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MEMO 

TO: BNL Work Group 

FROM: Ron Buchanan, SC&A 

DATE: May 22, 2012 

SUBJECT: SC&A’s Reply to NIOSH’s March 28, 2012, Responses to BNL SEC Issues 

 

The following 13 Brookhaven National Laboratory (BNL) Special Exposure Cohort SEC-00116 

(NIOSH 2008) issues remained to be addressed from the January 21, 2011, work group meeting. 

A statement of each issue, NIOSH’s response of March 28, 2012, and then SC&A’s reply are 

provided below. 

1. Determine if BNL applied any fading correction factors to neutron dose of record. 

NIOSH’s Response: BNL did not apply fading correction factors. This is because the 

calibration process accounted for any fading that may have occurred. See the FaustRuhter paper (NIOSH 2012b) for discussion. 

SC&A’s Reply: It appears that the vendor did calibrate the NTA film at the beginning of 

the exchange cycle and read them at the end of the cycle, therefore incorporating fading 

in the calibration cycle as if the whole dose was received on the first day of exposure 

(NIOSH 2011c), which is claimant favorable. An additional 9%/wk fading factor, as 

recommended on page 86 of the BNL technical basis document (TBD) (ORAUT 2010), 

is to be applied to the recorded dose. Note that the statement in the Faust-Ruhter paper 

(NIOSH 2012b) that, “...the NIOSH recommendation to apply a fading correction of 

1.56 (2 week wear period)...” is incorrect according to the BNL TBD (ORAUT 2010, 

page 86); it should read 9%/wk. Although there may have been some differences in 

environments for the worn and stored badges, the favorable practice of exposing the 

calibration field at the beginning of the cycle, and applying an additional 9%/wk fading 

factor to the worn badges should result in sufficient fading compensation. 

SC&A has no further comments concerning the issue at this time. 

2. Check recent BNL DRs to see if fading and angular dependence correction factors 

were used for neutron dose as described in the current TBD. 

NIOSH’s Response: Specifically, fading is not to be applied, per the NIOSH Response to 

item 1 above, and angular dependence is only considered for the neutrons >2 MeV. See 

the D.L. Strenge paper (NIOSH 2012a) for discussion. 

SC&A’s Reply: If the angular dependence correction factor of 1.3 is applied as listed on 

page 86 of the BNL TBD (ORAUT 2010), then SC&A has no further comments 

concerning the issue at this time. 
Memo: BNL SEC Issues 2 SC&A – May 22, 2012 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

3. See if any documentation can be found describing how BNL assigned neutron dose 

when NTA film was used with CR-39 and Lexan. 

NIOSH’s Response: When the several neutron dosimeters were used at the same time, 

the highest value was assigned as the dose of record. See Faust-Ruhter paper (NIOSH 

2012b) for discussion. 

SC&A’s Reply: It appears, from the documents reviewed to date, that generally the 

highest of the neutron readings were recorded. Therefore, SC&A has no further 

comments on the issue at this time. 

4. Write up evaluation of the variation of NTA and Lexan dosimetry NIOSH’s 

Responses over various energy ranges. Determine if a correction factor needs to be 

adopted or if these variations even significantly impact dose reconstruction. 

NIOSH’s Response: No correction factors are needed since the most appropriate 

dosimeter was generally used and the highest value was selected when multiple 

dosimeters were in service for any one individual. See Faust-Ruhter paper (NIOSH 

2012b) for discussion.

SC&A’s Reply: Even if the highest dose value was recorded, this does not mean that the 

highest dose value correctly represented the dose received. According to a March 16, 

2011, BNL memo from H. Kahnhouser to Dr. Falco (Kahnhauser 2011): 

The next step was to interview the individual that had been the Personnel 

Monitoring Group Leader during the time that RSL was used as the 

vendor. His name is Carl Schopfer, who is now the Radiation Safety 

Officer at the National Urban Security Technology Laboratory, for the 

U.S. Department of Homeland Security in New York City. 

This was his response to your query: 

“I don't think all three were used simultaneously for too long, 2–3 

years at most but the paper dosimetry reports should indicate. There 

should be a memorandum (to Landauer) in the records documenting 

how the neutron dose equivalent was to be assigned. I seem to recall 

that the decision was to take the highest of the three. The rationale 

was partly because of the differing energy response (e.g., trying to 

capture some significant part of the actual spectrum), but just as much 

because at the time all three were being used, one or the other 

component experienced catastrophic failure at anyone time. For 

example, total fading with NTA, or bad processing or counting 

procedure with the plastics. I don't think they ever correlated for a 

typical occupational exposure. Gradually, Landauer stopped even 

trying to perform with the NTA but did work to improve the other two, 

so when the NTA was dropped, the higher of the two plastics was used, 
Memo: BNL SEC Issues 3 SC&A – May 22, 2012 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

as I recall. Then as before the rationale was more reliability, e.g., 

hedging our bets during instances of component failure (hoping that 

both did not fail at the same time) rather than the spectrum issues. 

