Draft

Advisory Board on Radiation and Worker Health

National Institute for Occupational Safety and Health

Review of Documentation Provided by CORE Advocacy 

Related to the Evaluation of SEC-00235 at the Santa Susana 

Field Laboratory

Contract No. 75D30119C04183

Document No. SCA-TR-2019-SEC006, Revision 0

Prepared by

Milton Gorden

SC&A, Inc.

2200 Wilson Boulevard, Suite 300

Arlington, VA 22201-3324

November 25, 2019

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 report has been reviewed to identify and redact any information that is protected 

by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, Inc. Technical Support for the Advisory Board on Radiation and Worker Health’s Review 

of NIOSH Dose Reconstruction Program

Document Title Review of Documentation Provided by CORE Advocacy Related to the 

Evaluation of SEC-00235 at the Santa Susana Field Laboratory

Document Number SCA-TR-2019-SEC006

Revision Number 0 (Draft)

Supersedes N/A

Effective Date November 25, 2019

Task Manager John Stiver, MS, CHP [signature on file]

Project Manager John Stiver, MS, CHP [signature on file]

Document Reviewer(s) Bob Barton, CHP [signature on file]

Record of Revisions

Revision Number Effective Date Description of Revision

0 (Draft) 11/25/2019 Initial Issue
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Table of Contents

Abbreviations and Acronyms........................................................................................... 4

1 Introduction and Background ................................................................................... 6

2 Summary of SC&A Review ...................................................................................... 8

2.1 Monitoring of site remediation workers............................................................... 8

2.2 TRUMP-S program ............................................................................................ 9

2.3 Transuranic waste management at SSFL ........................................................ 11

3 Summary Conclusions ........................................................................................... 13

4 References............................................................................................................. 14

Attachment A: Responses to Specific SSFL Petitioner Concerns Presented during the 

2019 Advisory Board Meeting and Provided with the Document Submittal................... 17
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Abbreviations and Acronyms

ABRWH, Board Advisory Board on Radiation and Worker Health 

Am americium

BZ breathing zone 

CEP Controls for Environmental Pollution 

CH contact-handled 

CORE Advocacy CORE Advocacy for Nuclear and Aerospace Workers

CRIEPI Central Research Institute of Electric Power Industry (Japan) 

CT computer tomography 

DAC derived air concentration 

DOE U.S. Department of Energy 

DOELAP Department of Energy Laboratory Accreditation Program

EEOICPA Energy Employees Occupational Illness Compensation Program Act

FOIA Freedom of Information Act 

GA general area

KHI Kawasaki Heavy Industries

mrem millirem

MURR Missouri University Research Reactor 

NIOSH National Institute for Occupational Safety and Health

NMDF Nuclear Materials Development Facility

Np neptunium 

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

Pu plutonium 

PWR pressurized-water reactor

RH remote-handled 

RIHL Rockwell International Hot Laboratory

RMDF Radioactive Material Disposal Facility

RMHF Remote Materials Handling Facility

SEC Special Exposure Cohort 

SRDB Site Research Database

SSFL Santa Susana Field Laboratory 
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TRU transuranic

TRUMP-S Transuranic Management by Pyropartitioning-Separation 

UMC University of Missouri at Columbia

WAC waste acceptance criteria

WIPP Waste Isolation Pilot Plant
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1 Introduction and Background

In May 2017, the National Institute for Occupational Safety and Health (NIOSH) issued an 

evaluation report for Special Exposure Cohort (SEC) Petition SEC-00235 for Area IV of the 

Santa Susana Field Laboratory (SSFL) for the period August 1, 1991, to June 30, 1993 (NIOSH, 

2017). SEC-00235 was qualified for evaluation because of compromised bioassay samples 

analyzed by the vendor Controls for Environmental Pollution (CEP) during this time period 

(referred to as the “CEP period” in this report). NIOSH does not use the bioassay results from 

CEP because they were implicated in data falsification at another site (not SSFL-affiliated). 

NIOSH found that, despite the lack of roughly 2 years’ worth of in vitro bioassay data, there was 

no dose reconstruction infeasibility for the evaluated period and did not recommend that a class 

be added to the SEC. In order to perform internal dose reconstruction during this period, NIOSH 

recommends use of the coworker models developed for Area IV and documented in ORAUTOTIB-0080 (NIOSH, 2014). However, two issues subsequently arose during SSFL work group 

discussions: 

• Issue 1: The possible presence of thorium and americium isotopes that may represent a 

significant internal exposure hazard. 

• Issue 2: The evaluation and comparison of air sampling data during the operational 

period and CEP period in order to demonstrate that the general radiological conditions 

during the CEP period are sufficiently similar to, or bounded by, the operational 

conditions. 

These two issues were discussed during the Area IV SSFL work group meeting held on 

December 4, 2017, at which time NIOSH was tasked with evaluating each concern. NIOSH 

delivered two separate white papers on these subjects to the Area IV SSFL work group on 

November 1, 2018. SC&A reviewed these two white papers1 and available documentation, 

issuing a draft report with the following conclusions: 

• Issue 1: “SC&A did not identify evidence of internal exposure potential to americium 

and/or thorium sources that would preclude dose reconstruction feasibility. . . . NIOSH 

might consider establishing an occupational exposure model, in place of an 

environmental intake model that uses available air sampling results (BZ and GA) or some 

fraction of the administrative limits in place at the time” (SC&A, 2019a, p. 23). 

• Issue 2: “SC&A found no evidence in either the available documentation or GA air 

sample data that radiological conditions were significantly different from the operational 

period that would preclude the use of coworker intake models developed for uranium, 

plutonium, and fission/activation products (strontium and cesium) during the CEP 

Period” (SC&A, 2019a, p. 23). 

1 Although NIOSH issued two separate white papers on these subjects, due to the general overlap of these two 

issues, SC&A elected to combine its review into a single report.

