0005 

Prepared by 

Stephen L. Ostrow, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

February 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.
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S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation and Worker Health Review of

NIOSH Dose Reconstruction Program

Document No. 

SCA-SP-IM2013-0005

Effective Date: 

February 24, 2014

Revision No. 

1 – Draft

Idaho National Laboratory (INL) Site Profile 

Review Status Update, Revision 1 Page 2 of 75

Task Manager:

________________________ Date: ___________

Stephen L. Ostrow, PhD

Supersedes:

Rev. 0

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer(s):

 John Mauro

 John Stiver

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 10/23/13 Initial issue

1 (Draft) 02/24/14 General revision to reflect issue reviews subsequent to the Rev. 0 report 

and to correct errata.
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................5

1.0 Introduction and Background ..............................................................................................8

2.0 Site Profile Review Chronology ........................................................................................14

3.0 TBD Item Status and Discussion .......................................................................................16

3.1 Issue 1: Routine Airborne Releases ......................................................................17

3.2 Issue 2: Episodic Airborne Release ......................................................................18

3.3 Issue 3: Direct Gamma Exposures ........................................................................19

3.4 Issue 4: Completeness and Quality of INL Internal Dosimetry Programs ...........20

3.5 Issue 5: High-Risk Jobs (Internal Exposure) ........................................................22

3.6 Issue 6: Calibration of Internal Dosimetry Analytical and Monitoring 

Equipment ..............................................................................................................23

3.7 Issue 7: Changes of Internal Dose Limits .............................................................26

3.8 Issue 8: High-Fired Plutonium and Uranium Intakes ...........................................27

3.9 Issue 9: Skin and Facial Contamination ................................................................28

3.10 Issue 10: Breathing Rates......................................................................................30

3.11 Issue 11: Non-Occupational Worker Elimination of DU Background .................31

3.12 Issue 12: Unmonitored Workers ...........................................................................32

3.13 Issue 13: Naval Reactor Facility Workers ............................................................33

3.14 Issue 14: Plutonium Monitoring ...........................................................................34

3.15 Issue 15: SL-1 Accident Dose Reconstructions ....................................................35

3.16 Issue 16: Completeness and Quality of INL Beta/Gamma Dosimetry and 

Record Keeping Programs .....................................................................................36

3.17 Issue 17: Penetrating and Non-Penetrating Doses ................................................38

3.18 Issue 18: Correction for Beta Doses .....................................................................40

3.19 Issue 19: Angular Dependence Correction Factor for Gamma Dose ...................42

3.20 Issue 20: Restating Beta Dose...............................................................................43

3.21 Issue 21: Photon Spectrum Split ...........................................................................44

3.22 Issue 22: Immersion Dose .....................................................................................45

3.23 Issue 23: High-Risk Jobs (Beta/Gamma Exposure)..............................................46

3.24 Issue 24: Extremity Dose ......................................................................................47

3.25 Issue 25: Discrepancies Between PIC and Film Reading .....................................49

3.26 Issue 26: Minimum Detection Limit .....................................................................50

3.27 Issue 27: Minimum Reporting Level (Beta/Gamma) ...........................................51

3.28 Issue 28: Minimum Reporting Level (Neutron) ...................................................54

3.29 Issue 29: Failure to Properly Address Neutron Exposures ...................................56

3.30 Issue 30: Neutron Calibration Deficiencies ..........................................................58
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3.31 Issue 31: Completeness and Quality of INL Neutron Dosimetry and Record 

Keeping Programs ..................................................................................................60

3.32 Issue 32: Uncertainty Estimation for Neutron Doses ...........................................62

3.33 Issue 33: Neutron Organ Dose ..............................................................................64

3.34 Issue 34: High-Risk Jobs (Neutron Exposure)......................................................65

3.35 Issue 35: Multiplying Factors for Missed Neutron Dose ......................................67

3.36 Issue 36: Missed Low-Energy Beta Dose .............................................................69

3.37 Issue 37: Error in Reference .................................................................................70

3.38 Issue 38: Shallow Dose .........................................................................................71

References ......................................................................................................................................72
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

AmBe americium-beryllium 

ANL-W Argonne National Laboratory – West 

ANP Aircraft Nuclear Propulsion Facility 

AP anterior posterior 

ATR Advanced Test Reactor 

CFR U.S. Code of Federal Regulations 

CPP Chemical Processing Plant 

DCAS NIOSH Division of Compensation Analysis and Support (formerly called OCAS) 

DFO Designated Federal Official 

DOE U.S. Department of Energy 

DOE-HQ U.S. Department of Energy Headquarters 

DNFSB Defense Nuclear Facility Safety Board

DU Depleted Uranium 

EDF Engineering Design File 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

EPA U.S. Environmental Protection Agency 

ETR Engineering Test Reactor 

FNCF Facility Neutron Correction Factor 

GB Gross Beta 

GG Gross Gamma 

IAEA International Atomic Energy Agency 

ICPP Idaho Chemical Processing Plant (formerly CPP and now INTEC) 

ICRP International Commission on Radiological Protection 

INEL Idaho National Engineering Laboratory 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center (formerly ICPP and CPP) 

IREP Interactive RadioEpidemiological Program 

keV kiloelectron volts 

L Liter 
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μg microgram 

m

3 cubic meter 

MDA Minimum Detectable Activity 

MDL Minimum Detection Limit 

MeV Mega Electron Volts 

mg/cm2 milligram per square centimeter 

mm millimeter 

mrem millirem 

MRL Minimum Dose Reporting Level 

MTR Materials Test Reactor 

NCRP National Council on Radiological Protection and Measurements 

NIOSH National Institute for Occupational Safety and Health 

NRF Naval Reactor Facility 

NTA Nuclear Track Emulsion-Type A 

OCAS NIOSH Office of Compensation Analysis and Support (now known as DCAS) 

ORAUT Oak Ridge Associated Universities Team 

OTIB ORAUT Technical Information Bulletin 

ORAUT Oak Ridge Associated Universities Team 

OW Open Window (dosimeter) 

PIC Pocket Ionization Chamber 

PoBe polonium-beryllium 

PoC Probability of Causation 

RAC Risk Assessment Corporation 

RWMC Radioactive Waste Management Complex 

S slow 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SEC Special Exposure Cohort 

SL-1 Stationary Low-Power Reactor Number One 

SMC Specific Manufacturing Capability Facility 

SRDB Site Research Database 

SRS Savannah River Site 

TAN Test Area North 
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TBD Technical Basis Document 

TIB Technical Information Bulletin

TLD Thermoluminescent Dosimeter 

TREAT Transient Reactor Test Facility 

UO2 uranium dioxide

WG ABRWH Work Group 

yr year 

ZPPR Zero Power Plutonium Reactor 
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1.0 INTRODUCTION AND BACKGROUND 

This report summarizes SC&A’s understanding of the issues resolution status of the Idaho 

National Laboratory (INL)/Argonne National Laboratory-West (ANL-W) site profile, and also 

presents comprehensive background and review information for convenience. In short, 10 of the 

38 issues are closed and, after two rounds of further evaluation, SC&A recommended closing 10 

more in its Rev. 0 report (SC&A 2013) and recommends closing an additional 4 in this, its 

Rev. 1 report, for a total of 14 issues. 

The Revision 0 of this report (SC&A 2013) was prepared at the request of the Designated 

Federal Official (DFO), who, in October 2013, asked SC&A to prepare for the INL/ANL-W 

Work Group (WG) a summary matrix showing the status of each issue, organized under each 

Technical Basis Document (TBD) of the site profile. That summary appears in this section. 

SC&A has also included, in Section 3.0, a more detailed discussion of each issue, drawn from 

several existing sources, showing the key steps in its resolution process. The material in the 

report represents a consolidation in one convenient document of the history and disposition 

status of each issue. It is hoped that this will be a useful living document for all interested 

parties, facilitating final resolution of all the site profile issues. 

SC&A issued its status update report (SC&A 2013) on October 23, 2013, and NIOSH issued two 

brief status reports on November 7, 2013 (NIOSH 2013b, 2013c). Subsequently, the DFO, on 

November 13, 2013, requested that SC&A address the issues assigned to SC&A in the NIOSH 

updates. SC&A reviewed open issues in detail and produced this report (SCA-SP-IM2013-0005, 

Rev. 0), Revision 1 of its Idaho National Laboratory (INL) Site Profile Review Status Update

report. This report is intended to support the deliberations of the WG at its next meeting, 

scheduled for March 25, 2014. 

NIOSH first issued the six-volume TBD comprising the INL site profile in July 2004 and SC&A 

reviewed it in September 2005 (SC&A 2005), followed by a revised review in January 2006 

(SC&A 2006). SC&A performed a supplemental review of the July 2007 TBD revisions in 

December 2008 (SC&A 2008). The Advisory Board on Radiation and Worker Health 

(ABRWH, or the Board) INL Work Group held its first meeting in June 2009 and decided to 

combine the INL and ANL-W (SC&A 2007) reviews, as the ANL-W facility is physically 

located within the INL site. SC&A produced a combined issues matrix for the two facilities in 

July 2009 (SC&A 2009). NIOSH subsequently revised all its TBDs over the period from 

December 2009 through April 2011, merging the INL and ANL-W material and making some 

other changes as well; these are the current versions of the TBDs (ORAUT 2009, 2010a, 2010b, 

2010c, 2010d, 2011b). The WG held its second meeting in June 2011 and SC&A subsequently 

issued an issue status and action item list for the 38 issues that SC&A identified (SC&A 2011a), 

which was soon revised to include NIOSH comments received on the first draft of the list 

(SC&A 2011b). 

Table 1 shows the current INL/ANL-W TBD volumes that constitute the site profile. 
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Table 1. INL/ANL-W Site Profile TBDs 

TBD Title Rev. Revision Date

1 Introduction 3 March 12, 2010

2 Site Description 4 August 2, 2010

3 Occupational Medical Dose 2 December 31, 2009

4 Occupational Environmental Dose 2 January 8, 2010

5 Occupational Internal Dose 3 March 2, 2010

6 Occupational External Dosimetry 3 April 19, 2011

Section 2 of this report presents a brief chronology for reference, listing key events that have 

taken place since NIOSH issued Rev. 0 of the TBDs in 2004. Section 3 consists of a detailed 

listing of all 38 issues along with their status and action (NIOSH and/or SC&A) determined at 

the June 2011 WG meeting; it is included for completeness and convenience in having all 

pertinent information in one place. It should be noted that the first 35 issues appeared in the 

2006 SC&A review (SC&A 2006), which added Attachment 3, “Summaries of Site Expert 

Reviews” and Attachment 5, “Issue Resolution Matrix for Findings and Key Observations,” 

neither of which were present in the 2005 review (SC&A 2005). In 2008, SC&A performed a 

brief supplemental review (SC&A 2008) of the latest revisions of the six INL TBD volumes, 

which were issued in 2007. The supplemental review corrected one issue (No. 2), expanded four 

issues (Nos. 25, 26, 29, 35), and added three new issues (Nos. 36, 37, 38), for the current total of 

38 issues. The following summarizes the status of all the issues:

Closed: The WG closed 10 of the 38 issues at the June 21, 2011 meeting: 

Issues 3, 7, 10, 11, 12, 13, 22, 25, 37, and 38. 

Recommended for Closure:1 SC&A was authorized to perform a “quick” 

review of its assigned issues after that meeting to try to identify issues that it 

could recommend that the WG close. This led SC&A shortly thereafter to 

recommend closing an additional 10 issues: Issues 4, 8, 14, 17, 18, 20, 26, 29, 33, 

and 36. 

Subsequent additional review of the open issues, as reported in Rev. 1 of this 

report, leads SC&A to also recommend closing an additional 4 issues: Issues 21, 

30, 32, and 35, which brings the total number of issues recommended for closure 

to 14. 

In addition, NIOSH stated in a presentation made at the July 2013 ABRWH meeting in Idaho 

(NIOSH 2013a), an October 1, 2013, communication from ORAUT, and in NIOSH 2013b and 

2013c, that it is working on four white papers, which will address some of the issues. These are 

shown in Table 2, along with the issues that NIOSH stated each paper addresses. 

 

1

 Note that alternative terminology for SC&A recommending closing an issue that it reviewed would be to 

recommend putting it in abeyance pending WG discussion and determination. 
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Table 2. Planned NIOSH White Papers 

Issue TBD White Paper Topic

1

ORAUT-TKBS-0007-4 

(Environmental) INL Environmental Monitoring

2

ORAUT-TKBS-0007-4 

(Environmental)

Aircraft Nuclear Propulsion Issue

9

ORAUT-TKBS-0007-5 

(Internal) Hot Particle Issue

23 ORAUT-TKBS-0007-6 

(External) Hot Particle Issue

28 ORAUT-TKBS-0007-6 

(External)

Investigation of the NTA Film

Dosimeter Limits of Detection Being 

Used for INL Dose Reconstructions

NIOSH is also currently developing an INL-specific Coworker Model, which is purported to 

address Issues 16 and 31. SC&A is not aware at this time of NIOSH submitting any of the above 

reports to the Board or SC&A for consideration or review. In addition, NIOSH noted in NIOSH 

2013b that it had completed data capture efforts on June 14, 2013, and added the data to the Site 

Research Database (SRDB). 

Table 3 is a comprehensive summary of all the issues, showing the ones already closed by the 

WG at its June 21, 2011, meeting; action items assigned to NIOSH and/or SC&A at that 

meeting; white papers and other material that NIOSH is producing to respond to some of the 

issues; and SC&A recommendations for issue dispositions (i.e., remain open or close) following 

further review of the action items assigned to it. 

Table 3. Issue Status Summary

Issue

No. TBD(b) Title Status(a) Assigned

Action(c) Note

1 4 Routine Airborne Releases Open N NIOSH is working on a white 

paper to address this issue: 

INL Environmental 

Monitoring. SC&A will 

review it when it is available. 

SC&A recommends: Remain 

Open.