High-energy neutron dose equivalent, such as at AGS was probably 

missed since NTA was history, and it did not seem despite assertions 

that the Lexan really did cover the range. The QC test program 

showed how the detectors performed (or didn't) on a routine basis to 

the neutron source, but tests with accelerator spectra were not 

conducted.” [Emphasis added.] 

“RCD Staff looked for the referred to memorandum in the Personnel Monitoring 

files and were unable to find it in the personnel monitoring records.” 

Obviously, this article does not speak well of the recorded neutron doses correctly 

reflecting the actual doses received on a consistent basis. 

The use of NTA, Lexan, and CR-39 at the BNL throughout the years has seen numerous 

problems. The issues of the detectors’ lack of response to low-energy and high-energy 

neutrons (below their threshold and above their calibrated range) has not received a 

workable solution, nor has the noted inconsistency of the dose readings within a given 

detector type, or among the different detectors, been satisfactorily addressed by BNL or 

NIOSH. The use of a quality factor (QF) of 10 does not address, nor compensate, for 

these shortcomings. These problems were discussed in detail in SC&A’s evaluation 

(SC&A 2009) of the BNL site profile document (2006) and SC&A’s review (SC&A 

2010) of NIOSH’s SEC ER (NIOSH 2009). This information indicates that the neutron 

doses at BNL were not measured and recorded with sufficient accuracy to allow 

reasonable neutron dose reconstruction without further consideration of adjusting the 

recorded neutron dose to account for unregistered neutron dose, until the DOELAP 

accreditation in 1995 and onsite processing began in 1996 (ORAUT 2010, page 89). An 

overall evaluation of the neutron dosimetry problems indicates that the recorded dose 

may have been <50% of the actual dose in some areas; therefore, an adjustment factor of 

2 to 4 is needed to ensure claim favorability. 

5. Look for Piesch memo on NTA film fading. 

NIOSH’s Response: This memo has been found and has been entered into the SRDB as 

#91775 (Piesch 1975) and is attached. 

SC&A’s Reply: SC&A has reviewed this document in light of Issue #1 above and has no 

further comments at this time. However, it should be noted that it appears that NIOSH 

did not obtain the BNL TBD-recommended fading factor of 9% from this document. 
Memo: BNL SEC Issues 4 SC&A – May 22, 2012 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

6. Provide WG with SRDB numbers with WBC data for 2 individuals missing data in 

1980 memo. 

NIOSH’s Response: This data is no longer applicable since the SEC period has been 

recommended to be extended through 12/31/1993. 

SC&A’s reply: SC&A concurs with NIOSH’s response. 

7. Report status of BNL requests for data. 

NIOSH’s Response: BNL has remedied any problems they had with timeliness. 

NIOSH’s Responses are now received in a timely manner. 

SC&A’s Reply: If this is correct, then SC&A has no further issues with this item. 

8. Evaluate feasibility of the need for and ability to develop an internal coworker 

model. 

a. What BNL facilities and timeframes are relevant for an internal dose co-worker 

application by virtue of exposure potential and numbers of workers affected? 

b. Would any existing claimants be affected (i.e., they have been assigned ambient 

environmental, but should be assigned a co-worker dose, instead)? 

c. How complete is the existing dose record for those designated facilities/timeframes? 

NIOSH’s Response: At this time, there are no plans to develop a coworker internal dose 

model. 

SC&A’s Reply: These are details that should be incorporated in Issue #12 and addressed 

along with that issue. 

9. Provide WG with NIOSH IDs for 8 cases used in “in-house” data evaluation. 

NIOSH’s Response: These eight cases were used as part of the justification for the 1979 

end period of the previously established SEC. Because the SEC period has been 

extended, these cases are no longer applicable. 

SC&A’s Reply: SC&A concurs with NIOSH’s response. 

10. Update “in-house” study with any additional information provided by BNL. 

NIOSH’s Response: The additional “in-house” review resulted in the determinations that 

internal doses could not be completed with sufficient accuracy prior to 12/31/1993. 

SC&A’s Reply: SC&A concurs with NIOSH’s response. 
Memo: BNL SEC Issues 5 SC&A – May 22, 2012 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

11. Try to determine if data was transferred from paper to a database or between 

databases. Determine if this transfer was verified to be accurate. 

NIOSH’s Response: In 1985, all external dosimetry data was summarized as quarterly 

totals [onto hardcopies] and the old [hardcopy] records were destroyed. It is not certain if 

the summary information is in an electronic database, or if only the [quarterly] hardcopy 

exists as provided by BNL for claims. Consequently, for BNL, the only external 

dosimetry information available prior to 1985 is quarterly [hardcopy] summaries, 

although most workers were monitored on a monthly basis. No information is available 

regarding verification of the data transfers. In about 1967, internal dosimetry records (at 

least for reactor workers) were transferred from old forms to a new standard form. The 

new forms indicate the information transfer was verified with a signature of the 

verification included on the form. 