The SEC petitioner for SSFL (CORE Advocacy for Nuclear and Aerospace Workers, hereafter 

“CORE Advocacy”) notified NIOSH on January 28, 2019, that approximately 1,463 boxes of 

U.S. Department of Energy (DOE) records relevant to SSFL were scheduled to be made 

 
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available no later than fall 2019. The SEC petitioner discussed some of the content of these 

records at the meeting of the Advisory Board on Radiation Worker Health (ABRWH or 

“Advisory Board”) held in Knoxville, TN on August 21, 2019. These documents were made 

available to NIOSH and SC&A reviewers in August and September 2019. During the ABRWH 

meeting on August 21, the SEC petitioner contended that the submitted documents confirm 

“operations with americium and thorium at Area IV until 2008. . . . [and] another document 

today that potentially puts processes with these materials at the site until 2010” (ABRWH, 2019, 

p. 87). More specifically:

• The documentation provides “new evidence that suggest site remediation workers were, 

and currently are, insufficiently monitored. . . . under the FOIA [Freedom of Information 

Act] we obtained several of the requests from Boeing to be exempted from Department of 

Energy’s requirements to monitor site remediation workers” (ABRWH, 2019, pp. 90–91). 

• The documentation contains “a Boeing technical progress report that details TRUMP-S 

operations Area IV from 1993 until 1998,” with it appearing to the petitioner that “they 

brought the program back” (ABRWH, 2019, p. 90). 

• The documentation contains “several . . . acceptable knowledge summaries that describe 

transuranic waste generation and processes between 2002 to 2008, and the storage of 

transuranics for up to 20 years . . . the plutonium content was quickly decaying to rising 

levels of americium” (ABRWH, 2019, p. 90). 

In this report, SC&A has reviewed the documentation submitted by the SEC petitioner to 

ascertain the effect of such new information on dose reconstruction feasibility. The 

documentation consisted of nine computer files. One of the files was a technical progress report 

for the period 1993 through 1998 regarding the Transuranic Management by PyropartitioningSeparation (TRUMP-S) program. Four files were related to the storage, processing, and 

management of transuranic (TRU) waste (including three files associated with acceptable 

knowledge summary reports for specific TRU waste streams). One file contained 1,276 pages of 

documentation, much of which was related to radiological monitoring of workers and the 

Department of Energy Laboratory Accreditation Program (DOELAP) certification of SSFL’s 

internal dosimetry monitoring program. One file was a copy of a worker performance review.

The two remaining documents were summaries of the SEC petitioner’s findings associated with 

the recently submitted material. 

Section 2 of this report summarizes SC&A’s review of the documentation in the context of the 

three general concerns reported to the Advisory Board by the SSFL petitioner in August 2019. 

Attachment A provides a more detailed review of the specific statements made by the SEC 

petitioner and their reported findings submitted to the Advisory Board. 
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2 Summary of SC&A Review

2.1 Monitoring of site remediation workers

The SEC petitioner states (ABRWH, 2010, p. 91): 

under the FOIA we obtained several of the requests from Boeing to be exempted 

from Department of Energy's requirements to monitor site remediation workers.

Those are dated between 1991 into the 2000s. So they coincide with the site 

remediation processes and the transuranic work that we're talking about. 

The Department of Energy expected compliance from the contractor, but they 

gave Boeing a loophole to exemption. 

SC&A reviewed the largest file of the petitioner’s document submittal, consisting of 1,276 

pages, that contains radiation protection program descriptions, procedures, incident reports, and 

other documents to determine if there was any information that would indicate SSFL workers 

were not being properly monitored and thus sufficiently accurate dose reconstruction may not be 

feasible.

Much of the documentation contained in the 1,276-page file consisted of radiation protection 

plans and procedures, letters related to compliance with DOE requirements, and program 

certification. Upon review of this documentation, SC&A did not identify information that would 

suggest that workers were not being monitored. Much of the documentation is related to DOE 

seeking to require SSFL to obtain certification for the DOELAP internal dosimetry program. 

However, SC&A did not identify information in the DOE correspondence to suggest that the 

monitoring program was otherwise inadequate. This is with the noted exception of the 2-year 

period in which bioassay results were invalidated due to the involvement of CEP as the bioassay 

vendor. 

The submitted documents included a Boeing Company letter (Boeing, 2001) in which the Boeing 

Company (hereafter “Boeing”) offered data to support its position that it does not meet the 100 

millirem (mrem)/year committed effective dose equivalent limit requiring participation in the 

DOELAP program for internal dosimetry. The data provided represented alpha emitters in 

ambient conditions from 1991 to 2000. In building 20 (also known as the Rockwell International 

Hot Lab, or RIHL), the letter states, “the primary source of the airborne contamination was 

related to the cleaning and demolition of the cells, which had been used for decladding of nuclear 

fuels. This work was completed by mid-1996” (Boeing, 2001, p. 3). Boeing noted that, upon 

completion of the decontamination and decommissioning (D&D) work, “no alpha emitters have 

been detected in the facility” (Boeing, 2001, p. 6). Regarding the Remote Materials Handling 

Facility (RMHF), the letter states: 

“While some projects involve relatively low levels of alpha contamination, the 

media (drainline and tank debris) are of large particle size and are not readily 

respirable (as demonstrated by previous experience with the materials). As the 

facility nears the end of its life, it will be decontaminated and decommissioned.

(Boeing, 2001, p. 7) 
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In addition, alpha contamination had not been found in Building 24 (Boeing, 2001, p. 8). Boeing 

noted that 236 persons participated in the bioassay program from 1989 through 1999 (Boeing, 

2001, p. 5). Boeing asserted that because past D&D activities had not caused significant intakes 

of radioactive materials, and the nature of future projects would not cause such uptakes, the 100 

mrem committed effective dose equivalent limit requiring participation in the DOELAP program 

for internal dosimetry would not be exceeded; therefore, Boeing’s participation in the DOELAP 

program was not required. However, Boeing did note that “we consider it prudent to monitor 

personnel we consider most likely to receive internal exposures” (Boeing, 2001, pp. 8–9). 