2 4 Episodic Airborne Releases Open N NIOSH is working on a white 

paper to address this issue: 

Aircraft Nuclear Propulsion 

Issue. SC&A will review it 

when it is available. SC&A 

recommends: Remain Open.
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Table 3. Issue Status Summary

Issue

No. TBD(b) Title Status(a) Assigned

Action(c) Note

3 4 Direct Gamma Exposures Closed -

4 5 Completeness & Quality of 

INL Internal Dosimetry

Programs

Open N, S SC&A recommends: Close.

5 5 High-Risk Jobs (Internal 

Exposure)

Open S SC&A recommends: Remain 

Open.

6 5 Calibration of Internal 

Dosimetry Analytical & 

Monitoring Equipment

Open S SC&A recommends: Remain 

Open.

7 7 Changes of Internal Dose 

Limits

Closed -

8 5 High-Fired Plutonium and 

Uranium Intakes

Open N, S SC&A recommends: Close.

9

(d) 5 Skin and Facial 

Contamination

Open N, S NIOSH is working on a white 

paper to address this issue: 

Hot Particle Issue. SC&A 

will review it when it is 

available. SC&A 

recommends: Remain Open.

10 5 Breathing Rates Closed -

11 5 Non-Occupational Worker 

Elimination of DU 

Background

Closed -

12 5 Unmonitored Workers Closed -

13 4,5,6 Naval Reactor Facility 

Workers

Closed -

14 5 Plutonium Monitoring Open N, S SC&A recommends: Close.

15 4,5,6 SL-1 Accident Dose Open S SC&A recommends: Remain 

Open.

16 6 Completeness and Quality of 

INL Beta/Gamma Dosimetry 

and Record Keeping 

Programs

Open N, S NIOSH is working on an INLspecific coworker model. 

SC&A will review it when it 

is available (see Issue 31). 

SC&A recommends: Remain 

Open.

17 6 Penetrating and NonPenetrating DosesOpen S SC&A recommends: Close.

18 6 Correction for Beta Doses Open S SC&A recommends: Close.
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Table 3. Issue Status Summary

Issue

No. TBD(b) Title Status(a) Assigned

Action(c) Note

19 6 Angular Dependence 

Correction Factor for Gamma 

Dose

Open N SC&A is waiting for NIOSH 

response. SC&A 

recommends: Remain Open.

20 6 Restating Beta Dose as 

Gamma Dose

Open S SC&A recommends: Close.

21 6 Photon Spectrum Split Open S SC&A recommends: Close.

22 6 Immersion Dose Closed -

23(d) 6 High-Risk Jobs (Beta/Gamma 

Exposure)

Open N, S NIOSH is working on a white 

paper to address this issue: 

Hot Particle Issue. SC&A 

will review it when it is 

available. SC&A 

recommends: Remain Open.

24 6 Extremity Dose Open N, S SC&A recommends: Remain 

Open.

25 6 Discrepancies Between PIC 

and Film Reading

Closed -

26 6 Minimum Detection Limit Open S SC&A recommends: Close.

27 6 Minimum Reporting Level 

(Beta/Gamma)

Open S SC&A recommends: Remain 

Open.

28 6 Minimum Reporting Level 

(Neutron)

Open N, S NIOSH is working on a white 

paper to address this issue: 

Investigation of the NTA Film 

Dosimeter Limits of Detection 

Being Used for INL Dose 

Reconstructions. SC&A will 

review it when it is available. 

SC&A recommends: Remain 

Open.

29 6 Failure to Properly Address 

Neutron Exposures

Open S SC&A recommends: Close.

30 6 Neutron Calibration 

Deficiencies

Open S SC&A recommends: Close.

31 6 Completeness and Quality of 

INL Neutron Dosimetry and 

Record Keeping Programs

Open N NIOSH is working on an INLspecific coworker model. 

SC&A will review it when it 

is available (see Issue 16). 

SC&A recommends: Remain 

Open.

32 6 Uncertainty Estimation for 

Neutron Doses

Open S SC&A recommends: Close.
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Table 3. Issue Status Summary

Issue

No. TBD(b) Title Status(a) Assigned

Action(c) Note

33 6 Neutron Organ Dose Open S SC&A recommends: Close.

34 6 High-Risk Jobs (Neutron 

Exposure)

Open N, S NIOSH revisiting issue. 

SC&A recommends: Remain 

Open.

35 6 Multiplying Factors for 

Missed Neutron Dose

Open S SC&A recommends: Close.

36 6 Missed Low Energy Beta 

Dose

Open S SC&A recommends: Close.

37 6 Error in Reference Closed -

38 6 Shallow Dose Closed -

Notes: 

(a) The WG closed Issues 3, 7, 10, 11, 12, 13, 22, 25, 37, and 38 at its June 21, 2011, meeting. 

(b) The six volumes comprising the site profile are numbered ORAUT-TKBS-0007-1 to ORAUTTKBS-0007-6. Their titles are: 

1. Introduction 

2. Site Description 

3. Occupational Medical Dose 

4. Occupational Environmental Dose 

5. Occupational Internal Dose 

6. Occupational External Dose 

(c) Assignments made at the June 21, 2011, WG meeting. N – NIOSH; S – SC&A 

(d) June 2011 WG meeting recommended combining issues 9 and 23.
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2.0 SITE PROFILE REVIEW CHRONOLOGY 

The following briefly summarizes the chronology of key events in the INL/ANL-W TBD review 

process. 

July 2004: NIOSH issues Rev. 0 of TBD. 

Sept 2005: SC&A issues review of Rev. 0 TBD (SC&A 2005). 

Jan 2006: SC&A issues Rev. 1 of its September 2005 review adding worker interviews and 

Issues Resolution Matrix (SC&A 2006). 

Apr-Aug 2007: NIOSH issues revised TBDs; notably, the ones for internal and external 

exposures were completely rewritten. 

July 2007: SC&A issues Review of ANL-W Site Profile (SC&A 2007). 

Dec 2008: SC&A issues a supplemental review—a “quick look” (no detailed review or 

comparison)—of the 2007 TBDs, concluding that the original January 2006 SC&A comments 

are still valid, as none of its findings appear to have been addressed in the 2007 TBDs. The 

SC&A supplemental review includes a revised Issues Resolution Matrix (SC&A 2008). 

6/10/09: First INL WG meeting. WG decides to combine INL and ANL-W (physically located 

within the INL site) TBDs and review the two sites together. 

7/15/09: SC&A produces a “Combined Issues Matrix for INL and ANL-W” (SC&A 2009).

Dec 2009–Apr 2011: NIOSH revises all TBDs to merge INL and ANL-W and to make other 

revisions (ORAUT 2009, 2010a, 2010b, 2010c, 2010d, 2011b). These are the current revisions. 

5/31/11: NIOSH adds its responses to the Issues Resolution Matrix. 

6/21/11: Second WG meeting. SC&A produces a memo entitled, “INL/ANL-W Work Group 

Meeting, June 21, 2011: Actions,” including a table of action items (SC&A 2011a). 

6/24/11: SC&A issues a revised table incorporating comments from June 21 meeting 

participants (SC&A 2011b). 

7/16/13: NIOSH’s status report on INL/ANL-W site profile issues resolution given at the 

ABRWH Meeting in Idaho Falls, Idaho (NIOSH 2013a). 

10/23/13: SC&A issues its Idaho National Laboratory (INL) Site Profile Review Status Update, 

draft, Rev. 0 (SC&A 2013). This is a complete summary of the history and status of the issues. 
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11/7/13: NIOSH issues two brief status reports: 

(a) INL WG Issues Summary (NIOSH 2013b). 

(b) Nov. 2013 Status on INL WG Issues (this is the file name. The document has no report 

name). This is a NIOSH markup of an SC&A table entitled: “October 2013 Status & 

Update in INL TBD WG Issues” (NIOSH 2013c).

2/28/14: SC&A issues its revised Idaho National Laboratory (INL) Site Profile Review Status 

Update, draft, Rev. 1 (SCA-SP-IM2013-0005, Rev. 1). This is a complete summary of the 

history and status of the issues, updating the Rev. 0, SC&A 2013 report. 
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3.0 TBD ITEM STATUS AND DISCUSSION 

This section contains a comprehensive listing of the 38 issues by TBD, including, for each issue, 

the TBD section (at the time of the SC&A 2006 review); the page number of the full comment 

made in SC&A 2006 and SC&A 2008; NIOSH responses to SC&A comments made just prior to 

the June 21, 2011, WG meeting; the WG Action Item or determination from the June 21st

meeting; and SC&A’s subsequent response to the items assigned to it (SC&A 2011b) performed 

in a quick review (SC&A 2013) after the meeting; and SC&A’s latest response after a 

subsequent thorough review (SCA-SP-IM2013-0005, Rev. 0). Note that this report presents the 

information in a linear fashion rather than the more traditional spreadsheet matrix in the interests 

of easier readability, as the matrix would have several very long and narrow columns. In 

addition, SC&A took the liberty in a few places to slightly edit the previously expressed findings 

and responses to clarify them. 
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3.1 ISSUE 1: ROUTINE AIRBORNE RELEASES 

ORAUT-TKBS-0007-4, Occupational Environmental Dose, TBD Sect. 5.1.1.1, SC&A p. 45 

Issue: Source terms provided require improvement for use in determining the worker intake 

from airborne releases at different INL facilities. The data NIOSH uses do not take into account 

the deficiencies in the environmental monitoring equipment and their locations, and, in addition, 

NIOSH does not assess the uncertainties associated with the meteorological dispersion model 

used for the INL site. Most importantly, the source terms do not account for worker inhalation 

of resuspended contaminated soils and materials around the INL facilities. 

NIOSH Response: The SC&A comments are directly related to the Tiger Team report 

DOE/EH-0178 (DOE 1991). That report cites 40 CFR 50 and 40 CFR 58, both of which are 

EPA regulations concerning primary ambient air quality standards. The equipment type, location 

requirements, and uncertainties referred to in those standards are designed for purposes other 

than those for which NIOSH is using this data. The dose calculations made by NIOSH are 

independent of the requirements in those standards. NIOSH requests the reference SC&A used 

to determine that the uncertainties not accounted for in the meteorological dispersion model. 

WG Action Items: 

 NIOSH: Revisit meteorological dispersion model, especially for relatively close 

proximity to release points. 

Note: (Oct. 2013 update) NIOSH is working on a white paper to address this issue: INL 

Environmental Monitoring. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH is working on a white paper to address this 

issue. 

SC&A Further Review: SC&A is waiting for the NIOSH white paper. Hence, SC&A 

recommends that this issue remain Open.
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3.2 ISSUE 2: EPISODIC AIRBORNE RELEASE 

ORAUT-TKBS-0007-4, Occupational Environmental Dose, Sect. 5.1.1.2, SC&A p. 55 

Issue: The airborne releases associated with several of the Initial Engine Tests of the Aircraft 

Nuclear Propulsion (ANP) Program were likely to have been underestimated by factors ranging 

from 2 to 16. Also, NIOSH did not evaluate the uncertainties associated with the deficiencies in 

air monitoring equipment. 

NIOSH Response: Please provide a basis for the “factors ranging from 2 to 16.” Please see 

response to number 1 regarding uncertainties. 

WG Action Items: 

 NIOSH: Review SC&A report: Critical Review of Source Terms for Select Initial 

Engine Tests Associated with the Aircraft Nuclear Propulsion Program and INEL, 2003, 

on the RAC modeling approach. [SC&A 2003] 

Note: (Oct. 2013 update) NIOSH is working on a white paper to address this issue: Aircraft 

Nuclear Propulsion Issue. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH is working on a white paper to address this 

issue. 

SC&A Further Review: SC&A is waiting for the NIOSH white paper. Hence, SC&A 

recommends that this issue remain Open.
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3.3 ISSUE 3: DIRECT GAMMA EXPOSURES 

ORAUT-TKBS-0007-4, Occupational Environmental Dose, Sect. 5.1.1.3, SC&A p. 57 

Issue: The fence-line thermoluminescent dosimeter (TLD) measurements are not adequate for 

reconstructing direct gamma doses to personnel working outdoors at and around a specific INL 

facility inside the fence-line boundary, because they do not take into account the most bounding 

scenarios. 

NIOSH Response: Personnel within the various facilities were monitored and access was 

controlled. Dosimetry was required to enter the various “fenced” facilities on site. TLDs were 

placed on the fences enclosing the various facilities. The dose from these TLDs represents the 

bounding condition at the closest point an unmonitored individual could get to a facility. 

WG Action Items: None. Issue closed based on NIOSH’s response at the June 21, 2011, WG 

meeting. 

ISSUE CLOSED
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3.4 ISSUE 4: COMPLETENESS AND QUALITY OF INL INTERNAL DOSIMETRY 

PROGRAMS 

ORAUT-TKBS-0007-4, Occupational Environmental Dose, Sect. 5.1.2.1, SC&A p. 73. 

Issue: The identification and determination of missed internal dose for workers are heavily 

influenced by the assumption of confidence, but SC&A found this premise to be unsupported 

after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, 

many site experts interviewed by SC&A indicated that there were significant deficiencies and 

inconsistencies in radiation work practices throughout the operating history of the INL facilities. 

These observations jeopardize the validity of the TBD approaches in reconstructing missed 

worker internal doses. 

NIOSH Response: The default table for missed dose (5-24) does not have a basis in the 

“confidence” of the INL radiological program. The table is based on monitoring results, 

favorable ratios, and other claimant-favorable assumptions. 

However, in resolving the issue associated with SC&A’s Finding 3.5-1 for the ANL-W Site 

Profile, the previous approaches used to calculate missed and unmonitored internal doses have 

been completely replaced. The missed and unmonitored doses for activation and fission products 

are now based on the approach described in OTIB-0054 (ORAUT 2007b). The unmonitored 

actinide doses are now being calculated using a new site-specific approach based on source term 

information and a broader list of radionuclides. 

WG Action Items: 

 NIOSH: Report the number of people sampled and the time periods when the samples 

were taken. 

 SC&A: Review applicable portions of the current version of the Internal Exposure TBD 

and reassess the issue. 

