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

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

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

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

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

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

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

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

MEMORANDUM

TO: Argonne National Laboratory – East Work Group

FROM: SC&A, Inc.

DATE: May 10, 2018 

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

Introduction and Background 

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

technical basis documents (TBDs) are as follows: 

• ORAUT-TKBS-0036-2, Revision 00 PC-1, Argonne National Laboratory – East – Site 

Description (2006) 

• ORAUT-TKBS-0036-3, Revision 01 PC-1, Argonne National Laboratories – East – 

Occupational Medical Dose (2006) 

• ORAUT-TKBS-0036-4, Revision 00, Argonne National Laboratory – East – 

Occupational Environmental Dose (2006) 

• ORAUT-TKBS-0036-5, Revision 00, Argonne National Laboratory – East – 

Occupational Internal Dose (2006) 

• ORAUT-TKBS-0036-6, Revision 01, Argonne National Laboratory – East – External 

Dosimetry (2014). Revision 01 replaced ORAUT-TKBS-0036-6, Revision 00, of 

February 9, 2006 

SC&A issued a review of the ANL-E TBDs in 2009 (SC&A 2009) and an updated report in 2016 

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

System (BRS) in February 2017. 

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

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

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

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

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

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

informed the ANL-E WG and NIOSH of these entries in the BRS in an email on April 11, 2017 

(SC&A 2017b). 
Memo – Status of ANL-E Findings and Observations 2 SC&A – May 10, 2018 

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

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

SC&A issued a memorandum, Current Status of ANL-E Site Profile Findings and Observations, 

to the ANL-E WG on July 17, 2017 (SC&A 2017a). NIOSH posted responses to the findings and 

observations in the BRS on February 9, 2018. 

This memorandum is a summary of NIOSH’s recent posting to the BRS and SC&A’s current 

response.

Current Status of Findings 

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

from the BRS. Further details are available on the BRS, including discussion of the finding and 

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

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

and Radionuclides Not Addressed in Site Profile 

NIOSH BRS Posting, February 9, 2018 

For a research facility with the broad range of activities that were in existence at 

ANL-E, identifying a “routine” enrichment value for enriched uranium or a 

sitewide mixture ratio for plutonium isotopes would not be expected. Research 

into ANL-E records indicates a variety of radionuclides in addition to uranium 

and plutonium were encountered, and bioassay procedures were implemented to 

monitor the specific radionuclides from early periods of operation. Records show 

that analysis results for at least 34 individual radionuclides were included in 

bioassay analytical reports from 1953 through 1976. 

NIOSH acknowledges the difficulty this presents in performing dose 

reconstructions on mixtures of radionuclides, however, assumptions can be made 

to allow reasonable and claimant favorable assessments. [See BRS posting 

concerning Finding 1 for complete description.] 

Guidance in the TBD will be modified or added where appropriate based on the 

available information to aid dose reconstructors in interpreting mixtures of 

radionuclides. TBD will be revised to provide dose reconstructors with 

additional definition, assumptions, and details as outlined above, as well as any 

information derived from recent data capture and interviews, to aid in assessment 

and interpretation of early bioassay records. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.
Memo – Status of ANL-E Findings and Observations 3 SC&A – May 10, 2018 

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

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

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

(1946 to 1972) 

NIOSH BRS Posting, February 9, 2018 

Gross alpha analysis, also termed “fluoride insoluble” analysis, was used as a 

screening method to evaluate exposure to several alpha-emitting radionuclides at 

once. Detection limits for early periods are derived for the TBD using the lowest 

positive reported amounts found in ANL-E records. Additional record 

acquisitions and records of previous DOE [U.S. Department of Energy] reported 

values are being evaluated and will possibly result in refinements to these values. 

It is noted that a specific procedure for analyzing plutonium may have existed 

separately from the gross alpha analysis method prior to the earliest period 

described in the TBD (for example, SRDB Ref. ID 165282 [ANL-E n.d.] includes 

a record for a [plutonium-239] result of <0.5 [disintegrations per minute]

/1500 mL for a urine sample in 1951, along with a positive fecal sample result). 

Additional guidance will be provided in the TBD to direct dose reconstructors on 

how to interpret bioassay data for gross alpha analysis. Current practice has been 

to apply the bioassay results to all nuclides represented and use the most claimant 

favorable of the results unless the particular radionuclide can be determined from 

the records. Based on the programmatic limitations of the bioassay program for 

this period, this is considered adequate as a claimant favorable approach to 

interpreting the results.