Regarding the presence of thorium, a radiation protection activity report for November 1994 

states the following: 

Numerous laboratory containers of chemical compounds that contain uranium and 

thorium, (“generally licensed” radioactive materials), are being discovered in 

various Rocketdyne laboratories. A search and collection is being done for these 

items, and 25 items have been collected, inventoried, and transferred to RP&HPS 

[Radiation Protection and Health Physics Services] control. Possible beneficial 

recycling/disposal options are being investigated.” (Rockwell, 1994, p. 3) 

SC&A reviewed all of the activity reports for the subsequent year (1995) to see if there was any 

followup information regarding containers holding uranium and thorium but did not discover any 

additional information. More importantly, SC&A did not identify evidence of operational 

activities involving thorium. The discovery of waste packages containing uranium and thorium is 

consistent with D&D activities known to have occurred at SSFL. Dose reconstruction methods 

for thorium to such exposures are currently in development by NIOSH and will be taken under 

consideration by the SSFL work group as well as the full Advisory Board. Intakes of uranium are 

currently reconstructed using individual bioassay results or, in the absence of such results, 

coworker intakes developed in ORAUT-OTIB-0080 based on operational urinalysis data. 

Another activity report from 1995 shows that there was a plutonium inventory in the Radioactive 

Material Disposal Facility (RMDF), including in waste packages, RIHL drainline debris, and the 

former RIHL Liquid Waste Holdup Tank (Rockwell, 1995b, p. 3). Such an inventory is 

consistent with the D&D activities that were occurring at SSFL during this period. SC&A notes 

that coworker intakes of plutonium have been developed in ORAUT-OTIB-0080 for workers 

who were not monitored directly. 

Nothing in the provided documentation suggests that there was an inadequate internal dosimetry 

program at SSFL, or that the overall radiation program was not in compliance with regulatory 

requirements. In a DOE letter dated August 14, 1998, DOE stated that SSFL’s internal dosimetry 

program is in compliance with DOE requirements (DOE, 1998, PDF p. 108). A 1995 letter from 

Rockwell International shows that, with some minor adjustments to the checklists and courses 

(not specified in the letter), the SSFL radiation worker training programs met DOE Rad Worker 

II training requirements (Rockwell, 1995a, p. 1). 

2.2 TRUMP-S program

As part of its review of petitioner-provided documents, SC&A reviewed the provided “Technical 

Progress Report Private Sector Initiative Between the United States and Japan January 1993-
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September 1998” (Boeing, 1998). The Private Sector Initiatives Program began in mid-1987 to, 

in part, “provide a basis for U.S. vendor participation in advanced Japanese liquid metal reactor 

(LMR) designs” (Boeing, 1998, p. v). From 1994 through September 1997, the TRUMP-S 

process was demonstrated at a 1/6000 and 1/2000 scale. The TRUMP-S process: 

was demonstrated at MURR [Missouri University Research Reactor] by MURR, 

UMC [University of Missouri at Columbia], CRIEPI [Central Research Institute 

of Electric Power Industry (Japan)], KHI [Kawasaki Heavy Industries] and 

Boeing personnel. The demonstration tests utilized simulated PUREX wastes 

consisting of nonradioactive components with actinides added in the proper 

proportions to simulate the waste generated when Japan’s PUREX plant is 

processing 48,000 megaWatt day/tonne burnup PWR fuel. [Boeing, 1998, p. 1] 

The TRUMP-S program objectives after 1988 were as follows:

1. 1988–1990: Measure chemical and electrochemical properties of actinides and rare earths 

to predict actinide separation efficiency and purity for pyrochemical partitioning. 

2. 1991–1993: Determine the americium electrochemical properties and measured actinide 

separation efficiency and product purity for pyrochemical partitioning of PUREX waste. 

3. 1994–1997: Process demonstration of pyropartitioning steps and develop a computer 

code to model the process as developed and to perform a pyropartitioning process 

engineering feasibility study.

Although the progress report did not identify the specific location at which these objectives were 

met, or who performed them, the report clearly states that the process was demonstrated at 

MURR. Per the report, Boeing personnel were present during the tests at MURR (Boeing, 1998, 

p. 1). 

The progress report references six previous technical progress reports that date back to July 

1987. Four of these reports are in the Site Research Database (SRDB), available to SC&A, 

NIOSH and the Advisory Board. One of reports, for the period January 1989–December 1989, is 

discussed in the SC&A memorandum dated July 25, 2019, “Evaluation of Petitioner-Specific 

Concerns Regarding SEC-00235” (SC&A, 2019b), and therefore is not discussed further in this 

report. 

Based on the technical progress report for 1990 (Rockwell, 1993a), there were some TRUMP-S 

tests performed in Japan, but planned activities at SSFL were not conducted due to public 

pressure regarding the RIHL. Instead, an alpha lab including gloveboxes was constructed at 

MURR to perform the work. This is confirmed in the 1991 progress report (Rockwell 1993b), 

which states: 

Electrochemical test cells and methodology were developed at the Rockwell Santa 

Susana Field Laboratory (SSFL) using rare earths in the inert atmosphere 

glovebox. This technology was transferred to the [MURR] Alpha Laboratory for 

use with actinides by interchange of laboratory personnel. [Rockwell, 1993b, p. 3] 
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A computer program on an IBM system was installed at SSFL and MURR. Safety upgrades were 

made at MURR. These activities match the 1988–1990 TRUMP-S program objectives; however, 

no information is currently available that suggests the actual tests involving the handling of TRU 

material occurred at SSFL.