SC&A Reassessment: Upon reviewing TBD Section 5, Revision 3, SC&A observes that 

Section 5.8 “Default for Missed Dose” has been deleted and a new Section 5.6 “Intake and 

Internal Dose Assessment for Unmonitored Workers” has been added. New Section 5.6 refers to 

OTIB-0018 (ORAUT 2005a) and OTIB-0033 (ORAUT 2005c) for assigning a default missed 

internal dose. Additionally, in Section 5.5.1, missed and unmonitored doses for activation and 

fission products are now based on the approach described in OTIB-0054 (ORAUT 2007b), as 

stated by NIOSH in their response. OTIB-0018, OTIB-0033, and OTIB-0054 have each been 

reviewed by SC&A, under the Procedures Review Subcommittee [N.B., SC&A is currently (Oct. 

2013) reviewing OTIB-0054, Rev. 1]. Outstanding issues with these three OTIBs are being 

resolved within that Subcommittee.

SC&A is satisfied with the manner in which NIOSH has resolved this issue, and recommends to 

the WG that this issue be closed. 
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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.5 ISSUE 5: HIGH-RISK JOBS (INTERNAL EXPOSURE) 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.2, SC&A p. 77 

Issue: NIOSH did not evaluate comprehensively the facility and field data to identify and 

separate out the high-risk or high-dose jobs for worker internal exposures. This information is 

essential for dose reconstructors to fill in the data gap when dose records in a claimant’s file are 

not complete. 

NIOSH Response: NIOSH has monitoring records for internal dose and NIOSH feels the 

records are fairly comprehensive for “high-risk” jobs. The TBD contains requirements for 

reconstructing internal doses and for missed doses. 

WG Action Items: 

SC&A: Review applicable portions of the current version of the Internal Exposure TBD and 

reassess the issue. 

SC&A Reassessment: Revision 3 of the TBD does not explicitly address this finding; rather, 

the NIOSH response argues that the dose reconstruction methodology contained within the TBD 

is sufficient. A similar concern was raised by SC&A during the review of OTIB-0052 (ORAUT 

2011a) regarding “high-risk” construction jobs. With regard to the OTIB-0052 concern, SC&A 

suggested (and we believe that NIOSH concurred) that wording be provided in OTIB-0020

(ORAUT 2008a) to instruct the dose reconstructor to modify the dose reconstruction and/or 

perform additional research if a claimant expresses a specific concern (either verbally or in 

writing) and the dose reconstructor is able to confirm that concern. SC&A suggests that a 

similar statement be provided in the INL TBD.

SC&A recommends to the WG that this finding remain open for further discussion. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the statement above, shown under 

WG Action Items: SC&A. 

SC&A Further Review: SC&A repeated its review of the Internal Exposure TBD and believes 

that its earlier assessment, shown above under WG Action Items: SC&A Reassessment, remains 

valid and that the “action” is on NIOSH to respond. Hence, SC&A recommends that this issue 

remain Open.
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3.6 ISSUE 6: CALIBRATION OF INTERNAL DOSIMETRY ANALYTICAL AND 

MONITORING EQUIPMENT 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.3, SC&A p. 78 

Issue: The TBD does not provide any information on the calibration procedures, sensitivities, 

and standards of the internal dosimetry analytical equipment and monitoring instrumentation. 

The 1991 DOE Tiger Team findings (DOE 1991) show the deficiencies in these areas. NIOSH 

should evaluate the uncertainties and impacts on the internal dose assessment results associated 

with the deficient calibration programs at INL. 

NIOSH Response: The references cited in the TBD provide information on the analytical 

equipment maintenance. Other facility audits find the program adequate. 

The equipment type, location requirements, and uncertainties referred to in the Tiger Team 

report are designed for purposes other than those for which NIOSH is using this data. The dose 

calculations made by NIOSH are independent of the issues discussed in an old Tiger Team 

report. NIOSH did account for uncertainties associated with the radiological model. 

WG Action Items: 

SC&A: Review applicable portions of the current version of the Internal Exposure TBD and the 

Tiger Team report and reassess the issue.

SC&A Reassessment: There is no additional information provided in Revision 3 to address this 

observation. The only additional information is that provided in the NIOSH response. There is 

too little information provided in the response to allow SC&A to agree or disagree with it. 

SC&A would like to know, what were the different “designed for purposes” between the Tiger 

Team report and NIOSH data? Also, how are the NIOSH calculations independent of the issues 

discussed in the Tiger Team report? Finally, how did NIOSH account for uncertainties 

associated with the radiological model?

SC&A recommends to the WG that this issue remain open for further discussion. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the statement above, shown under 

WG Action Items: SC&A. 

SC&A Further Review: SC&A reexamined the INL Tiger Team report (DOE 1991), the 

current site profile Internal Dosimetry TBD (ORAUT 2010d), the SC&A comment and 

background discussion in its 2006 site profile review (SC&A 2006) pertaining to Issue 6, and, 

additionally, Defense Nuclear Facilities Safety Board (DNFSB) reports (DNFSB 1994a, 1994b, 

1995); the latter were found not germane to this issue and will not be discussed in the following. 
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The INL Tiger Team assessment was conducted as part of the overall DOE Tiger Team 

Independent Assessment Program across the DOE facilities complex, which begun in the late 

1980s. The INL assessment was accomplished during the summer of 1991 and the 

comprehensive, multi-volume report (DOE 1991) was published in August 1991. The evaluation 

focused on several areas, notably environment, safety and health, management, and organization. 

Much of the evaluation and many of the findings are programmatic and procedural, such as 

organizational structure (multiple governmental and private organizations were involved 

simultaneously at INL), direction, and coordination, and compliance with federal, state, and local 

regulations and procedures. The assessment is quite critical overall, particularly with respect to 

management. With regard to radiation protection, the Executive Summary notes: 

The radiation protection program at EG&G Idaho [i.e., INL] was found to be 

particularly deficient. The nuclear accident dosimetry program is not in 

compliance with performance requirements for fixed and personnel nuclear 

accident dosimeters. The personnel dosimeter program is not in compliance with 

applicable DOE Orders and there is no program to identify and resolve problems 

related to the response of radiation protection instrumentation. 

Section 5.1.2 of the original SC&A site profile review (SC&A 2006), which assessed Rev. 0 of 

the INL Internal Dose TBD (ORAUT 2004b), discusses several issues noted in the Tiger Team 

report and quotes portions of it. In particular, Section 5.1.2.1, Completeness and Quality of INL 

Internal Dosimetry Programs, concludes: 

Given these deficiencies noted in the INL radiological protection and internal 

dosimetry programs, it is unlikely that the information and internal exposure 

records provided in the worker files are complete. It is also likely that many 

worker internal exposures associated with high-dose jobs were not monitored or 

documented. 

SC&A reviewed the current, Rev. 3, INL Internal Dose TBD (2010d) and finds that it addresses 

some of the areas raised in Issue 6. For example, Section 5.1.6 and subsequent sections discuss 

the INL internal dosimetry program throughout the years, including air monitoring and in-vitro 

and in-vivo radiobioassay techniques and programs. Those sections contain several tables on 

detection sensitivities, such as minimum detectable activities (MDAs) for different types of 

measurements over different periods of time. The TBD discusses uncertainties only for 

bioassays in Section 5.4.2, and states that: 

The uncertainty values for all types of bioassay measurements are typically 

included in the INEL’s [i.e., INL’s] bioassay records that are provided by the 

DOE. When measurement-specific uncertainty values are available, those values 

are preferred for the data analysis over generic values. When the uncertainty 

values are not included with the bioassay records, the uncertainty values to be 

used for the data analysis should be determined in accordance with the 

recommendations in the “Technical Information Bulletin: Internal Dose 

Reconstruction” [i.e., ORAUT-OTIB-0060, ORAUT 2007a]. 
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However, the TBD still does not comment on how accurate the data are expected to be, given the 

aforementioned deficiencies in, among other factors, calibration of monitoring and assay 

equipment, found in the radiation protection program by the Tiger Team assessment. The 

reliability of NIOSH’s dose calculations for claimants depends on the reliability of the 

underlying data. Hence, SC&A recommends that Issue 6 remain open pending an elaboration of 

the issue by NIOSH, subsequent review of the response by SC&A, and action of the WG.
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3.7 ISSUE 7: CHANGES OF INTERNAL DOSE LIMITS 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.4, SC&A p. 78 

Issue: Inconsistent work practices were prevalent in the early years of the INL operation and 

may have led to significant missed dose to workers. NIOSH should evaluate the impacts of these 

dose limit changes over the operating history of INL to see whether there were missed doses in 

the early years when the radiation protection policy was less protective and inconsistently 

implemented. 

NIOSH Response: Dose limits have no impact on missed doses, since missed doses are solely 

the doses that would have gone undetected by a particular monitoring method because of the 

limit of detection. Whereas, unmonitored dose is that for which no monitoring was performed. 

Therefore, NIOSH’s response assumed that this comment was applicable to the potential 

unmonitored doses, since the dose limits were functions of when internal dose monitoring was 

performed. 

A review of 90,515 urine sample results indicates that over 98% of the gross beta (GB) and gross 

gamma (GG) in urine results were below the minimum detectable activity (MDA) values 

provided in this TBD. In addition, a significant number of those positive bioassay measurements 

were follow-up measurements to previously identified intakes. Given that an overwhelming 

majority of the GB and GG in urine bioassay results, which constitute most of the bioassay data 

in the early years of the INL’s operations, were below the MDAs for those measurement 

methods, it is unlikely that the alleged inconsistent practices led to significant unmonitored 

internal doses. 

WG Action Items: None. WG concurs with NIOSH. Issue closed at the June 21, 2011, WG 

meeting. 

ISSUE CLOSED
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3.8 ISSUE 8: HIGH-FIRED PLUTONIUM AND URANIUM INTAKES 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.5, SC&A p. 78 

Issue: The TBD did not evaluate the hazard associated with high-fired plutonium and uranium 

at the INTEC (ICPP) and Radioactive Waste Management Complex (RWMC) facilities. Highfired Pu-238, Pu-239, and uranium are not easily dissolvable, nor do they readily break into very 

small particles. They also emit some gamma rays and neutrons. Similar to the treatment of 

recycled uranium, NIOSH should evaluate the lung dose for intake of high-fired uranium and 

plutonium oxide particulates (alveolar deposition). 

NIOSH Response: The INL internal TBD has been revised to include super-S Pu as a potential 

material type at the INL. 

Please define what you mean by high-fired uranium intakes. 

WG Action Items: 

 NIOSH: Revisit the issue; in particular, the applicability of ICRP-66. Produce a “white 

paper” on recycled uranium.

 SC&A: Review applicable portions of the current version of the Internal Exposure TBD.

SC&A Reassessment: To create ceramic pellets, uranium dioxide (UO2) powder is fired in a 

high-temperature (about 1,700°C) sintering furnace. The pellets are then ground to a uniform 

size. Inhalation or ingestion of this sintered material is what is meant by “high-fired uranium 

intakes.” High-fired uranium has an absorption classification of slow (S).

The SC&A review of Revision 3 confirms that super-S plutonium has been included in the 

determination of which solubility classification yields the highest dose (Section 5.1.4). 

Likewise, uranium class S representing high-fired uranium is also included (i.e., the “dose 

reconstructor should assume either type M or type S uranium to maximize the dose” 

(Section 5.5.5). 

Therefore, SC&A believes that NIOSH has addressed this issue, considers this issue to be 

resolved, and recommends that the WG close it. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.9 ISSUE 9: SKIN AND FACIAL CONTAMINATION 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.6, SC&A p. 79 

Issue: This TBD does not consider incidents with workers having skin contamination, facial 

contamination, and positive nasal swipes in the INL facilities. These kinds of problems would 

be compounded by the deficiencies in air sampling systems and ineffective respiratory protection 

programs. Guidance should be provided to a dose reconstructor to account for the missed dose 

due to the unaccounted uptake. 

NIOSH Response: All versions of the internal TBD have indicated that the monitoring and 

analytical programs were designed to initiate, through in vitro and/or in vivo bioassay analysis, 

an investigation of any potential internal intake as indicated by positive air sampling, personnel 

contamination, etc... As a result, the skin and facial contamination incidents would have followup in vitro and/or in vivo bioassay measurement data when an intake was suspected. Therefore, 

the alleged deficiencies are of no consequence in NIOSH’s dose reconstruction methods, since 

urine, fecal, whole body count, and lung count data would take precedence over air monitoring, 

contamination survey, and nasal smear data. 

WG Action Items: 

 NIOSH: Look at how the issue of shallow exposures to radioactive particles or flakes is 

addressed. Did the facilities where this may have been an issue have programs 

addressing it? What work controls were used on the site? 

 SC&A: Look at ORAUT-OTIB-0017 (ORAUT 2005b) for how it addresses potential 

hot particle doses. 

SC&A Reassessment: SC&A performed a review of OTIB-0017 (ORAUT 2005b), including 

the “hot particle” portions, in June 2006 under the direction of the Procedures Review 

Subcommittee. The review of OTIB-0017 resulted in 15 findings being identified by SC&A, 

including Findings 3 and 5, which were related to “hot particles.” All 15 of the OTIB-0017 

findings have been discussed among the Procedures Review Subcommittee, NIOSH, and SC&A, 

and closed. In regards to the “hot particle” findings, SC&A recommended closure of the 

findings because it is believed that the methodology in OTIB-0017 could not be improved upon, 

even though it was believed to be technically weak. Obviously, NIOSH disagreed that OTIB0017 was technically weak.

SC&A cannot make a recommendation to the WG regarding this observation until we have 

reviewed the NIOSH response to their action item. 

Note: (Oct. 2013 update) NIOSH is working on a white paper to address this issue: Hot Particle 

Issue. 
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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH is working on a white paper to address this 

issue and comments that this issue should be merged with Issue 23, High Risk Jobs (Beta/gamma 

Exposure). NIOSH also states that it is awaiting SC&A’s response: “SC&A: Look at ORAUTOTIB-0017 for how it addresses potential hot particle doses.” 

SC&A Further Review: SC&A is waiting for NIOSH’s white paper before it will consider this 

issue further. Hence, SC&A recommends that this issue remain Open.
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3.10 ISSUE 10: BREATHING RATES 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.7; SC&A p. 79 

Issue: The TBD assumption appears less claimant favorable than the ICRP or NCRP 

assumptions. 