It is noted that identification of specific nuclides is sometimes available from 

bioassay information in ANL-E monthly program reports. This source of 

information will be further evaluated to determine if additional resources can be 

made available to the dose reconstructors (i.e., in addition to the individual 

bioassay records provide by DOE) to identify the radionuclide of interest. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released. SC&A would like to caution 

that the use of data obtained from gross counting of bioassay samples to project 

specific radionuclide intakes (from an assortment of potential radionuclides) 

presents issues as outlined in SCA’s report for Lawrence Berkeley National 

Laboratory [SC&A 2018]. 

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

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

recommends closure. 
Memo – Status of ANL-E Findings and Observations 4 SC&A – May 10, 2018 

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

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

Finding 4 – Insufficient Information on the Calculation of Minimum Detectable 

Concentrations (MDC) and Uncertainties in Bioassay Methodology 

NIOSH BRS Posting, February 9, 2018 

From the review of previous and recently obtained records, it is likely that some 

refinements in uranium and plutonium MDC values, and their applicable dates, 

can be made in the TBD. Further analysis of this data will be performed to 

evaluate whether modifications are possible for MDCs and/or uncertainties of 

other nuclides as well.

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

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

NIOSH BRS Posting, February 9, 2018 

According to ANL-E records and interviews with former workers and radiological 

program personnel (SRDB Ref. ID 12632 [ANL-E 1961–1982]), all employees in 

radiologically controlled areas were monitored; external dosimetry reports, 

bioassay results, and information in ANL-E monthly reports appear to confirm 

this. Review of 95 claims with employment dating back to 1946 and extending to 

2008 revealed only three claims with no internal or external monitoring, with 

either short-duration employment (<3 months) or job titles consistent with nonradworkers. Therefore, information from environmental reports incorporated as 

internal environmental intakes in ORAUT-TKBS-0036-4 are most appropriate for 

unmonitored workers outside of radiologically controlled areas. These values 

would be considered overestimating since they include contributions from fallout 

for early years in addition to potential intakes from ANL-E operations. ORAUTTKBS-0036-5 will be revised to direct the use of environmental intakes from 

ORAUT-TKBS-0036-4 to clarify this. 

SC&A Response, May 2, 2018 

SRDB Ref. ID 12632 [ANL-E 1961–1982] is a very lengthy document 

(347 pages) that covers many documents, decades, and situations. It would be 

helpful in verifying NIOSH’s statement that “all employees in radiologically 

controlled areas were monitored” if NIOSH could provide page numbers in that 

document that provide support for that conclusion. Additionally, SC&A will 

review the revised TBD when released.
Memo – Status of ANL-E Findings and Observations 5 SC&A – May 10, 2018 

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

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

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

the Pre-1988 Years and Potentially Misses Special Employment Exams 

NIOSH BRS Posting, March 8, 2017 

ORAUT-OTIB-0006, Revision 03 PC-1, Dose Reconstruction from Occupational 

Medical X-Ray Procedures, has been revised (to Revision 04 in 2011) since the 

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

TBD will be evaluated and revised as necessary to incorporate ORAUT-OTIB0006, Revision 04, recommendations regarding special screening exams. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

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

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

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

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

recommendation. 

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

NIOSH BRS Posting, February 9, 2018 

Pertinent information from ORAUT-OTIB-0006 will be incorporated in the 

ANL-E TBD, as stated above.

Evaluation of claimant files supports the SC&A concern that post-1980 X-rays 

may have been implemented more frequently than every four years. TBD will be 

revised to assume annual X-rays, rather than at four-year intervals, be applied for 

workers with no available X-ray records. 

Claimant files and other record information will be evaluated to determine 

whether the ending date for the application of PFG [photofluorography] exam 

should be extended from 1956 through 1958. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

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

Reexamination 

NIOSH BRS Posting, February 9, 2018 

To date, no additional information has been identified from recently captured 

documents or from interviews with former ANL-E employees that is expected to 
Memo – Status of ANL-E Findings and Observations 6 SC&A – May 10, 2018 

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

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

significantly modify or enhance the current descriptions in the TBD. Review 

efforts will continue to identify more detailed specification information for film 

and neutron dosimeters for early time periods, including evaluating the need for 

additional data capture.

SC&A Response, May 2, 2018 

SC&A will review the additional data and/or revised TBD when released.