As described in the technical progress report for 1992 (Rockwell 1993c, p. vi), data 

interpretation was conducted and several studies were performed, but the location is not 

specifically identified. However, current documentation does note that TRU waste was generated 

at MURR (“Appendix 4.10.2.2,” 2002, PDF p. 3).

According to the 1998 Boeing report provided by the petitioner, during 1994 through September 

1997, the TRUMP-S process “was demonstrated at MURR by MURR, UMC, CRIEPI, KHI, and 

Boeing personnel” (Boeing, 1998, p. 1) The report continues (p. 1) that “a consistent set of 

electrochemical and physical data were required to develop the pyropartitioning process; these 

data were measured and the TRUMP-S pyropartitioning process was developed and tested to 

show that actinides could be separated from PUREX wastes”; these activities match the 

TRUMP-S program objectives for 1991–1993. Finally, the report states (p. 2) that “computer 

programs were developed to simulate the pyropartitioning process.” This confirms that the 

TRUMP-S program objectives for 1994–1997 were accomplished. Taken together, these quoted 

passages demonstrate that the TRUMP-S process was demonstrated at MURR, with some 

supporting nonradiological activities possibly occurring at SSFL. 

SC&A identified a document (Schrag, n.d.) summarizing a meeting at SSFL regarding 

TRU/mixed waste that was planned to be generated in late 1989/early 1990 from TRU 

partitioning tests. The meeting summary is a planning document; therefore, it does not state that 

such tests involving generation of TRU waste had yet occurred. The purpose of the meeting was 

to develop the necessary steps on how to plan for the management and disposal of the waste. 

This document did not identify where the waste would be generated.

SC&A identified another document (“Appendix 4.10.2.2,” 2002) that provides the compliance 

methodology for TRU waste generated at MURR, but it did not identify where the waste would 

be sent to be managed, stored, and prepared for eventual disposal.

SC&A concludes, after reviewing the status reports, that radiological operations associated with 

TRUMP-S were conducted at MURR and not at SSFL for the duration of the project. SSFL 

personnel were present at MURR to observe and take part in the technology demonstration 

activities. While it is not clear from the available documentation where the TRUMP-S equipment 

and radiological waste was sent at the end of the project for dispositioning and eventual disposal, 

SC&A did not identify evidence that it was sent back to SSFL. Nonetheless, TRU waste was 

present at SSFL as a result of legacy waste management and D&D activities. This TRU waste is 

discussed in the next section.

2.3 Transuranic waste management at SSFL

The SEC petitioner stated at the August 21, 2019, ABRWH meeting that TRU waste was 

generated between 2002 and 2008 and that TRU waste has been stored up to 20 years. The 

petitioner states that the documentation that was submitted “shows the presence of americium 

and thorium onsite well into the 2000s” (ABRWH, 2019, p. 91). 
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The documentation that the SEC petitioner submitted to the Advisory Board and NIOSH 

included three acceptable knowledge summaries that describe TRU waste streams that were 

managed at SSFL. One acceptable knowledge report shows that, between 1993 and 1995, a new 

TRU waste stream, “consisting of residue removed from the hot cell drain lines, was 

accumulated between 1993 and 1995 during the D&D of the Hot Laboratory” (Boeing, 2002, 

PDF p. 21). Legacy TRU wastes from past SSFL operations also were managed at SSFL after 

1988. Waste characterization and repackaging took place at SSFL in a temporary sampling and 

repackaging facility that is described as follows:

The facility consisted of a HEPA-filtered, fire-retardant plastic enclosure that was 

located at the bottom of a HEPA-ventilated storage vault within a radiologically 

controlled facility. . . . This configuration provided a double-containment working 

environment. 

The specific-activity of all materials, including the RH waste, was sufficiently 

low that personnel could work with the material directly. All TRU 

characterization and repackaging activities were performed within this facility by 

personnel using double layers of personal protective clothing, full respirators with 

air lines, shielded work areas, and procedures that minimized exposures were 

based on pre-operations mockup testing and process hazards analyses. Other 

protective measures included continuous air monitoring, frequent surveys, 

extensive personal dosimetry, and a clear tent top for observation. Multiple plastic 

layers were used within the enclosure to allow change-out for contamination 

control, and five video cameras were installed to document operations. [Kneff et 

al., 2004, p-. 8–9] 

All TRU waste was transported to Hanford in December 2002 in one shipping campaign, 

eliminating the TRU waste inventory at SSFL.

All TRU waste streams that contain plutonium are expected to contain americium. Such D&D 

activities were to be expected at SSFL, and dose reconstruction methods for americium are 

currently under development by NIOSH and will be taken under consideration by the SSFL work 

group and the Advisory Board. As noted in section 2.1, coworker intakes of plutonium have been 

developed in ORAUT-OTIB-0080 for workers who were not monitored directly. 

In summary, SC&A found no evidence that TRU waste was generated after 1988 due to post1988 operations other than remediation activities. TRU wastes generated and managed at SSFL 

after 1988 are related to legacy (pre-1989) operations as well as D&D activities that occurred 

after 1988. 
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3 Summary Conclusions

SC&A reviewed the documentation provided to NIOSH by the SEC petitioner in August 2019 to 

address petitioner comments in the following areas: monitoring of site remediation workers, 

exposures related to the TRUMP-S program, and exposures related to the management of TRU 

waste at SSFL.

SC&A found no evidence in the documentation that the SSFL operating contractor did not 

monitor remediation workers who needed monitoring or that such monitoring was inadequate 

(with the exception of the 2-year period when CEP operated as the bioassay contractor for 

SSFL). While Boeing was contesting DOE’s determination that they needed to certify the 

internal dosimetry monitoring program through DOELAP, the internal dosimetry monitoring 

program at SSFL did not cease. In fact, in 1998 DOE stated that SSFL’s internal dosimetry 

program was in compliance with DOE requirements. SC&A also did not find any evidence that 

the radiation worker training programs did not meet DOE requirements. Regarding the presence 

of americium, residual amounts of americium would be expected after 1988 due to the plutonium 

inventory present at SSFL that had to be managed during the process of facility 

decommissioning. Regarding the presence of thorium, some containers containing thorium 

materials were found (Rockwell, 1994), but no other information about these containers was 

identified. Such thorium inventory would be expected during the facility D&D period, and the 

presence of such material does not necessarily indicate that operations-related thorium activities 

and exposures continued at SSFL post 1988.