NIOSH Response: Based on the Section 5.1.2.7 of SCA-TR-TASK1-0005, this comment is 

actually being made for ORAUT-TKBS-0007-4. 

NIOSH was only able to find breathing rate information in Footnote c of Table 1 in ICRP 68, 

which also indicates that the information being provided was obtained from Table 6 of ICRP 66. 

The breathing rates in ICRP Reports 23, 66, and 68 for 8 hr of light work activity are all 

9.6 m

3

/workday. The INL Environmental TBD used an intake rate of 2,400 m3/yr, which is 

equivalent to 9.6 m3/workday times 250 workdays/yr. Therefore, the breathing rate used in the 

INL Environmental TBD is equivalent to the breathing rates recommended in ICRP Reports 23, 

66, and 68. 

WG Action Item: None. The WG accepted NIOSH’s response and closed the issue at the June 

21, 2011, WG meeting. 

ISSUE CLOSED
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3.11 ISSUE 11: NON-OCCUPATIONAL WORKER ELIMINATION OF DU 

BACKGROUND 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.8, SC&A p. 79 

Issue: The derivation of the background value of 0.16 μg/L used for subtraction from each 

urinalysis result of uranium prior to assessment of occupational internal dose for Specific 

Manufacturing Capability (SMC) Facility radiation workers is not technically sound. The 

baseline background (population) intake value was determined by a study of urine samples 

submitted by non-radiation workers at the SMC facility. A better approach would be to use the 

urine excretion samples by non-INL people in the Idaho Falls area. NIOSH should consider this 

subtraction from urinalysis results as a missed internal dose. 

NIOSH Response: The idea to collect background samples from non-INL personnel is not 

feasible and is unreasonable. ICRP 23 lists the daily intake of naturally occurring uranium as 

1.9 μg per day. Assuming equilibrium, the daily excretion of uranium through urine would also 

be 1.9 μg. Applying the excretion volume for Reference Man of 1.4 liters per day, this results in 

a range of typical urinary concentration of 0.04 to 0.5 μg/L. Therefore, the INL’s adjustment 

value of 0.16 μg/L is consistent with ICRP reference values for natural uranium. 

Reference: King, V.A., 2001, Technical Basis for Internal Dosimetry at SMC, EDF No. SMC2001-02, Rev. 3, Idaho National Environmental and Engineering Laboratory, Idaho Falls, Idaho, 

May 31. [SRDB Ref ID: 8479, p. 67] 

WG Action Item: None. The WG accepted NIOSH’s response and closed the issue at the June 

21, 2011, WG meeting. 

CLOSED
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3.12 ISSUE 12: UNMONITORED WORKERS 

ORAUT-TKBS-0007-5, Occupational Internal Dose, TBD Sect. 5.1.2.9, SC&A p. 80 

Issue: The potential missed doses for unmonitored workers would be from inhaling resuspended 

contaminated soils and ingesting contaminated materials while eating in a contaminated, 

previously considered uncontaminated, area (such as office and cafeteria). NIOSH should 

evaluate these potential missed doses. 

NIOSH Response: These scenarios are considered in the development of unmonitored doses. 

WG Action Items: None. The WG accepted NIOSH’s response and closed the issue at the June 

21, 2011, WG meeting. 

CLOSED
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3.13 ISSUE 13: NAVAL REACTOR FACILITY WORKERS 

ORAUT-TKBS-0007-4 (Environmental), -5 (Internal), -6 (External), SC&A p. 80 

Issue: As the internal dose TBD indicates, “some workers’ internal dose could have resulted 

from their support work at the NRF.” NIOSH should evaluate the potential missed dose at the 

Naval Reactor Facility (NRF) for these workers. 

NIOSH Response: Workers assigned to the NRF are not covered as required by EEOICPA. 

However, doses received by NRF workers while responding to the Stationary Low-Power 

Reactor Number One (SL-1) accident are covered. 

WG Action Items: None. The WG found the NIOSH response acceptable and closed the issue 

at the June 21, 2011, WG meeting. 

CLOSED
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3.14 ISSUE 14: PLUTONIUM MONITORING 

ORAUT-TKBS-0007-5, Occupational Internal Dose, Sect. 5.1.2.11, SC&A p. 80 

Issue: The TBD does not provide any historical information on the plutonium analysis methods 

used at INL. It is entirely possible that selective plutonium monitoring on workers was used at 

INL until 1980, but without this information, the dose reconstructors would not be able to assign 

missed internal dose due to plutonium intakes in the time period before 1980. NIOSH should 

provide information on plutonium monitoring. 

NIOSH Response: Because plutonium was not separated from the spent nuclear fuel at the INL, 

the plutonium was always present with the more readily detectable mixed fission products that 

were also in the spent nuclear fuel. Therefore, in the vast majority of the plutonium exposure 

scenarios, the plutonium would have been present with the product and waste streams containing 

mixed fission products, and any intakes of radioactivity would have been more readily detectable 

by performing bioassay measurements for mixed fission products. Exceptions to these exposure 

scenarios may have included exposures to laboratory workers that may have separated and/or 

handled laboratory quantities of plutonium and the limited number of workers that may have 

somehow received a plutonium intake from the plutonium that was plated out on the surfaces 

inside a decontaminated hot cell at the ICPP. Performing bioassay measurements for these few 

types of scenarios and possibly just as experimental bioassay procedures, would explain the 

sporadic plutonium bioassay data. Because the INL appears to have routinely performed 

bioassay measurements for mixed fission products when it thought there was any potential for 

exposure, and because the intakes of mixed fission products can be correlated to intakes of 

plutonium, the dose reconstruction process for the INL involves assigning missed plutonium 

doses based on either Pu:Sr-90 or Pu:Cs-137 ratios that get applied to intakes that were estimated 

for those fission products. 

WG Action Items: 

 NIOSH: Provide SC&A with the source documents used. 

 SC&A: Review applicable portions of the current version of the Internal Exposure TBD 

and reassess the issue.

SC&A Reassessment: SC&A’s review of Revision 3 indicates that the text of TKBS-0007-5 

has been revised to incorporate a discussion on bioassay monitoring in Section 5.1.6.3.

Therefore, SC&A believes that NIOSH has addressed this issue, considers this issue to be 

resolved, and recommends that the WG close this issue. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.15 ISSUE 15: SL-1 ACCIDENT DOSE RECONSTRUCTIONS 

ORAUT-TKBS-0007-4/5/6, Occupational Environmental Dose, Occupational Internal Dose, 

Occupational External Dose, TKBS-5 Section 5.1.3, SC&A p. 80 

Issue: The TBDs do not evaluate the potential missed internal and external doses or the 

associated uncertainties for the over 1,000 rescue and cleanup workers involved with the SL-1 

accident that occurred in January 1961. There was a high potential for significant exposures, 

because the equipment used and the radiological control policies in place in that era were not as 

advanced and protective as those in current use. The TBDs should develop adjustment factors 

related to stay time, dose field estimates, internal dose results, external dose readings, and 

contamination level estimates. 

NIOSH Response: NIOSH has a significant dosimetry history for first-responder and recovery 

workers at the SL-1 facility. The dosimetric records provide enough data to accurately 

reconstruct doses. In some instances, SL-1 specific coworker dose is used. SL-1 dose 

reconstruction data are addressed in the TBD. 

WG Action Items: 

 SC&A: Review applicable portions of the current versions of the TBDs and reassess the 

issue. 

SC&A Reassessment: SC&A’s review of Revision 3 indicates that NIOSH did not make any 

changes to TKBS-5 as a result of this finding. NIOSH provided additional information in its 

issue response; however, SC&A would like to see more specifics before recommending that this 

finding be closed. For example, what constitutes “a significant dosimetry history?” How was it 

determined that the “dosimetric records provide enough data to accurately recalculate doses?” 

An example of an instance when SL-1-specific coworker dose was used would be appreciated.

SC&A recommends that this finding remain open for further discussion. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the content of the WG Action Items: 

SC&A, shown above. 

SC&A Further Review: SC&A revisited the current versions of the INL TBDs that address the 

SL-1 accident: Occupational Environmental Dose (ORAUT 2010c), Occupational Internal Dose 

(ORAUT 2010d), and Occupational External Dosimetry (ORAUT 2011b). SC&A would still 

like to see a NIOSH discussion of the personnel exposures and underlying data associated with 

the SL-1 criticality accident. Hence, SC&A recommends that the WG keep this issue open.
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3.16 ISSUE 16: COMPLETENESS AND QUALITY OF INL BETA/GAMMA 

DOSIMETRY AND RECORD KEEPING PROGRAMS 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.1, SC&A p. 96 

Issue: The identification and determination of missed external dose for workers are heavily 

influenced by this assumption of confidence, but SC&A found this premise to be unsupported 

after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, 

many site experts interviewed by SC&A indicated that there were significant deficiencies and 

inconsistencies in radiation work practices throughout the operating history of the INL facilities. 

These observations jeopardize the validity of the TBD approaches in reconstructing missed 

worker external doses. 

NIOSH Response: Please provide the reports of “significant deficiencies and inconsistencies in 

radiation work practices” and provide how the NIOSH-derived missed dose calculations are 

subject to the results of the Tiger Team report. 

WG Action Items: 

 NIOSH/SC&A: SC&A will clarify its concerns with respect to the Tiger Team reports 

and NIOSH will respond to those concerns and identify any additional relevant issues. 

SC&A Reassessment: None at this time.

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the statement above, shown under 

WG Action Items: SC&A. 

SC&A Further Review: SC&A re-examined the INL Tiger Team report (DOE 1991), the 

current site profile External Dose TBD (ORAUT 2011b), the original External Dose TBD 

(ORAUT 2004a), the original SC&A comment and background discussion, as well as the site 

expert interview summary, in its 2006 site profile review (SC&A 2006) pertaining to Issue 16, 

and, additionally, the Defense Nuclear Facilities Safety Board (DNFSB) reports (DNFSB 1994a, 

1994b, 1995); the latter were found not germane to this issue and will not be discussed in the 

following. 

The INL Tiger Team assessment was conducted as part of the overall DOE Tiger Team 

Independent Assessment Program across the DOE facilities complex, which begun in the late 

1980s. The INL assessment was accomplished during the summer of 1991 and the 

comprehensive, multi-volume report (DOE 1991) was published in August 1991. The evaluation 

focused on several areas, notably environment, safety and health, management, and organization. 

Much of the evaluation and many of the findings are programmatic and procedural, such as 

organizational structure (multiple governmental and private organizations were involved 

simultaneously at INL), direction, and coordination, and compliance with federal, state, and local 
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regulations and procedures. The assessment is quite critical overall, particularly with respect to 

management. With regard to radiation protection, the Executive Summary notes: 

The radiation protection program at EG&G Idaho [i.e., INL] was found to be 

particularly deficient. The nuclear accident dosimetry program is not in 

compliance with performance requirements for fixed and personnel nuclear 

accident dosimeters. The personnel dosimeter program is not in compliance with 

applicable DOE Orders and there is no program to identify and resolve problems 

related to the response of radiation protection instrumentation. 

The Tiger Team report also mentions in several places that not everyone who should have had 

personal monitoring actually had it. 

Section 5.1.4.1.1 of the SC&A site profile review (SC&A 2006), which assessed Rev. 0 of the 

INL External Dose TBD (ORAUT 2004a), cites several issues noted in the Tiger Team report, as 

well as site interviews SC&A had conducted. In particular, in reference to missed dose: 

(3) During the site expert interviews, past and current workers at INL facilities 

provided first-hand information about potential missed dose scenarios and 

deficiencies in personnel protection programs and dosimetry record keeping. 

Even though there is a sentiment that the INL radiological protection programs 

and the advancement of equipment and techniques have made dramatic 

improvements over the past two decades, the missed dose problems due to these 

deficiencies in the early days must be addressed in a fair and reasonable manner. 

SC&A reviewed the current, Rev. 3, INL External Dose TBD (ORAUT 2011b) as well as the 

Rev. 0 External Dose TBD (ORAUT 2004a) and found that the issue is addressed in Section 6.5 

of the former, Missed Dose, with subsections; dosimeter not worn, missed photon dose, missed 

electron dose, and missed neutron dose. The first two subsections are applicable to this issue. 

For the situation of a worker claiming exposure to radiation while not wearing a dosimeter 

(Section 6.5.1, dosimeter not worn), the TBD refers the dose reconstructor to ORAUT-OTIB020, Use of Coworker Dosimetry Data for External Dose Assignment (ORAUT 2011c). The 

OTIB gives generic guidance, but NIOSH has indicated that it is currently preparing an INLspecific coworker model, which SC&A will review when it is available. The other subsections 

of Section 6.5 provide guidance for other missed dose situations that might be applicable to a 

particular dose reconstruction. 

SC&A recommends that the WG keep this issue open pending receipt and review of the INLspecific coworker model under development by NIOSH.
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3.17 ISSUE 17: PENETRATING AND NON-PENETRATING DOSES 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.2, SC&A p. 96 

Issue: NIOSH should re-evaluate the missed gamma dose, due to the deficiencies in the 

procedures and algorithms. 

NIOSH Response: The under-reporting of the penetrating photon doses at the INL, due to the 

two-element film dosimeter’s limitation for measuring low-energy photon doses, is much less of 

a significant situation for the majority of exposure scenarios than what is being indicated by 

SC&A. 

INL Health Physics personnel have been aware of the dosimeter response issues associated with 

low energy photons for many years, including at least some of the years when the two-element 

film dosimeters were being used. However, there were ways for the dosimetry personnel to 

determine whether a non-penetrating dose was likely attributable to beta or low-energy photon 

radiation. One such way was noting the ratio of the Open Window (OW) and S readings from 

the dosimeter, since this ratio should be relatively consistent for similar radiation fields (i.e., in 

terms of radiation type and energy distribution). Because the OW reading for the two-element 

film dosimeters being used at the INL had a significant over-response to low-energy photons, an 

unusual amount of blackening on the OW film would be observed when the dosimeter was 

exposed to low-energy photons. Therefore, an OW to S reading ratio that was significantly 

higher than usual would be an indication that the worker’s non-penetrating dose contained a 

significant contribution from low-energy photon exposure. Also, using such dosimeter readings 

as is would potentially result in a significant overestimate of the non-penetrating dose that was 

being reported and could potentially have resulted in a dose limit being exceeded. Therefore, it 

was in the INL’s best interest to at least be somewhat familiar with the OW to S reading ratios 

and the photon energy distributions for the various exposure scenarios and to adjust any doses 

that were too high because of the dosimeter’s over-response to low-energy photons. In addition 

to the unusual amount of blackening that would have been observed on the OW dosimeter, the 

survey instrument readings would have indicated to the INL Health Physics personnel that the 

“beta” doses based on the dosimeter results were being significantly over-reported and that they 

were likely seeing the effect of the dosimeter’s over-response to low energy photon radiation, 

since the hand held survey instruments that were carried during most hot jobs did not overrespond to the low-energy photons. 