SC&A’s reply: This presents a question of the completeness and accuracy of the external 

dose database, either in hardcopy or electronic form, prior to 1985. Additionally, the 

question still remains if the original external dose data from 1985 forward have been 

transferred to any new databases, and if the transfer(s) was verified for completeness and 

accuracy. 

12. Report what we are doing for individuals without internal dosimetry deemed to 

have the potential for greater than environmental internal dose. 

NIOSH’s Response: At this time there are no plans to develop a coworker internal dose 

model. 

SC&A’s reply: This response does not answer the question of what will be done in cases 

where an Energy Employee had the potential for intake, but was not bioassayed or the 

results are not available, after 1993. Details from Issue # 8 are also applicable to this 

issue. 

13. Request the Radiological Footprint Project from BNL. 

NIOSH’s Response: This was a document that the work group had mentioned seeing at 

one of the meetings. We have been unable to identify or locate this document. 

SC&A’s reply: The footprint document was discussed at the January 21, 2011, work 

group meeting (NIOSH 2011a, pages 131, 167, and 169 of the transcript). A search of 

the SRDB provided Ref ID #100494 dated June 23, 2011 (NIOSH 2011b), which states 

the following on page 2: 

1. Document Description: Brookhaven Building Data Access Files - 

Rad Footprint Project - Information, Maps and Pictures 
Memo: BNL SEC Issues 6 SC&A – May 22, 2012 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

2. Project Document Number: 030086345 (NIOSH 2011b) 

Type of information: large number of related files including multiple 

Access databases. This information can be found at the following file 

location: O:\DOE Site Images\Brookhaven National 

Laboratory\030086345 - BNL Building Data Access Files. 

However, the directory on the O-drive for the DOE Site Images for BNL is empty at this 

time. 

References 

Kahnhauser 2011. ORAU Team Dose Reconstruction Project from NIOSH Data Request, H. 

Kahnhauser to Dr. Falco, March 16, 2011. SRDB 93609. 

NIOSH 2008. SEC-00116 “Brookhaven National Laboratory Special Exposure Cohort – 

January 1, 1947 through December 31, 2007. National Institute for Occupational Safety and 

Health, Office of Compensation Analysis and Support, Cincinnati, Ohio. July 21, 2008. 

NIOSH 2009. SEC Petition Evaluation Report, Petition SEC-00113, Rev. 0. National Institute 

for Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. September 29, 2009. 

 

NIOSH 2011a. Work Group On Brookhaven National Laboratory – January 21, 2011. National 

Institute for Occupational Safety and Health, Office of Compensation Analysis and Support, 

Cincinnati, Ohio. January 21, 2011. 

NIOSH 2011b. “Brookhaven Building Data Access Files - Rad Footprint Project - Information, 

Maps and Pictures.” National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. June 23, 2011. SRDB 100494. 

 

NIOSH 2011c. Telephone Interview between Landauer Personnel and M.H. Chew personnel, 

July 27, 2011. National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio. SRDB 100347. 

NIOSH 2012a. Strenge, D. Neutron Dose Calculations at BNL. National Institute for 

Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. February 22, 2012. 

NIOSH 2012b. Faust, L.G. and Ruhter, P.E. NIOSH Response to BNL NTA Fading and Lexan 

Use Issues. National Institute for Occupational Safety and Health, Office of Compensation 

Analysis and Support, Cincinnati, Ohio. March 28, 2012. 
Memo: BNL SEC Issues 7 SC&A – May 22, 2012 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

ORAUT 2006. Technical Basis Document for the Brookhaven National Laboratory, ORAUTTKBS-0048, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 30, 

2006. 

ORAUT 2010. Technical Basis Document for the Brookhaven National Laboratory, ORAUTTKBS-0048, Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. April 26, 

2010. 

Peisch 1975. Piesch, E., and Sayed, A. Latent Fading of Gamma and Neutron Monitoring Films 

Nuclear Instruments and Methods 123 (1975) 397-402 North-Holland Publishing Co. Karlsruhe 

Nuclear Research Centre, Health Physics Division, Karlsruhe, Germany. Received September 

20, 1974. 

SC&A 2009. Review of the NIOSH Site Profile for Brookhaven National Laboratory. SC&A, 

Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. September 2009. 

 

SC&A 2010. Preliminary Issues From SC&A’s Review Of NIOSH’s Evaluation Report 

For Brookhaven National Laboratory Special Exposure Cohort Petition Sec-00113. SC&A, 

Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. July 2010.