SC&A found no evidence in the documentation that radiological operations occurred at SSFL 

that were related to TRUMP-S. All radiological activities associated with TRUMP-S appear to 

have occurred at MURR, with some SSFL personnel present to observe the activities. Such 

exposures are not relevant to SEC-00235. SC&A could not find specific information concerning 

the disposition of equipment and wastes generated as a result of the TRUMP-S program. 

However, no evidence was identified that the material was sent back to SSFL for any 

reclamation or processing activities that would represent a different exposure potential than 

typical D&D activities. 

In summary, SC&A found no evidence in the currently available documentation that TRU waste 

was generated after 1988 due to post-1988 operations. TRU waste generated and managed at 

SSFL after 1988 appears solely related to legacy (pre-1989) operations and D&D activities that 

occurred after 1988. Management activities related to TRU waste would have included 

packaging any TRU waste generated during decommissioning activities, managing TRU waste 

generated during pre-1988 operations, performing nondestructive assays of TRU waste packages, 

and repackaging and shipping of the TRU waste packages. Because TRU waste packages contain 

plutonium, it is expected that a buildup of americium would occur in the waste packages. Dose 

reconstruction methods for americium and thorium are currently under development by NIOSH 

and will be taken under consideration by the SSFL work group and the Advisory Board. Methods 

for reconstructing intakes to plutonium, uranium, and fission products have been developed 

based on operational urinalysis data and are discussed in ORAUT-OTIB-0080.
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4 References

Advisory Board on Radiation and Worker Health (ABRWH). (2019). Advisory Board on 

Radiation and Worker Health 130th meeting, Wednesday, August 21, 2019 [Transcript]. 

Retrieved from https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2019/tr082119-508.pdf 

Appendix 4.10.2.2 Compliance methodology for TRU waste from Missouri University Research 

Reactor (MURR) Columbia, MO (rev. 18). (2002). Retrieved from SRDB Ref. ID 107393 

The Boeing Company (Boeing). (1998). Technical progress report private sector initiative 

between the United States and Japan January 1993-September 1998 (RD98-372). Retrieved 

from SRDB Ref. ID 158384 

The Boeing Company (Boeing). (2001, April 20). DOELAP for radiobioassay; Supporting data 

for exception, DOE operations at the Santa Susana Field Laboratory [Letter from James G. 

Barnes, Boeing, to E. Njoku, U.S. Department of Energy Oakland Operations Office]. Retrieved 

from “09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf,” PDF pp. 42–50

The Boeing Company (Boeing). (2002). Working draft: TRU waste stream C1-B55: Acceptable 

knowledge summary report (EID-04711, rev. A). Retrieved from file 

“EID_04711_TRU_NEW_Sep2019.pdf,” PDF pp. 3–85 

CORE Advocacy for Nuclear & Aerospace Workers (CORE Advocacy). (2019). SEC 00235 

Santa Susana Field Laboratory (SSFL) supplement to document: EID-04711: Closure of ETEC, 

TRU waste stream C1-B55 acceptable knowledge summary report The Boeing Company, 2002. 

Retrieved from “EID_04711_TRU_NEW_Sep2019.pdf,” PDF pp. 1–2 

Fluor Hanford, Inc. (Fluor). (2007). Acceptable knowledge summary report for the Energy 

Technology Engineering Center transuranic mixed debris, transuranic mixed solidified liquids, 

and low-level mixed organic liquids waste stream (WMP-32570, rev. 0). Retrieved from 

“05_WMP-32570_(ETEC)_Rv0_Final.pdf” 

Fluor Hanford, Inc. (Fluor). (2008). Acceptable knowledge document for the Energy Technology 

Engineering Center debris, RLETECD (HNF-34702, rev. 0). Retrieved from “04_HNF34702_REV_0_ACCEPTABLE_KNOWLEDGE_DOCUMENT_FOR_THE_ETEC_DEBRIS,_

RLETECD_04-08-08.pdf” 

Kneff, D. W., Waite, P. H., Spenard, M., Amar, R. C., Lee, M. E., & Marshall, R. A. (2004). 

TRU waste removal from ETEC, a small-quantity generator site. Paper WM-4412 presented at 

the WM’04 Conference, February 29–March 4, 2004, Tucson, AZ. Retrieved from 

http://archive.wmsym.org/2004/pdfs/4412.pdf 

National Institute for Occupational Safety and Health (NIOSH). (2014). Internal coworker 

dosimetry data for Area IV of the Santa Susana Field Laboratory and the De Soto Avenue 

Facility (ORAUT-OTIB-0080, rev. 00). Retrieved from 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t80-r0.pdf 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

National Institute for Occupational Safety and Health (NIOSH). (2017). SEC petition evaluation 

report, Petition SEC-00235, Area IV of the Santa Susana Field Laboratory. Retrieved from 

SRDB Ref. ID 174360 

Rockwell International (Rockwell). (1993a). Technical progress report private sector initiatives 

between the United States and Japan January 1990 – December 1990 (RI/RD93-150). Retrieved 

from SRDB Ref. ID 158380 

Rockwell International (Rockwell). (1993b). Technical progress report private sector initiatives 

between the United States and Japan, January 1991 – December 1991 (RI/RD93-159). Retrieved 

from SRDB Ref. ID 158382 

Rockwell International (Rockwell). (1993c). Technical progress report private sector initiatives 

between the United States and Japan January 1992 – December 1992 (RI/RD93-167). Retrieved 

from SRDB Ref. ID 158383 

Rockwell International (Rockwell). (1994, November 28). Activity report for Radiation 