WG Action Items: 

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue. 

SC&A Reassessment: SC&A’s review of Revision 3 indicates that NIOSH did not make any 

changes to TKBS-0007-5 as a result of this finding. NIOSH provided additional information in 

their issue response. However, SC&A suggests that NIOSH incorporate the information 

provided above in the response into TKBS-0007-5 during its next revision, so that future 
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reviewers will have access to it. SC&A believes that the NIOSH response has adequately 

addressed this issue and recommends that the WG close it. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.18 ISSUE 18: CORRECTION FOR BETA DOSES

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.3, SC&A p. 97 

Issue: NIOSH should develop a method to consistently account for uncertainties in dosimetry 

readings. Claimant-favorable correction factors should be developed for beta dose 

reconstruction. 

NIOSH Response: Table 6-9 in the TBD provides correction factors for under-reporting. 

Comment 18 quotes the following statement along with several others from OCAS-IG-001, 

which are quotes from Revision 1 (OCAS 2002) versus Revision 3 (OCAS 2007) of the OCASIG-001 and some of which is no longer in OCAS-IG-001. “If individual energy distribution 

information is not available for two-element film badges, the open window dose should be used 

as a claimant friendly estimate of the 30 to 250 keV dose.” However, the comment didn’t quote 

some statements that were in between the quoted statements. One such statement was, “When 

monitoring data do not indicate the relative energy distribution, the distribution can be estimated 

based upon either the site radionuclide inventory or the relative energy distribution which can be 

estimated for most facilities based upon a review of historical operations,” which is still a 

statement in Revision 3 of OCAS-IG-001 (OCAS 2007) and is what was used for the INL TBD. 

The photon energy distribution of 25% 30–250 keV photons and 75% >250 keV photons in the 

INL TBD is claimant-favorable for the majority of exposure scenarios at the INL, based on the 

radioactivity in The Materials Test Reactor’s (MTR’s) spent reactor and the waste stream for the 

ICPP (see attached file). MicroShield calculations indicate that 88.9% of the photons in the 

spent MTR reactor fuel have an energy greater than 300 keV, and that percentage increases to 

98.8% for the ICPP’s waste stream that contains all of the fission products and transuranics. It 

should also be noted that these energy distributions do not account for the effect from any 

minimal shielding that would have been in place for most exposure scenarios and would have 

further reduced the amount of low-energy photons that the workers were being exposed to. 

In addition, the potential under-reporting of the penetrating photon doses would have only been 

able to have occurred when the reported non-penetrating dose was significantly greater than the 

dosimeter’s limit of detection, since the OW reading for the dosimeter would have been capable 

of detecting the low-energy photons and would have significantly over-responded to them. 

Therefore, this issue is only potentially applicable to the instances when a significant nonpenetrating dose is reported for a specific dosimeter. Because reviews of the dosimetry data for 

a significant number of cases indicate that the majority of non-penetrating doses reported for 

most INL workers were either zero or insignificant, NIOSH expects that the number of 

potentially under-reported penetrating photon doses would have been very small. If SC&A has 

encountered any specific examples where an INL worker’s penetrating dose was likely underreported, NIOSH would be willing to investigate this potential issue further. 

It should also be noted in Comment 18 that the reference to the correction factor used at the SRS 

(i.e., the factor of 1.119) is not applicable to other sites. 
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WG Action Items: 

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue. 

SC&A Reassessment: SC&A’s review of Revision 3 indicates that NIOSH did not make any 

changes to TKBS-0007-5 as a result of this observation. NIOSH provided additional information 

in their issue response. However, SC&A suggests that NIOSH incorporate the information 

provided above in the response into TKBS-0007-5 during its next revision, so that future 

reviewers will have access to it.

SC&A believes that the NIOSH response has addressed this issue, considers this issue to be 

resolved, and recommends that the WG close this issue. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.19 ISSUE 19: ANGULAR DEPENDENCE CORRECTION FACTOR FOR GAMMA 

DOSE 

ORAUT-TKBS-0007-6, Occupational External Dose, TBD Sect. 5.1.4.1.4, SC&A p. 99 

Issue: NIOSH should provide angular dependence (anatomic geometry) correction factors for 

external gamma doses, particularly for low-photon energies, where the angular dependence of 

the sensitivity of the dosimeter is most pronounced. These correction factors are used to account 

for, for example, the bias introduced by a dosimeter worn at the neck level and the higher doses 

received by tissues/organs below the waist. 

NIOSH Response: NIOSH DCAS-TIB-010 (DCAS 2011) provides angular correction factors 

for such exposure geometries that are usable for all sites. Also, NIOSH OCAS-IG-001 External 

Dose Reconstruction Guideline, Revision 3 (OCAS 2007), provides DCFs based on incident 

photon geometry. Therefore, no site-specific factors are needed. In addition, clamant-favorable 

AP geometry is typically assumed. 

WG Action Items: 

 NIOSH: Revise its response to correct a misstatement [clarification: that DCAS-TIB010 contains angular correction factors in addition to geometric correction factors]. 

--------------------------------------------------------------------------- 

Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH indicates that its response is available for WG 

and SC&A review.

SC&A Further Review: Communication (via email) with NIOSH’s Pete Darnell on January 

29, 2014, revealed that NIOSH is currently revisiting the issue and has not yet issued a response. 

SC&A will review that response when it is available; SC&A recommends that the issue remain 

open.
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3.20 ISSUE 20: RESTATING BETA DOSE 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.5, SC&A p. 99 

Issue: It is not claimant favorable to state that the entire dose measured in the open window is 

due to the beta dose. 

NIOSH Response: Open window beta dose is discussed in OCAS-IG-001 (OCAS 2007). 

Please provide a basis for these opinions—where has SC&A found data supporting <30 keV 

photons? 

WG Action Items: 

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue (related to Issues 17 and 18). 

SC&A Reassessment: SC&A’s review of Revision 3 shows that NIOSH has revised 

Section 6.5.3 to address this issue. SC&A has reviewed the revised section, believes that it 

addresses this issue, considers it resolved, and recommends that the WG close this issue.

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.21 ISSUE 21: PHOTON SPECTRUM SPLIT 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.6, SC&A p. 99 

Issue: NIOSH should provide guidance assigning dose values for the 30 keV<E<250 keV and 

E>250 keV regions. 

NIOSH Response: Photon energy ranges are based upon the predominant radionuclides found 

in the workplace. Scenarios like those discussed in the SC&A report would be reconstructed on 

a case-by-case basis. Please provide a basis for these statements and for the SC&A opinion that 

a 50/50 energy range is more appropriate. 

WG Action Items: 

 SC&A: Explain why it believes a 50:50 split between low- and high-energy photon 

energy groups is preferable to the 25:75 split assumed by NIOSH. 

SC&A Reassessment: Not at this time.

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats its statement under WG Action Items: 

SC&A above. 

SC&A Further Review: When a penetrating dose is recorded on a film badge, the total dose is 

split into one to three different energy ranges: <30 keV for the x-rays emitted by transuranics, 3–

250 keV for x-rays and many radionuclides, and >250 keV for the higher energy photon 

emitters. NIOSH uses its judgment regarding how to make this split. This split is made because 

the risk conversion factor (risk per rad) is energy dependent. We judge the reasonableness of 

this split on a case-by-case basis. 

For INL, there is a very wide range of radionuclides, so we concur with NIOSH’s response and 

recommend that the WG close this issue.
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3.22 ISSUE 22: IMMERSION DOSE 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.7, SC&A p. 100 

Issue: The dose recorded on a dosimeter due to a semi-infinite cloud irradiation would be 

approximately half of the actual dose received. NIOSH should, therefore, consider a weighting 

factor of 2 for immersion dose. 

NIOSH Response: NIOSH does not use personnel whole-body or extremity dosimeter data to 

estimate internal doses. The comment listed in this matrix does not appear to coincide with the 

discussion in the SC&A review report. This comment may be an error, because there is no 

mention of semi-infinite cloud exposures in the TBD. 

WG Action Items: None. The WG accepted NIOSH’s response and closed the issue at the June 

21, 2011, WG meeting. 

CLOSED
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3.23 ISSUE 23: HIGH-RISK JOBS (BETA/GAMMA EXPOSURE)

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.8, SC&A p. 100 

Issue: Site experts interviewed by SC&A classified INL as an “acute dose” site, with a 

significant number of facilities, operations, experiments, and occurrences providing the 

possibility of personnel receiving dangerous levels of radiation. NIOSH did not evaluate 

comprehensively the facility and field data to identify and separate out the high-risk or high-dose 

jobs for worker external exposures. This information is essential for dose reconstructors to fill in 

the data gap when dose records in a claimant’s file are not complete.

NIOSH Response: Please provide a basis for these statements regarding NIOSH evaluation of 

facility and field data. The referenced section of the SC&A report does not appear to relate to 

the comment provided. The report discusses beta dose and hot particles. NIOSH would only 

perform dose reconstruction for hot particles or unreported skin contamination that were 

documented. There is no reasonable way to estimate hot particle doses without monitoring data. 

WG Action Items: 

 NIOSH/SC&A: Merge with Issue 9 and see also Issues 5 and 34. 

SC&A Reassessment: As the WG noted, this issue is similar to Issue 5 (internal exposure), 

Issue 9 (skin contamination), and Issue 34 (neutron exposure). The approach outlined in the 

response to Issue 5 could also be applied for high-risk gamma exposure jobs, i.e., wording could 

be provided in TKBS-0007-6 to instruct the dose reconstructor to modify the dose reconstruction 

and/or perform additional research if a claimant expresses a specific concern (either verbally or 

in writing) that he/she was inadequately monitored for gamma exposure, and the dose 

reconstructor is able to confirm that concern.

SC&A recommends that the WG keep this issue open for further discussion. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH is working on a white paper to address this 

issue and comments that this issue should be merged with Issue 9, Skin and Facial 

Contamination. NIOSH also refers to Issue 34, High-Risk Jobs (Neutron Exposure). 

SC&A Further Review: SC&A is waiting for NIOSH’s Hot Particle Issue white paper before it 

will consider this issue further. Hence, SC&A recommends that this issue remain Open.
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3.24 ISSUE 24: EXTREMITY DOSE 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.9, SC&A p. 100 

Issue: NIOSH should evaluate the potential for missed extremity dose for workers working in 

facilities where highly contaminated equipment, piping, instruments, valves, and systems 

resulted in exposures in confined spaces to hands. 

NIOSH Response: INL assigned extremity dosimetry when needed. For other workers, NIOSH 

will address this on a case-by-case basis—we routinely use multiplication factors to account for 

geometry differences for cancer on extremities when the EE was a “hands-on” worker.

WG Action Items: 

 NIOSH/SC&A: Look at interviews appearing in SC&A’s site profile review for relevant 

anecdotal discussions on extremity exposures. NIOSH will report how many INL/ANLW claimants have extremity cancers. 

SC&A Reassessment: Discussion of extremity dose is provided in Attachment C, pages 190 to 

191. Specific exposures to the hands and face are discussed on pages 171 and 206. 

In the 1980s, the Specific Manufacturing Capability (SMC) facility was built in 

the TAN area. Operations at the SMC facility, which involved the machining of 

depleted uranium (DU), are considered classified. Chip fires occurred due to the 

pyrophoric nature of the uranium. An incident occurred when the elevated 

temperature resulting from a worker drilling a can containing DU reacted with 

the moisture inside the can to produce hydrogen gas. The hydrogen was ignited 

by the sparks, and flames shot up to the ceiling. This worker got burned all over 

his face and hands. (SC&A 2006, p. 171)

In the ICPP Calciner Facility, workers had to use friction saws to cut off valves 

that were contaminated with high levels of Cs-137, Sr-90/Y, and U-235. When 

they were drilling into the valves, sometimes filters were burned through, spilling 

contaminants, which would get all over their hands or faces. This often resulted 

in skin contamination. The airborne radioactivity level was also very high and 

may have been responsible for significant uptakes of radionuclides. 

(SC&A 2006, p. 206)

SC&A cannot make a recommendation to the WG regarding this observation until we have 

reviewed the NIOSH response to their portion of the action item. 

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NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the SC&A action item shown above, 

“Look at interviews appearing in SC&A’s site profile review for relevant anecdotal discussions 

on extremity exposures,” and also states that there are “no new data to report (NIOSH will report 
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how many INL/ANL-W claimants have extremity cancers. NIOSH response expected late 

2013).” 

SC&A Further Review: SC&A is waiting for the NIOSH response before it will consider this 

issue further. Hence, SC&A recommends that this issue remain Open.
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3.25 ISSUE 25: DISCREPANCIES BETWEEN PIC AND FILM READING 

ORAUT-TKBS-0007-6, Occupational External Dose, TBD Sect. 5.1.4.1.10, p. 100 

Issue: NIOSH should compare PIC versus film badge data (i.e., shallow and deep), and ensure 

that all the dose has been captured by the film badge. It is important to note that some PICs were 

worn for only the length of the job, so the discrepancy between readings of the two-dosimeter 

systems cannot be explained by drifting. 

Expanded: Many difficulties in comparing PIC readings and film badge results make 

agreement within a factor of two the best that can be expected. 

NIOSH Response: The PIC is not a legal record and is a lower-preference for reconstructing 

dose. The PIC typically over-responded to site photon energies and was sensitive to shock. 