Finding 10 – Neutron Dosimetry Is Inadequately Addressed 

NIOSH BRS Posting, February 9, 2018 

To date, no additional information has been identified from recently captured 

documents or from interviews with former ANL-E employees that is expected to 

significantly modify or enhance the current descriptions in the TBD. Review 

efforts will continue to identify more detailed specification information for 

neutron monitoring. 

NIOSH will continue efforts to locate and evaluate ANL-E records to develop 

neutron to photon ratios from available monitoring data, as well as other methods 

of addressing these deficiencies (e.g., adopting appropriate ratios from sites with 

similar facilities, see comment below) and will update the TBD information 

accordingly. Additional data capture efforts targeted at film and neutron 

dosimeters specifications for early periods may be warranted.

For periods prior to the implementation of neutron dose monitoring (1953), or 

when neutron films were only read when the gamma dose was above 100 mrem 

(before 1960), it is suggested that the glovebox neutron to photon ratio developed 

for Hanford could adequately describe plutonium glovebox work at ANL-E. Since 

this ratio is more claimant favorable than [neutron to photon] ratios for reactors at 

Hanford, it would be expected to overestimate neutron doses from sources at 

ANL-E (primarily test reactors and plutonium gloveboxes) for these periods. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

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

Inadequately Justified

NIOSH BRS Posting, February 9, 2018 

Current estimates of ambient external dose from ORAUT-TKBS-0036-4 are 

based on overestimates of airborne exposure to short-lived, gamma emitting 

nuclides, primarily [argon-41] from the CP-5 reactor releases since onsite 

measurements of direct radiation based on [thermoluminescent dosimeter]

monitors were indistinguishable from offsite measurements given the uncertainty 
Memo – Status of ANL-E Findings and Observations 7 SC&A – May 10, 2018 

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

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

of the results. The maximum external dose currently assigned for non-monitored 

workers based on these values is 0.014 rem per year (assumed to be 2600 hours). 

By contrast, the average value of the maximizing onsite ambient doses from the 

sites listed in ORAUT-PROC-0060 [Revision 01, 2006] range from around 

0.150 rem in 1971 up to 2.7 rem in 1946. Because these values would likely be 

comparable to, or exceed, average external doses for monitored workers at 

ANL-E for the same periods, they would be anticipated to be very claimant 

favorable estimates of doses to non-monitored workers. These ORAUT-PROC0060 values, or more reasonable estimates, if they can be derived, will be 

incorporated in the TBD direction to dose reconstructors. 

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

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

Area A and from Particulates Released During Accidents Are Not Adequately Addressed 

NIOSH BRS Posting, March 8, 2017 

According to the TBD (ORAUT-TKBS-0036-2, Section 2.2.2), waste disposal 

operations at Site A were conducted from 1943 through 1949, with buried waste 

removed to Site D in 1949. Consequently, all waste disposal operations at Site A 

were conducted during the period prior to 1954 when the TBD assumptions were 

considered to be adequate. 

SC&A Response, July 17, 2017 

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

March 21, 2017, and recommends closing the issue. 

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

Plot M 

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

recommends closure. 

Current Status of Observations 

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

copied from the BRS. Further details are available on the BRS, including discussion of the 

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

NIOSH. 
Memo – Status of ANL-E Findings and Observations 8 SC&A – May 10, 2018 

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

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

Observation 1 – Potential Missed Dose from Skin and Clothing Contamination 

NIOSH BRS Posting, February 9, 2018 

TBD revision will incorporate appropriate guidance from, or reference to, 

ORAUT-OTIB-0017 [Revision 01, 2005] in assessing doses from skin and 

clothing contamination.

SC&A Response, May 2, 2018 

SC&A will review the revised TBD when released.

Observation 2 – Other Potential Medical Exposures Have Not Been Identified 

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

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

recommendation. 

Observation 3 – Additional Factors Contribute to Medical Dose Uncertainties 

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

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

recommendation. 

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

NIOSH BRS Posting, February 9, 2018 

No records have been identified which indicate worker monitoring for radon was 

routinely performed; however no major sources of enhanced radon exposure have 

been identified for the ANL-E site. There were no large quantities of uranium or 

radium in ore stored or handled at ANL-E. 