Protection and Health Physics Services, month ending 11/30/94 [Internal letter]. Retrieved from 

“09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf,” PDF pp. 1006–1011 

Rockwell International (Rockwell). (1995a, October 11). DOE Rad Worker II equivalency

[Internal letter from J.G. Barnes]. Retrieved from “09_DOELAP_COMPLIANCE_emcbc-2018-

00694-f blaze.pdf,” PDF pp. 129–132 

Rockwell International (Rockwell). (1995b, August 28). Activity report for Radiation Protection 

and Health Physics Services, month ending 8/31/95 [Internal letter]. Retrieved from 

“09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf,” PDF pp. 53–60 

Rockwell International (Rockwell). (1995c, May 23). Activity report for Radiation Protection 

and Health Physics Services, month ending 5/31/95 [Internal letter]. Retrieved from 

“09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf,” PDF pp. 73–78 

Rockwell International (Rockwell). (1995d, June 26). Activity report for Radiation Protection 

and Health Physics Services, month ending 6/30/95 [Internal letter]. Retrieved from 

“09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf,” PDF pp. 79–83 

SC&A, Inc. (2014). A review of ORAUT-OTIB-0080, rev. 00: Internal coworker dosimetry data 

for Area IV of the Santa Susana Field Laboratory and the DeSoto Avenue Facility (SCA-TROTIB2014-0080, rev. 0). Retrieved from SRDB Ref. ID 157630 

SC&A, Inc. (2019a). Review of remaining internal dose topics related to the evaluation of 

SEC-00235 at the Santa Susana Field Laboratory (SCA-TR-2019-SEC002, rev. 0). Retrieved 

from SRDB Ref. ID 175490 

SC&A, Inc. (2019b). Evaluation of petitioner-specific concerns regarding SEC-00235

[Memorandum]. Retrieved from https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scassflsec235-072519-508.pdf 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Schrag, F. C. (n.d.). TRUMP-S project waste highlights 1989–1990 [Excerpt from a document 

by F.C. Schrag, Acting Manager, Nuclear Operations]. Retrieved from SRDB Ref. ID 177909 

U.S. Department of Energy (DOE). (1998, August 14). Internal dosimetry program review

[Letter from Hannibal Joma, ETEC Site Office Manager, DOE, to Mark Gabler, Director, 

Energy Technology Engineering Center, Boeing, with enclosure, “Internal dosimetry program 

review at the Energy Technology Engineering Center”]. Retrieved from pdf file 

09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze, PDF pp. 108–128 
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Attachment A: Responses to Specific SSFL Petitioner Concerns

Presented during the 2019 Advisory Board Meeting and Provided with 

the Document Submittal

Comment 1 2

2 Comments numbers are arbitrarily assigned to facilitate discussion.

Petitioner comment 

And it's my understanding that the Site Profile does not reference transuranic 

waste combustion practices, which is a process that began at the site in 1974. And 

documentation suggests that it continued until 1998. [ABRWH, 2019, p. 88] 

Response 

SC&A was unable to determine from the documents submitted by CORE Advocacy what is 

being referred to in this comment. It is possible the comment was intended to refer to the 

TRUMP-S program, which is discussed in section 2.2 of this report as well as previous SC&A

analyses (2019a, 2019b). 

References: SC&A (2019a, 2019b) 

Comment 2

Petitioner comment 

SC&A has already acknowledged that there were americium separation processes 

at the site until 1993. In their own document. [ABRWH, 2019, p. 89] 

Response 

SC&A assumes that this comment was made in reference to its review of ORAUT-OTIB-0080, 

which provides the internal dose reconstruction methods for unmonitored workers at SSFL 

(SC&A, 2014). In that review, SC&A noted that 24 americium bioassay results were noted for 

the period from the late 1960s through 1993. There were americium bioassay samples for three 

individuals after 1988. One individual was a claimant, and a document in the claim file notes that 

the worker was at Argonne National Laboratory – East during the period when the americium 

samples were taken. Therefore, the exposure was not likely related to SSFL. Further information 

is not currently available for the other two individuals, though it is possible the individuals were 

sampled due to involvement in the TRUMP-S radiological tests occurring at MURR. None of the 

americium bioassay samples after 1988 were reported as positive. 

Reference: SC&A (2014) 

 
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Comment 3

Petitioner comment 

And NIOSH has already acknowledged DAC emissions data in 1995 that were 

positive for americium and thorium, which suggests an operational use for those 

materials. [ABRWH, 2019, p. 89] 

Response 

The “Activity Report for Radiation Protection and Health Physics Services, month ending 

11/30/94” (Rockwell, 1994, PDF p. 1006), states the following regarding uranium and thorium 

chemicals: 

Numerous laboratory containers of chemical compounds that contain uranium and 

thorium, (“generally licensed” radioactive materials), are being discovered in 

various Rocketdyne laboratories. A search and collection is being done for these 

items, and 25 items have been collected, inventoried, and transferred to RP&HPS 

control. Possible beneficial recycling/disposal options are being investigated. 

[Rockwell, 1994, p. 3, PDF p. 1006] 

SC&A was unable to identify any followup information regarding this material. 

The “Activity Report for Radiation Protection and Health Physics Services, month ending 

8/31/95” (Rockwell, 1995b, PDF p. 55), states that an evaluation was conducted to determine the 

mass of plutonium contained in the RMDF. This included waste packages, the RIHL drainline 

debris, and the former RIHL Liquid Waste Holdup Tank. This activity report reevaluates the 

amount of plutonium in a drum, with a result of 79 microcuries cesium-137, which led the 

personnel to conclude that the previous estimate was too high. In a previous activity report for 

May 31, 1995 (Rockwell, 1995c, PDF p. 74), it was estimated that the plutonium inventory in the 

building could range from 2 grams to 29 grams. In the following month (June) (Rockwell, 

1995d, PDF p. 81), a re-estimate showed the plutonium inventory to be about 4.8 grams, not 

including the drainline debris.