They are designed for use in the field to get a real-time exposure reading until the dosimeter 

could be read at a later time. 

WG Action Items: None. The WG accepted NIOSH’s response and closed the issue at the June 

21, 2011, WG meeting. 

CLOSED
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3.26 ISSUE 26: MINIMUM DETECTION LIMIT 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.11, SC&A p. 101 

Issue: NIOSH should re-evaluate the approach in determining the MDL of the dosimetry system 

by taking into account the system uncertainties. 

Issue Expanded: The selection of 10 mrem as the MDL [minimum detection limit] for highenergy gamma is questionable. Even for modern densitometers and film, it is a challenge to 

achieve this level, as a single density “click” can correspond to greater than 10 mrem for highenergy gamma radiation; this is not a problem, however, for intermediate and low-energy x-rays. 

Rather, one click of the densitometry system may correspond to 15 or 20 mrem for 660 keV or 

1.2 MeV gammas, for example. If the claim is made that 10 mrem is a valid choice for the 

MDL, then supporting materials should be provided, such as film dose-to-density curves and 

densitometer calibration data. Other sites [e.g., Savannah River Site (SRS)] have adopted 

40 mrem as the high-energy gamma MDL for early film. 

NIOSH Response: This observation is similar to finding 3 listed below (Issue 27). The 

response to the finding also satisfies this observation. 

WG Action Items: 

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue. 

SC&A Reassessment: SC&A believes that NIOSH has adequately addressed this issue and 

recommends that the WG close it. 

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NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.27 ISSUE 27: MINIMUM REPORTING LEVEL (BETA/GAMMA) 

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.1.12, SC&A p. 103 

Issue: NIOSH does not provide adequate information supporting the use of chosen detection 

threshold levels to represent the minimum dose reporting level (MRL) values for gamma film 

badges and TLDs. The use of MRL/2 as the missed external dose for dose reconstruction per 

OCAS-IG-001 (OCAS 2002) is not claimant favorable for claims where the probability of 

causation value is close to 50%. In addition, NIOSH should re-evaluate the MRL values used 

and provide more supportable default values. 

NIOSH Response: The MRLs used in the INL TBD are based on peer-reviewed and published, 

scientific documents as referenced in Table 6-15 (see footnote b in Rev. 2 of the TBD). 

Comments on OCAS-IG-001 are usually more programmatic in nature and not part of a specific 

site. In this case, the reviewer’s comment is not accurate. MRL/2 is assigned a lognormal 

distribution as required in OCAS-IG-001 and discussion of uncertainty may be found therein. 

Additionally, when the PoC is between 45 and 52%, the IREP sample size increases from 2,000 

to 10,000, the random seed (which is normally 99) is selected by chance, and IREP is run 30 

times at the 99th percentile versus the 50th percentile. These methods provide a more claimantfavorable dose reconstruction and ensure that the PoC is not underestimated. 

WG Action Items: 

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue. 

SC&A Reassessment: In order to confirm the MRLs, SC&A requests that NIOSH identify 

which MRLs were obtained from which documents, and since some of these documents are large 

(over 250 pages), please identify the page(s) from which they were taken. If instead of being 

taken directly from the reference documents, the MRLs were derived from information provided 

in the documents, please indicate the source (and page) of the information and the methodology 

used to calculate the MRLs. SC&A has also reviewed the above NIOSH response as regarding 

OCAS-IG-001, and we concur.

SC&A recommends to the WG that this observation remain open until we are able to confirm the 

MRLs. 

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Rev. 1 Status and Review Information 

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the SC&A action item shown above: 

“Review applicable portions of the current version of the External Exposure TBD and reassess 

the issue.”
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SC&A Further Review: SC&A reviewed Rev. 3 of the site profile to check on how MDLs are 

addressed. Section 6.3 provides useful background information and examples of the early 

personnel dosimetry program, indicating an MDL of 30 mR as the MDL for penetrating photon 

dose for the 1958 time frame for DuPont 552 film (page 12). This is not an unreasonable MDL 

for that time period, based on our experience with MDLs for other sites. However, 

Section 6.3.2.1 (page 18) indicates an MDL of 10 mR per change-out for DuPont 558 film for 

the 1958 time frame. This is an unusually low MDL for that time frame. Section 6.3 provides 

considerable discussion of the film badges used at the time and their calibration methods, along 

with recommended correction factors. 

Section 6.3.2.3 describes the LiF badges used beginning in late 1966 and goes on to describe the 

evolution of the different types of TLDs used at the facility over time, providing LODs 15 mrem 

beta and gamma from January to July 1986 (Gesell 1986), 10 mrem gamma and 30 mrem beta 

from July 1986 to September 1989, and 15 mrem for gamma and 30 mrem for beta until 1993 

(Perry et al. 1993), when it returned to 10 mrem gamma. 

Section 6.3.2.7 describes the NTA film used for neutron dosimetry in the 1950s with an LOD of 

14 mrem (on page 21) for neutron energies above 500 to 800 keV, and 20 mrem on page 22, 

followed by discussions of albedo dosimetry and associated correction factors. 

Section 6.3.4.2 presents a detailed discussion of non-penetrating radiation at the facility 

(>15 keV electrons and <30 keV photons and x-rays), along with correction factors for energy 

ranges not detected by the dosimeters. This is followed by extensive discussion of neutron 

sources and energy distribution at many of the different INL facilities, including adjustment 

factors and weighting factors for different energy groups (WR).

Table 6-15 provides recommended LODs of 30 or 10 mrem for photons (depending on time 

period and location), 30 mrem for electrons in general, but 15 mrem for LiF TLDs. Table 6-16 

presents neutron LODs ranging from 14 to 20, depending on time period. These values seem 

quite low compared to the LODs adopted in other site profiles. See the following table. 

Facility Dosimeter Type and Dates LODs Source

Hanford Film dosimeters 1950s–1971

TLDs 1970s–present

30–40 mrem

10–20 mrem

ORAUT-TKBS-0006-6

Savannah River Film 1952–1970

TLD 1970s–present

40 mrem

5–15 mrem

ORAUT-TKBS-0003

Rocky Flats 1951–1968 40mR

1968–1982 20mR

1980s–present

40 mR

20 mR

5–20 mrem

ORAUT-TKBS-0011-6

Fernald 1950s–1980s

1995–present

30–40 mrem

20 mrem

ORAUT-TKBS-0017-6

ORNL 1944–1974 

1975–present

30 mrem

10 mrem

ORAUT-TKBS-0012-6

LANL Film 1945–1979 

TLD 1980–present

40 mrem

10 mrem

ORAUT-TKBS-0010-6

LLNL Film 1952–1968

TLD 1969–present

30 mrem

10–20 mrem

ORAUT-TKBS-0035-6
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We believe that some explanation is needed regarding why INL LODs are considerably lower for 

photon external radiation compared to those reported in other site profiles. Hence, SC&A 

recommends that this issue remain open.
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3.28 ISSUE 28: MINIMUM REPORTING LEVEL (NEUTRON)

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.1, SC&A p. 108

Issue: NIOSH’s approach for determining the MRL values for NTA emulsion film is not 

thorough or supported. For example, NIOSH uses 10 neutron readings in 1 data sheet from 

March 1958 to determine the MRL values for the period between 1951 and 1957, and 6 neutron 

readings to represent all neutron measurements between 1959 and 1976. Furthermore, the use of 

MRL/2 as the missed external dose for dose reconstruction per OCAS-IG-001 is not claimant 

favorable for claims where the probability of causation value is close to 50%. In addition, 

NIOSH’s MRL values of 14 mrem and 20 mrem appear low and are inconsistent with generic 

values given for NTA dosimeters, as well as values cited by other DOE facilities with similar 

neutron source terms and detectors. NIOSH should re-evaluate the MRL values used and 

provide more supportable default values.

NIOSH Response: Comments on OCAS-IG-001 are usually more programmatic in nature and 

not part of a specific site. In this case, the reviewer’s comment is not accurate. MRL/2 is 

assigned a lognormal distribution as required in OCAS-IG-001 and discussion of uncertainty 

may be found therein. The MRLs used in the INL TBD are based on peer-reviewed and 

published, scientific documents as referenced on page 22. The MRL of 14 is cited on page 6 of 

Cipperly 1958. Additionally, when the PoC is between 45 and 52%, the IREP sample size 

increases from 2,000 to 10,000, the random seed (which is normally 99) is selected by chance, 

and IREP is run 30 times at the 99th percentile versus the 50th percentile. These methods provide 

a more claimant-favorable dose reconstruction and ensures that the PoC is not underestimated.

WG Action Items:

 NIOSH: Revisit its response about detection limits.

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: SC&A has also reviewed the above NIOSH response regarding OCASIG-001, and we concur. The SC&A review of Revision 3 found that attribution [41] needs to be 

changed to indicate that 14 mrem is from Cipperly. Finally, the NIOSH response above 

provided no rationale for the 28 or 15 mrem missed neutron dose given in Table 6-16.

SC&A cannot make a recommendation to the WG regarding this issue until we have reviewed 

the NIOSH response to their portion of the action item.

Note: (Oct. 2013 update) NIOSH is working on a white paper to address NTA film dosimeter 

issues: Investigation of the NTA Film Dosimeter Limits of Detection Being Used for INL Dose 

Reconstructions. 
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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH notes that it is still working on a white paper 

to address this issue.

SC&A Further Review: SC&A is waiting for the NIOSH white paper. Hence, SC&A 

recommends that this issue remain Open.
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3.29 ISSUE 29: FAILURE TO PROPERLY ADDRESS NEUTRON EXPOSURES

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.2, SC&A p. 109

Issue: INL had a total of 52 reactors, most of which were experimental/prototype in design, 

which typically operated with high-power densities and with minimum shielding and neutron 

moderation. It is unjustified to presume that there are no missed neutron doses. In addition, 

there are deficiencies associated with neutron calibrations. Due to the use of the PoBe source for 

neutron calibration, dosimeters would significantly under-measure neutron doses from sources 

with lower-energy spectra. NIOSH should re-evaluate the entire approach in the TBD to account 

for potential missed neutron doses.

Issue Expanded: The method presented in the TBD of determining who needs to be assigned a 

missed neutron dose is circular: Section 6.5.4 states, “If no neutron dose was assigned to the 

worker or coworkers for several months, the dose reconstructor should assume that the person 

was not exposed to neutrons.” Clearly this does not allow for individual workers having 

temporary or varying assignments. Also, if the program failed to correctly identify that they 

should have been monitored, the record will show no assigned neutron dose.

In addition, the TBD makes the assumption that high Z materials, such as iron and lead, were 

never used (e.g., for shield penetrations) in place of hydrogenous materials, such as water and 

concrete. However, no attempt is made to validate or qualify this assumption.

ORAUT-OTIB-0051, Effect of Threshold Energy and Angular Response of NTA Film on Missed 

Neutron Dose at the Oak Ridge Y-12 Facility (ORAUT 2006), was issued after the 2004 site 

profile and has a bearing on neutron dosimetry issues; hence, it should be considered in this 

TBD.

NIOSH Response: The inappropriate instructions to discount an INL worker's missed neutron 

doses has been eliminated from the Missed Neutron Dose Section of the external dosimetry 

TBD. Because it was impossible to determine who a worker's coworkers were from the redacted 

dosimetry records, the guidance in Revision 02 of that TBD was not being used to eliminate 

missed neutron doses. However, it should be noted that ORAUT-OTIB-0023 (ORAUT 2008b) 

is still considered an appropriate basis for eliminating unreasonably high missed neutron doses 

for some INL claims. In addition, neutron dosimeters at the INL were only assigned and read 

when there was a potential for exposure. Given that most of the reported neutron dosimeter 

results were reported as zero, the INL's process to determine who had the potential to receive 

neutron exposures appears to have been appropriate and adequate.

The guidance provided in Revision 03 of the external TBD now requires missed neutron doses to 

be assessed for every worker using the reported neutron dosimeter results, unless the missed 

neutron doses are unreasonably high per the guidance in ORAUT-OTIB-0023 (ORAUT 2008b). 

NIOSH is not clear what SC&A's issue is regarding the potential under-measurement of neutron 

doses to lower-energy neutrons, since Revision 00 through Revision 03 of the INL's external 

dosimetry TBD have included facility-specific adjustments to the reported neutron doses to 
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account for the dosimeters' poor energy response to lower-energy neutrons. The NTA film 

corrections for energy response in the INL TBD are comparable to the energy response 

corrections in ORAUT-OTIB-0051 (ORAUT 2006), which range from 1.0 to 2.2. Because the 

need to apply a correction to NTA film results to account for angular response is being discussed 

as an overarching issue, no angular response corrections were added in the latest revision of this 

TBD. Also, the assumption of AP geometry would negate the need to adjust for angular 

response.

WG Actions:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: SC&A has reviewed and agrees with the NIOSH response provided 

above. Also, SC&A has reviewed Revision 3 and agrees that the TKBS-0007-6 (Table 6-5) 

neutron correction factors are comparable to the OTIB-0051 (Table 8-1) factors. Finally, SC&A 

has reviewed OTIB-0023 under the direction of the Procedures Review Subcommittee, and 

identified eight findings. All eight of the OTIB-0023 findings have been discussed among the 

Procedures Review Subcommittee, NIOSH, and SC&A; agreement was reached, and all are 

closed.

SC&A considers this issue to be resolved, and recommends that the WG close it.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue.

SC&A Further Review: None
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3.30 ISSUE 30: NEUTRON CALIBRATION DEFICIENCIES

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.3, SC&A p. 110

Issue: Due to the use of the PoBe source for neutron calibration, dosimeters would significantly 

under-measure neutron doses from sources with lower energy spectra. NIOSH should reevaluate the approach in the TBD to account for potential missed neutron doses.

NIOSH Response: Section 6.3.3.2 indicates that the recorded dose is 11% high based on this 

calibration.

WG Action Items:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: As SC&A understands Section 6.3.3.2, the 11% refers to the difference 

between the AmBe dose conversion factor used by INL (4.17 × 10-8rem-cm

2

/n) and the AmBe 

dose conversion factor recommended by the IAEA (3.8 × 10-8rem-cm

2

/n). Both dose conversion 

factors are specific to the AmBe energy spectrum. However, the issue is concerned with whether 

neutron sources with energy spectra lower than the AmBe spectra are significantly underrecorded or missed entirely.