SC&A Response, May 2, 2018 

In evaluating this issue it would be helpful to know if NIOSH has located any 

bioassay data for radium and/or its decay products in the NOCTS files they have 

evaluated; such as the 95 claims previously referred to in Finding 5. If workers 

were bioassayed for radium and its decay products this would indicate that there 

was potential exposure from radon and it decay products.

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

Transferees, and Visitors 

NIOSH BRS Posting, February 9, 2018 

While no documentation has been found describing formal policy or contractual 

relationships involving radiation protection policy regarding contract workers, 
Memo – Status of ANL-E Findings and Observations 9 SC&A – May 10, 2018 

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

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

early monthly reports document that contractor company workers were included 

in monitoring. [SRBD references provided in BRS posting.] 

Interview with former ANL-E workers (earliest employment date 1947) verified 

that contractors were not typically used for work in radiological areas, but that all 

individuals in these areas were monitored. [SRBD references provided in BRS 

posting.] 

Consequently, there is no indication that visitors, contractors, or transferees would 

have been excluded from appropriate radiation protection or monitoring 

procedures. 

SC&A Response, May 2, 2018 

SC&A reviewed recent interviews and related documents and did not find 

evidences of subcontractors and visitors being monitored differently than ANL-E 

employees. Therefore, SC&A recommends closure of this issue.

Observation 6 – Human Radiation Experiments Not Addressed 

NIOSH BRS Posting, February 9, 2018 

Revised TBD will include explicit direction to dose reconstructors that doses from 

human radiation experiments are covered exposures to be included in the 

assessments, and will cite references providing additional information.

SC&A Response, May 2, 2018 

SC&A concurs with NIOSH’s explanation and will review the revised TBD when 

release.

Observation 7 – Incidents and Accidents Need to Be Reexamined 

NIOSH BRS Posting, February 9, 2018 

Review of records has identified ANL-E documentation of minor incidents (spills, 

contamination, etc.) after 1979, but no compilation or description of major 

accidents. However, ANL-E documentation demonstrates that even in early 

periods, exposures associated with significant incidents are noted as such in 

records. Because major incidents would likely have been tracked by DOE on a 

site-wide basis during the later period in question, no revision or additions to this 

section are considered necessary to aid in dose reconstructions. 

SC&A Response, May 2, 2018 

SC&A’s recent search for incidents at ANL-E did not result in any specific 

documentation of major incidents that would indicate unmonitored exposures. As 

at other DOE sites, incidents will be handled on any individual bases during dose 

reconstruction. Therefore, SC&A recommends closure of this issue.
Memo – Status of ANL-E Findings and Observations 10 SC&A – May 10, 2018 

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

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

References 

ANL-E 1961–1982. Information about the ANL Dosimetry Program, Argonne National 

Laboratory. Various dates, 1961–1982. [SRDB Ref. ID 12632]

ANL-E n.d. Internal Exposure to Miscellaneous Isotopes at Argonne National Laboratory, 

Argonne National Laboratory. No date. [SRDB Ref. ID 165282]

ORAUT-OTIB-0006. 2005. Dose Reconstruction from Occupationally Related Diagnostic

X-Ray Procedures, Revision 03 PC-1, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. December 21, 2005. 

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

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

Ohio. June 20, 2011. 

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

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

October 11, 2005. 

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

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

2006. 

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

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

July 24, 2006. 

ORAUT-TKBS-0036-3. 2006. Argonne National Laboratories – East – Occupational Medical 

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

March 27, 2006. 

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

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

Cincinnati, Ohio. February 9, 2006. 

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

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

March 1, 2006. 

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

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

2006. 
Memo – Status of ANL-E Findings and Observations 11 SC&A – May 10, 2018

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

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

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

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

October 16, 2014. 

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

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

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

Argonne National Laboratory–East, Revision 1, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., 

Jefferson, Maryland. June 5, 2016.

SC&A 2017a. Memorandum – Current Status of ANL-E Site Profile Findings and Observations, 

SC&A, Inc., Vienna, Virginia. July 17, 2017.

SC&A 2017b. Email from SC&A, Inc., to ANL-E Work Group, Subject: ANLE Site Profile TBD 

issues on BRS. April 11, 2017.

SC&A 2018. SC&A Evaluation of NIOSH White Paper, “Method to Assess Internal Dose Using 

Gross Alpha, Beta, and Gamma Bioassay and Air Sampling at the Lawrence Berkeley National 

Laboratory,” SCA-TR-2018-SP003, Revision 0, SC&A, Inc., Arlington, Virginia. April 18, 

2018.