SC&A agrees that thorium and americium materials were present at SSFL in the post-1988 

period. Furthermore, SC&A agrees that exposure to such materials via stewardship of waste 

materials and typical D&D activities at the time presents a source of exposure that must be taken 

into account during dose reconstruction. Dose reconstruction methods for americium and 

thorium are under development and will be taken under consideration by the SSFL work group 

and the Advisory Board. 

References: Rockwell (1994, 1995b, 1995c, 1995d) 

Comment 4

Petitioner comment 

And we've just been talking about whole body count data, but I've already 

supplied the documentation showing that they didn't report whole body counting 

from Helgeson. [ABRWH, 2019, p. 89] 
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Response 

SC&A was unable to determine from the documents submitted by CORE Advocacy what is 

being referred to in this comment. However, SC&A notes that the coworker intakes for 

plutonium, uranium, and mixed fission products are based on urinalysis results rather than whole 

body counts. Dose reconstruction methods for americium and thorium are under development 

and will be taken under consideration by the SSFL work group and the Advisory Board. 

Reference: NIOSH (2014) 

Comment 5

Petitioner comment 

And I think that the information that we've located establishes operations to at 

least 2008, potentially 2010, along with the new evidence that suggest site 

remediation workers were, and currently are, insufficiently monitored. [ABRWH, 

2019, pp. 89–90] 

Response 

As discussed in section 2.1 of this report, SC&A did not identify evidence that SSFL remediation 

workers were insufficiently or inadequately monitored, with the exception of the period during 

which CEP was the bioassay contractor for SSFL. Unmonitored intakes have been developed for 

plutonium, uranium, and fission products in ORAUT-OTIB-0080. Dose reconstruction methods 

for americium and thorium are under development. 

Comment 6

Petitioner comment 

So, the documentation that I'll be submitting today is a Boeing technical progress 

report that details TRUMP-S operations Area IV from 1993 until 1998. And 

apparently what it looks like is that after the public scrutiny died down and things 

weren't so heated, they brought the program back. That document provides a DOE 

contract number. And indicates that Boeing participated in Steps 4, 5 and 6 of the 

TRUMP-S transuranic separation processes. Which involve the reductive 

extraction and removal of metals from the molten salt phase of the process, the 

reductive extraction to remove actinides and rare earths from the active metals, 

followed by electro-refining, and the reductive extraction followed by electrode 

disposition to separate remaining transuranics from rare earths. So it doesn't look 

like their activities were just confined to non-radioactive processes. [ABRWH, 

2019, p. 90] 

Response 

SC&A reviewed the provided report, “Technical Progress Report Private Sector Initiative 

between the United States and Japan January 1993-September 1998” (Boeing, 1998), that is the 

subject of the petitioner’s comment. As stated in section 2.2 of this report, program objectives for 

the time period after 1988 were: (1) for 1988–1990, measure chemical and electrochemical 

properties of actinides and rare earths to predict actinide separation efficiency and purity for 
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pyrochemical partitioning; (2) for 1991–1993, determine the americium electrochemical 

properties and measured actinide separation efficiency and product purity for pyrochemical 

partitioning of PUREX waste; and (3) for 1994–1997, process demonstration of pyropartitioning 

steps, and develop a computer code to model the process as developed and to perform a 

pyropartitioning process engineering feasibility study (Boeing,1998, p. 3). 

Based on the technical progress report for 1990 (Rockwell, 1993a), there were some tests 

performed in Japan, but planned activities at SSFL were not conducted due to public pressure, 

and instead an alpha lab including gloveboxes was constructed at MURR to perform the work. 

This is confirmed in the 1991 report, which states that “electrochemical test cells and 

methodology were developed at the Rockwell Santa Susana Field Laboratory (SSFL) using rare 

earths in the inert atmosphere glovebox. This technology was transferred to the [MURR] Alpha 

Laboratory for use with actinides by interchange of laboratory personnel” (Rockwell 1993b, 

p. 3). A computer program on an IBM system was installed at SSFL and MURR. Safety 

upgrades were made at MURR. These activities meet the 1988–1990 TRUMP-S program 

objectives. 

As described in the technical progress report for 1992 (Rockwell, 1993c), data interpretation was 

conducted and several studies were performed, but the location is not identified. Evidence 

suggests that TRU waste associated with TRUMP-S was generated at MURR (“Appendix 

4.10.2.2,” 2002, PDF p. 3). 

According to the report provided by the petitioner, during 1994 through September 1997, the 

TRUMP-S process “was demonstrated at MURR by MURR, UMC, CRIEPI, KHI, and Boeing 

personnel” (Boeing, 1998, p. 1). Later, “a consistent set of electrochemical and physical data 

were required to develop the pyropartitioning process; these data were measured and the 

TRUMP-S pyropartitioning process was developed and tested to show that actinides could be 

separated from PUREX wastes” (Boeing, 1998, p. 1). These activities match the 1991–1993 

TRUMP-S program objectives. Finally, the report states that “computer programs were 

developed to simulate the pyropartitioning process,” which matches the 1994–1997 TRUMP-S 

program objectives. 

According to TRUMP-S project waste highlights from 1989–1990 (Schrag, n.d., PDF p. 2): 

A meeting was held with

 to discuss the disposition of the waste to be 

generated from the TRU partitioning tests. Since the waste will contain 

transuranics (Pu, Am, Np)) and cadmium, the waste generated in late 1989/early 

1990 will be TRU/mixed waste. will be in contact with 

 to determine what steps are needed to get a head start on the 

planning/disposal process. These steps were requested by as a 

requirement for the isotopes committee approval of the application to use 

radioactive materials. 