Since the NIOSH response does not appear to address the issue, SC&A recommends that the WG 

keep this issue open for further discussion.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the WG Action Items: SC&A entry 

shown above. 

SC&A Further Review: SC&A revisited Section 6.3.3.2, Neutron Calibration, of the current 

External Dose TBD (ORAUT 2011b). NIOSH notes that “the initial NTA neutron badges were 

calibrated using a PoBe neutron source...[and that] in 1982, an AmBe source was used.” SC&A 

further investigated the issue that it had raised previously about possibly significant differences 

in the neutron source energy spectra from the two neutron sources.

In both cases, neutrons are produced via the (α,n) reaction in Be, following decay of the parent 

radioisotope by α-particle emission:

T1/2 = 432.6 y, Eα = 5.486 MeV (85%), 5.443 MeV (13%) (BNL 2014)

T1/2 = 138 d y, Eα = 5.304 MeV (100%) (BNL 2014)

(Q = 5.71 MeV), 
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where the resulting broad neutron energy spectra for different parent nuclide decays and the 

average neutron energies emitted (4–5 MeV range) are quite similar and somewhat dependent on 

Eα (Knoll 2000).

Since the neutron energy spectra resulting from the AmBe and PoBe sources are quite similar, 

SC&A withdraws its previous comments and recommends that the WG close this issue.
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3.31 ISSUE 31: COMPLETENESS AND QUALITY OF INL NEUTRON DOSIMETRY

AND RECORD KEEPING PROGRAMS

ORAUT-TKBS-0007-6, Occupational External Dose, TBD Sect. 5.1.4.2.4, SC&A p. 110

Issue: The identification and determination of missed neutron dose for workers are heavily 

influenced by this assumption of confidence, but SC&A found this premise to be unsupported 

after examining several critical DOE-HQ Tiger Team and DNFSB site audit reports. In addition, 

many site experts interviewed by SC&A indicated that there were significant deficiencies and 

inconsistencies in radiation work practices throughout the operating history of the INL facilities. 

These observations jeopardize the validity of the TBD approaches in reconstructing missed 

worker neutron doses.

NIOSH Response: Please provide the reports of “significant deficiencies and inconsistencies in 

radiation work practices” and provide how the NIOSH-derived missed dose calculations are 

subject to the results of the Tiger Team report.

WG Action Items:

 NIOSH: Review TIGER Team reports for applicable information [per discussions 

during June 21, 2011, WG meeting].

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH notes that this issue is related to Issue 16: 

Completeness and Quality of INL Beta/Gamma Dosimetry and Record Keeping Programs. 

SC&A Further Review: SC&A reexamined the INL Tiger Team report (DOE 1991), the 

current INL site profile External Dose TBD (ORAUT 2011b), the original External Dose TBD 

(ORAUT 2004a), the original SC&A comment and background discussion, as well as the site 

expert interview summary, in its 2006 site profile review (SC&A 2006) pertaining to Issue 31, 

and, additionally, the Defense Nuclear Facilities Safety Board (DNFSB) reports (DNFSB 1994a, 

1994b, 1995); the latter were found not germane to this issue and are not discussed further. 

The INL Tiger Team assessment was conducted as part of the overall DOE Tiger Team 

Independent Assessment Program across the DOE facilities complex, which begun in the late 

1980s. The INL assessment was accomplished during the summer of 1991 and the 

comprehensive, multi-volume report (DOE 1991) was published in August 1991. The evaluation 

focused on several areas, notably environment, safety and health, management, and organization. 

Much of the evaluation and many of the findings are programmatic and procedural, such as 

organizational structure (multiple governmental and private organizations were involved 

simultaneously at INL), direction, and coordination, and compliance with federal, state, and local 

regulations and procedures. The assessment is quite critical overall, particularly with respect to 

management. With regard to radiation protection, the Executive Summary notes:
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The radiation protection program at EG&G Idaho [i.e., INL] was found to be 

particularly deficient. The nuclear accident dosimetry program is not in 

compliance with performance requirements for fixed and personnel nuclear 

accident dosimeters. The personnel dosimeter program is not in compliance with 

applicable DOE Orders and there is no program to identify and resolve problems 

related to the response of radiation protection instrumentation.

The Tiger Team report also mentions in several places that not everyone who should have had 

personal monitoring actually had it.

Section 5.1.4.1.1 of the 2006 SC&A site profile review (SC&A 2006), which assessed Rev. 0 of 

the INL TBD (ORAUT 2004a), cites several issues noted in the Tiger Team report, as well as 

site interviews SC&A had conducted. In particular, in reference to missed dose:

(3) During the site expert interviews, past and current workers at INL facilities 

provided first-hand information about potential missed dose scenarios and 

deficiencies in personnel protection programs and dosimetry record keeping. 

Even though there is a sentiment that the INL radiological protection programs 

and the advancement of equipment and techniques have made dramatic 

improvements over the past two decades, the missed dose problems due to these 

deficiencies in the early days must be addressed in a fair and reasonable manner. 

SC&A reviewed the current, Rev. 3, INL External Dose TBD (ORAUT 2011b), as well as the 

Rev. 0 External Dose TBD (2004a), and found that the issue is addressed in Section 6.5 of the 

former, Missed Dose, with subsections: dosimeter not worn, missed photon dose, missed 

electron dose, and missed neutron dose. For the situation of a worker claiming exposure to 

radiation while not wearing a dosimeter (Section 6.5.1, dosimeter not worn), the TBD refers the 

dose reconstructor to ORAUT-OTIB-0020, Use of Coworker Dosimetry Data for External Dose 

Assignment (ORAUT 2011c). The OTIB gives generic guidance, but NIOSH has indicated that 

it is currently preparing an INL-specific coworker model, which SC&A will review when it is 

available. The other subsections of Section 6.5 provide guidance for other missed dose 

situations. 

SC&A recommends that the WG keep this issue open pending receipt and review of the INLspecific coworker model under development by NIOSH. (See Issue 16 for beta/gamma).
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3.32 ISSUE 32: UNCERTAINTY ESTIMATION FOR NEUTRON DOSES

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.5, SC&A p. 110

Issue: NIOSH should explain how the Facility Neutron Correction Factors (FNCFs) were 

obtained and provide instruction to dose reconstructors on how to apply them.

NIOSH Response: The latest revision to the TBD appears to adequately explain the FNCFs. 

The text indicates that this is a correction that INL applied to the dosimeter results to generate

the reported dose (pg. 22 of TBD). Also, several references are cited in the TBD text to indicate 

how these FNCFs were obtained. The references also provide additional information on the 

methodology used.

WG Action Items:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: Since it appears that NIOSH did not develop the FNCFs, but rather 

obtained them from various references (primarily Cusimano 1981), SC&A agrees that providing 

only a summary of how they are developed is appropriate [i.e., “A FNCF ... can be generated 

from the ratio of the dose equivalent measured with a 9-in.-diameter Eberline PNR-4 and the 

corresponding signal (in millirem but not dose equivalent) with the detector in the 3-in.-diameter 

PNR-4 insert” (page 22)]. SC&A considers that the NIOSH response addresses the first portion 

of the issue.

In a teleconference between SC&A and NIOSH held June 29, 2005 (SC&A 2006, Attachment 1, 

pp. 150 and 151), SC&A stated, “It is not clear from the accompanying text whether the data 

recorded in the workers’ records were already adjusted based on the FNCFs or whether the dose 

reconstructor should make the adjustments.” NIOSH replied, “The adjustments have been made 

in the recorded data. NIOSH stated that it would clarify this point in a future revision of the 

TBD.” SC&A’s review could not confirm that the clarification had been provided in Revision 3 

of TBKS-0007-6.

Because the clarification on the use of the FNCFs has not been provided in TBKS-0007-6, 

Revision 3, SC&A recommends that the WG keep this issue open for further discussion.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the WG Action Items: SC&A item 

shown above.

SC&A Further Review: SC&A reviewed the current, Rev. 3, External Dose TBD (ORAUT 

2011b) and notes that Facility Neutron Correction Factors (FNCFs) appear in Section 6.3.2.8, 

Neutron Albedo Dosimetry. Table 6-5 tabulates the FNCFs for different INL facilities, taken 

from Cusimano 1981. The accompanying text states: “This correction was applied to generate 
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the reported neutron dose.” Hence, SC&A believes that all the points in this issue have been 

adequately addressed, and recommends to the WG that it close this issue.
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3.33 ISSUE 33: NEUTRON ORGAN DOSE

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.6, SC&A p. 110

Issue: NIOSH should provide neutron spectrum information and guidance for organ dose 

reconstruction for workers at ZPPR and TREAT.

NIOSH Response: Guidance provided in Section 6.4, spectrum data in Table 6-14 of 

Revision 03.

WG Action Items:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: Upon reviewing Revision 3, SC&A agrees with NIOSH that the 

requested information has been provided in Section 6.4. SC&A considers this issue to be 

resolved, and recommends that the WG close this issue.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.34 ISSUE 34: HIGH-RISK JOBS (NEUTRON EXPOSURE)

ORAUT-TKBS-00007-6, Occupational External Dose, Sect. 5.1.4.2.7, SC&A p. 111

Issue: NIOSH did not evaluate comprehensively the facility and field data to identify and 

separate out the high-risk or high-dose jobs for worker neutron exposures. This information is 

essential for dose reconstructors to fill in the data gap when dose records in a claimant’s file are 

not complete.

NIOSH Response: Please provide a basis for these statements regarding NIOSH’s evaluation of 

facility and field data. The report discusses that there were potential higher dose neutron 

activities conducted, but no details are provided. NIOSH would only perform dose 

reconstruction for such activities if they were documented. These types of reconstructions would 

be done on a case-by-case basis.

WG Action Items:

 NIOSH/SC&A: Look at interviews appearing in SC&A’s site profile review and 

elsewhere for relevant anecdotal discussions on neutron exposures. 

SC&A Reassessment: SC&A reviewed the summary of site expert interviews of current and 

former workers contained in SC&A 2006, Attachment 3. While there is additional discussion on 

neutron sources and neutron monitoring, no specific incidents of high neutron exposures were 

found in the interview summary. However, the following excerpt on the potential for missed 

neutron exposures is provided.

Some site experts believe the neutron monitoring program at INL has been 

inconsistent. For example, although the work has not changed, monitoring for 

neutron[s] changed over the course of time. Workers noted that those outside the 

radiation boundary at RWMC do not participate in neutron monitoring, while 

those inside do. There are some disagreements between RadCon and other site 

experts as to whether neutron dosimetry was consistently used at ATR and ETR 

throughout the years. There was also some inconsistency between monitoring of 

permanent workers versus vendors, such as equipment handlers and excavators at 

RWMC. There was no routine neutron monitoring of some hands-on maintenance 

workers in ICPP.

...

There was a potential for missed neutron dose in the early days, due to 

incomplete monitoring of the exposed population. For example, many laboratory 

analysts and chemists did not have neutron dosimeters, as they were not aware 

that there was an issue with neutrons. This lack of neutron monitoring could be 

verified by evaluating ambient neutron sources and cross comparing this 

information with dosimetry processing data. (SC&A 2006, Attachment 3, p. 189)

As the WG noted, this issue is similar to Issue 5 (Internal Exposure), Issue 9 (Skin 

Contamination), and Issue 23 (Gamma Exposure). The approach outlined in the response to 
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Issue 5 could also be applied for high-risk neutron exposure jobs; i.e., wording could be provided 

in TBKS-0007-6 to instruct the dose reconstructor to modify the dose reconstruction and/or 

perform additional research if a claimant expresses a specific concern (either verbally or in 

writing) that he/she was inadequately monitored for neutron exposure, and the dose reconstructor 

is able to confirm that concern.

SC&A recommends that the WG keep this issue open for further discussion.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH indicates that its response is available for WG 

and SC&A review.

SC&A Further Review: Private communication (via email) with NIOSH’s Pete Darnell on 

January 29, 2014, revealed that NIOSH is currently revisiting the issue and has not yet issued a 

response. SC&A will review that response when it is available; hence, the issue remains open.
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3.35 ISSUE 35: MULTIPLYING FACTORS FOR MISSED NEUTRON DOSE

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 5.1.4.2.8, SC&A p. 111

Issue: NIOSH should provide data to support the two multiplying factors (1.25 and 2) and the 

fixed missed neutron dose default value of 50 mrem.

Issue Expanded: See ORAUT-OTIB-0051 and Issue No. 29.

NIOSH Response: These values are based on weighting neutron spectra with dose conversion 

factors to determine the fraction of the dose below 0.8 MeV as referenced in footnote 37 of 

Revision 02. It should also be noted that the upper-bound for the factor of 2 ± 0.3 is being used 

(i.e., a factor of 2.3).

In regards to the 50 mrem of neutron dose, the TBD was not recommending that the dose 

reconstructors assign 50 mrem of unmonitored neutron doses to the affected workers. The TBD 

was merely describing an instance where unmonitored neutron doses were received by INL 

workers. The earlier versions of the external TBD neglected to indicate that the INL has already 

assigned unmonitored neutron doses for those workers based on the area dosimeter results, such 

that the dose reconstructors do not need to assign unmonitored neutron doses to the affected 

TAN workers. An additional clarifying statement was since added to Revision 02 of the external 

TBD that still subsists in Revision 03.

WG Action Items:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: SC&A notes that footnote 37 of Revision 02 is Attribution [46] of 

Revision 3. Attribution [46] states that the two multiplying factors “are based on weighting 

neutron spectra with dose conversion factors to determine the fraction of the dose below 

0.8 MeV,” but does not show the calculations. SC&A’s review of Revision 03 (and Revision 02) 

confirms that the “fixed missed neutron dose default value of 50 mrem” has been removed, since 

the unmonitored office workers dose records were already corrected by INL.

Since the NIOSH response does not provide data to support the two missed neutron dose 

multiplying factors, SC&A recommends that the WG keep this issue open for further discussion.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH repeats the statement above, shown under 

WG Action Items: SC&A, and adds: “This issue is related to Issue 29 that SC&A has 

recommended for closure – previous NIOSH efforts were to respond with 1 reply for both issues 

– NIOSH recommends closure for this issue.”
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SC&A Further Review: NIOSH (NIOSH 2013b, 2013c) refers SC&A to the Issue 29 

resolution. The NIOSH response in Issue 29 says:

...Revision 00 through Revision 03 of the INL’s external dosimetry TBD have 

included facility-specific adjustments to the reported neutron doses to account for 

the dosimeters’ poor energy response to lower-energy neutrons. The NTA film 

corrections for energy response in the INL TBD are comparable to the energy 

response corrections in ORAUT-OTIB-0051, which range from 1.0 to 2.2.

SC&A reviewed Rev. 3 of the External Dose TBD (ORAUT 2011b), which notes in

Section 6.5.4 that NTA dosimeters were used at INL before October 1976 and Hankins albedo 

TLDs thereafter. Section 6.5.4.1 states for the earlier period, “When the LOD for NTA film is 

used to estimate the missed neutron dose, it should be multiplied by 1.25 for most workers and 

by 2 for workers on the MTR experiment floor and on the TREAT or ZPPR experiment floor...” 

Data to support the correction factor is found in an extensive discussion in ORAUT-OTIB-0051

(ORAUT 2006). Although the OTIB is specifically for Y-12, the discussion on NTA film 

response to different energy neutrons is generic and applicable to INL as well. Hence, the range 

of NTA film response multiplication factors given in the INL External Dose TBD appears 

reasonable and consistent. SC&A recommends that the WG close this issue.
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3.36 ISSUE 36: MISSED LOW-ENERGY BETA DOSE

ORAUT-TKBS-0007-6, Occupational External Dose, Sect. 6.3.2.2 (subsequent to SC&A 2006)

Issue: Section 6.3.2.2 of the TBD discusses the 100 mg/cm2plastic dosimeter holder and the 

fact that betas of less than 360 keV will not penetrate the holder. (It is unclear if this density 

includes the film wrapper.) However, the TBD does not discuss allowance for or consideration 

of the possibility of the complete failure to detect these betas.

The general, averaging approach to missed beta is questionable. The concern is that beta 

exposure is always assumed to be due to a mix of energies and thus the dose component from 

low energies is known and can be corrected. Clearly this is not the case, as is stated in the 

attribution.

A specific concern is the Rare Gas Processing Facility (CPP-604), which harvested Kr-85. This 

nuclide is a pure beta emitter, with an endpoint energy of 670 keV. The film badges in use at the 

time were far from ideal for betas and failed to see any below 360 keV. NIOSH should 

determine if the maximum modifier recommended for betas of 2.8 is sufficient for this 

environment.

NIOSH Response: The current revision to the TBD (i.e., Revision 03) appears to address these 

concerns regarding the INL dosimeter responses to low-energy betas.

WG Action Items:

 SC&A: Review applicable portions of the current version of the External Exposure TBD 

and reassess the issue.

SC&A Reassessment: SC&A has reviewed Revision 03, including new Section 6.4.2 and 

Table 6-12. SC&A agrees with NIOSH that Revision 03 appears to address Issue 36, and 

recommends to the WG that this issue be closed.

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Rev. 1 Status and Review Information

NIOSH Update (NIOSH 2013b, 2013c): NIOSH agrees with SC&A’s recommendation to the 

WG to close this issue. 

SC&A Further Review: None
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3.37 ISSUE 37: ERROR IN REFERENCE

ORAUT-TKBS-0007-6, Occupational External Dose, TBD Sect. 6.5.4, (subsequent to SC&A 

2006)

Issue: The second paragraph of page 41 of the 2007 External Dose TBD references Table 6-16 

for IREP groups; it should refer to Table 6-14 instead.

NIOSH Response: Corrected in latest TBD revision.

WG Action Items: None. Issue closed at the June 21, 2011, WG meeting. 

CLOSED
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3.38 ISSUE 38: SHALLOW DOSE

ORAUT-TKBS-0007-6, Occupational External Dose, (subsequent to SC&A 2006)

Issue: NIOSH should consider making use of ORAUT-OTIB-0017, Interpretation of Dosimetry 

Data for Assignment of Shallow Dose, where appropriate. Additionally, contrary to the OTIB’s 

claim (p. 15) that the assumption of undergarment and pants thicknesses of 2 mm each is 

claimant favorable, SC&A believes that measured thicknesses are about half that and, hence, the 

OTIB assumptions are not claimant favorable.

NIOSH Response: This is a complex-wide issue and not specific to INL.

WG Action Items: None. ORAUT-OTIB-0017 already reviewed by Procedures Review 

Subcommittee. Issue closed at the June 21, 2011, WG meeting. 

CLOSED
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REFERENCES

40 CFR 50. U.S. Code of Federal Regulations, 40 CFR Part 50, National Primary and 

Secondary Ambient Air Quality Standards. 

40 CFR 58. U.S. Code of Federal Regulations, 40 CFR Part 58, Ambient Air Quality 

Surveillance.

BNL 2014. Brookhaven National Laboratory, National Nuclear Data Center, “Interactive Chart 

of the Nuclides,” www.nndc.bnl.gov (accessed February 12, 2014). 

Cipperly 1958. Cipperly, F.V., Personal Metering Operating Techniques, Self-Service System, 

Effective August 20, 1951 through March 29, 1958, IDO-12007, U.S. Atomic Energy 

Commission, Idaho Operations Office, 1958. [SRDB Ref. ID 8130] 

Cusimano 1981. Cusimano, J.P., Update of Facility Neutron Calibration Factor (FNCF), memo 

to Dosimetry File, U.S. Department of Energy, January 21, 1981. [SRDB Ref. ID 8145] 

DCAS 2011. Best Estimate Dose Reconstruction for Glovebox Workers, DCAS-TIB-0010, Rev. 

4, November 28, 2011. 

DOE 1991. Tiger Team Assessment of the Idaho National Engineering Laboratory, DOE/EH0178, U.S. Department of Energy, Office of Environment, Safety and Health, August 1991.

DNFSB 1994a. Memo from J.W. Troan to W. Cunningham, Technical Director, “Report on the 

Radiation Protection Program at the Idaho National Engineering Laboratory,” July 29, 1994.

DNFSB 1994b. Memo from Timothy J. Dwyer, Technical Staff, to G. W. Cunningham, 

Technical Director, “Sitewide Training and Qualification Review at the Idaho National 

Engineering Laboratory (INEL), July 11-15, 1994,” September 15, 1994. 

DNFSB 1995. Letter from John T. Conway, Chairman DNFSB, to Thomas P. Grumbly, 

Assistant Secretary for Environmental Management Department of Energy, March 28, 1995. 

Attaching: Memo from Daniel G. Ogg, Program Manager, INEL, to G. W. Cunningham, 

Technical Director, “Radiological Controls and Conduct of Operations, Idaho National 

Engineering Laboratory, High Level Waste Tank Farm Replacement Project, Report of Site 

Visit, November 30 - December 2, 1994,” January 17, 1995.

Gesell 1986. “Minimum Reporting Levels for the Panasonic Dosimetry Systems.” Letter to 

Dosimetry Customers, Radiological and Environmental Sciences Laboratory, May 15, 1986.

ICRP-23. Report of the Task Group on Reference Man, International Commission on 

Radiological Protection, Publication, No. 23, 1975. 

ICRP-66. Human Respiratory Tract Model for Radiological Protection, International 

Commission on Radiological Protection, Publication No. 66, 1994. 
Effective Date:

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NOTICE: This February 24, 2014, Issues Matrix has been reviewed for potential Privacy Act-protected information 

and cleared as written. Future versions of this issues matrix will not be freely distributed until further reviews for 

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ICRP-68. Dose Coefficients for Intake of Radionuclides by Workers, International Commission 

on Radiological Protection Publication, No. 68, 1995. 

King 2001. King, V.A., Technical Basis for Internal Dosimetry at SMC, EDF No. 2001-02, Rev. 

3, Idaho National Laboratory. [SRDB Ref. ID 8479]

Knoll, G., Radiation Detection and Measurement, 3rd Ed., New York: John Wiley & Sons, Inc., 

2000. 

NIOSH 2013a. Idaho National Laboratory (INL) Site Profile Update, presentation at ABRWH 

Idaho Falls, Idaho meeting. National Institute for Occupational Safety and Health, Cincinnati, 

Ohio. July 16, 2013. 

NIOSH 2013b. INL WG Issues Summary. National Institute for Occupational Safety and 

Health, Cincinnati, Ohio. November 7, 2013. 

NIOSH 2013c. Nov. 2013 Status on INL WG Issues (file name), November 7, 2013. This is a 

NIOSH markup of an SC&A table entitled: “October 2013 Status & Update in INL TBD WG 

Issues.” National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

OCAS 2002. External Dose Reconstruction Implementation Guideline, OCAS-IG-001, Rev. 1. 

Office of Compensation Analysis and Support, NIOSH, Cincinnati, Ohio. August 2002. 

OCAS 2007. External Dose Reconstruction Implementation Guideline, OCAS-IG-001, Rev. 3. 

Office of Compensation Analysis and Support, NIOSH, Cincinnati, Ohio. November 21, 2007.

ORAUT 2004a. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational External Dosimetry, ORAUT-TKBS-0007-

6, Rev. 0. Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 6, 2004. 

ORAUT 2004b. Technical Basis Document for the Idaho National Engineering and 

Environmental Laboratory (INEEL) – Occupational Internal Dose, ORAUT-TKBS-0007-5, 

Rev. 0, PC-1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 12, 2004. 

ORAUT 2005a. Internal Dose Overestimates for Facilities with Air Sampling Programs, 

ORAUT-OTIB-0018, Rev. 1. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

August 9, 2005.

ORAUT 2005b. Technical Information Bulletin: Interpretation of Dosimetry Data for 

Assignment of Shallow Dose, ORAUT-OTIB-0017, Rev. 01. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. October 11, 2005. 

ORAUT 2005c. Internal Dosimetry Coworker Data for X-10, ORAUT-OTIB-0033, Rev. 0. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 13, 2005.
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ORAUT 2006. Effect of Threshold Energy and Angular Response of NTA Film on Missed 

Neutron Dose at the Oak Ridge Y-12 Facility, ORAUT-OTIB-0051. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. May 15, 2006.

ORAUT 2007a. Technical Information Bulletin: Internal Dose Reconstruction, ORAUT-OTIB0060, Rev. 0. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 6, 2007.

ORAUT 2007b. Fission and Activation Product Assignment for Internal Dose-Related Gross 

Beta and Gross Gamma Analyses, ORAUT-OTIB-0054, Revision 0, PC-1. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. November 19, 2007.

ORAUT 2008a. Use of Coworker Dosimetry Data for External Dose Assignment, ORAUTOTIB-0020, Rev. 02. Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 4, 

2008.

ORAUT 2008b. Assignment of Missed Neutron Doses Based on Dosimeter Records, ORAUTOTIB-0023, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. May 14, 

2008.

ORAUT 2009. Idaho National Laboratory and Argonne National Laboratory-West: 

Occupational Medical Dose, ORAUT-TKBS-0007-3, Rev. 2. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. December 21, 2009.

ORAUT 2010a. Idaho National Laboratory and Argonne National Laboratory-West: 

Introduction, ORAUT-TKBS-0007-1, Rev. 3. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. March 12, 2010.

ORAUT 2010b. Idaho National Laboratory and Argonne National Laboratory-West: Site 

Description, ORAUT-TKBS-0007-2, Rev. 4. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. August 2, 2010.

ORAUT 2010c. Idaho National Laboratory and Argonne National Laboratory-West: 

Occupational Environmental Dose, ORAUT-TKBS-0007-4, Rev. 2. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. January 8, 2010.

ORAUT 2010d. Idaho National Laboratory and Argonne National Laboratory-West: 

Occupational Internal Dose, ORAUT-TKBS-0007-5, Rev. 3. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. March 2, 2010.

ORAUT 2011a. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Rev. 1. Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. February 17, 2011.

ORAUT 2011b. Idaho National Laboratory and Argonne National Laboratory-West: 

Occupational External Dosimetry, ORAUT-TKBS-0007-6, Rev. 3. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. April 19, 2011.
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ORAUT 2011c. Use of Coworker Dosimetry Data for External Dose Assignment, Rev. 3. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. November 14, 2011. 

Perry, O.R., B.L. Anderson, and P.E. Ruther, 1993. Minimum Reporting Level for the Idaho 

National Engineering Laboratory (INEL) Thermoluminescent Dosimetry (TLD) Systems, EGGESQ-10917, 1993.

SC&A 2003. Critical Review of Source Terms for Select Initial Engine Tests Associated with the 

Aircraft Nuclear Propulsion Program and INEL. SC&A, Inc., Vienna, Virginia. 2003

SC&A 2005. Review of the NIOSH Site Profile for the Idaho National Laboratory, Idaho, SCATR-TASK1-0005, Draft, Rev. 0. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. September 25, 2005.

SC&A 2006. Review of the NIOSH Site Profile for the Idaho National Laboratory, Idaho, SCATR-TASK1-0005, Draft, Rev. 1. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. January 25, 2006.

SC&A 2007. Review of the NIOSH Site Profile for the Argonne National Laboratory-West, 

Idaho, SCA-TR-TASK1-0021, Draft. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. July 27, 2007. 

SC&A 2008. Idaho National Laboratory (INL) Site Profile Review Update, SCA-TR-TASK1-

0005-S1, Draft. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. 

December 10, 2008. 

SC&A 2009. Combined Issues Matrix for the Idaho National Laboratory and the Argonne 

National Laboratory-West. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. July 15, 2009. 

SC&A 2011a. INL/ANL-W Work Group Meeting, June 21, 2011, Actions, June 24, 2011.

SC&A 2011b. INL/ANL-W Work Group Meeting, June 21, 2011, Actions, June 24, 2011 (incl. 

NIOSH comments). 

SC&A 2013. Idaho National Laboratory (INL) Site Profile Review Status Update, SCA-SPIM2013-0005, Rev. 0, Draft. SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. October 23, 2013.