This highlight does not mention the location of where the wastes would be generated (at SSFL or 

at MURR). Because radiological operations associated with SSFL’s participation in the 
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TRUMP-S program were moved to MURR, it is logical to assume that the waste generated 

would also be packaged at MURR for eventual disposal. 

Another document “presents how records and database information (process knowledge) have 

been used to qualify seven drums of Missouri University Research Reactor (MURR) contacthandled (CH) transuranic (TRU) waste as payload for transport in the CNS 10-160B cask”

(“Appendix 4.10.2.2,” 2002, PDF p. 3). This document also states (PDF p. 7) that “The CH-TRU 

waste was generated over eight years using a total of 3.5627 grams of Neptunium-237, 1.4701 

grams of Plutonium-239, 2.4125 grams of Americium-241 and 6.097 grams of depleted 

Uranium.” Based on a later sentence discussing the weight to be packaged (PDF p. 10), it 

appears that the waste was located at MURR: “Based on the total measured weight of the 

individual payload containers and the 3 dunnage drums needed to complete the 10-drum payload, 

the MURR shall calculate total assembly weight and evaluate compliance with the maximum 

cask payload weight limit.” Attachment A of this document is titled, “MR 121A Transuranic 

Content Code and Chemical List for Missouri University Research Reactor” (“Appendix 

4.10.2.2,” 2002, PDF p. 12).

SC&A concludes, after reviewing the status reports, that radiological operations associated with 

TRUMP-S were conducted at MURR and not at SSFL for the duration of the project. SSFL 

personnel were present at MURR to observe and take part in the technology demonstration 

activities. Although it is not clear where equipment was sent at the end of the project, and where 

radiological waste, such as TRU waste, was sent for dispositioning, SC&A could not find 

evidence that the material was sent back to SSFL. However, as described in section 2.3, other 

TRU waste was generated, stored, and eventually repackaged at SSFL during the period of 

interest. Radiological controls to limit exposure included double layers of personal protective 

clothing, air supplied respirators, and shielded work locations. Contamination control was 

achieved using multiple plastic enclosures, frequent surveys, and continuous air monitoring. 

Direct radiological monitoring of the personnel involved was described as “extensive” (Kneff et 

al., 2004, p. 8). 

References: “Appendix 4.10.2.2” (2002), Boeing (1998), Kneff et al. (2004), Rockwell (1993a, 

1993b, 1993c), Schrag (n.d.)

Comment 7

Petitioner comment 

We'll also be submitting several accepted -- acceptable knowledge summaries that 

describe transuranic waste generation and processes between 2002 to 2008, and 

the storage of transuranics for up to 20 years, prior to the repacking operations 

that happened at Area IV. Which constituted an entire program that they started to 

deal with the site closure demands. 

While the waste was sitting at Santa Susana during waste shipping moratoriums, 

the plutonium content was quickly decaying to rising levels of americium. And 

that's expressed in this report.

We have a 2003 photograph of large transuranic cask in the site closure team at 

the Area IV radioactive materials handling facility and a 2003 employment 
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performance development summary which acknowledges workers participation in 

waste management and repacking processes.

So those documents will be supplied to the Work Group, NIOSH, and SC&A. 

And that shows the presence of americium and thorium onsite well into the 2000s. 

And processes that involve those materials. [ABRWH, 2019, pp. 90–91]

Response 

SC&A acknowledges that TRU waste was stored and managed at SSFL after 1988. A paper by 

Kneff et al. (2004) describes the challenges of managing TRU waste and how they were 

resolved. Waste characterization and repackaging took place at SSFL in a temporary sampling 

and repackaging facility. According to Kneff et al. (2004, pp. 8–9):

The facility consisted of a HEPA-filtered, fire-retardant plastic enclosure that was 

located at the bottom of a HEPA-ventilated storage vault within a radiologically 

controlled facility . . . This configuration provided a double-containment working 

environment. 

The specific-activity of all materials, including the RH waste, was sufficiently 

low that personnel could work with the material directly. All TRU 

characterization and repackaging activities were performed within this facility by 

personnel using double layers of personal protective clothing, full respirators with 

air lines, shielded work areas, and procedures that minimized exposures and were 

based on pre-operations mockup testing and process hazards analyses. Other 

protective measures included continuous air monitoring, frequent surveys,

extensive personal dosimetry, and a clear tent top for observation. Multiple plastic 

layers were used within the enclosure to allow change-out for contamination 

control, and five video cameras were installed to document operations.

Such activities are consistent with the D&D activities occurring at SSFL during this time. SC&A 

agrees that because the TRU waste contains plutonium, americium would increase in 

concentration over time in the TRU waste packages. SC&A agrees that TRU exposures, 

primarily from americium and plutonium, must be adequately addressed at SSFL to assure the 

feasibility of sufficiently accurate dose reconstruction. Unmonitored intakes have been 

developed for plutonium, uranium, and fission products in ORAUT-OTIB-0080. Dose 

reconstruction methods for americium and thorium are under development. 

Refer also to the responses to petitioner comments 11 through 21.

Reference: Kneff et al. (2004)

Comment 8

Petitioner comment 

And then just to touch on the site remediation workers, under the FOIA we 

obtained several of the requests from Boeing to be exempted from Department of 

Energy’s requirements to monitor site remediation workers. 
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Those are dated between 1991 into the 2000s. So they coincide with the site 

remediation processes and the transuranic work that we’re talking about. 

The Department of Energy expected compliance from the contractor, but they 

gave Boeing a loophole to exemption by basically letting them know, if an 

employee is affiliated with a non-radiological location, like Area I, II or III, or has 

a job title that is inconsistent with radiation work, then that employee is not 

required to be monitored.

Site remediation subcontractor employees are currently administratively affiliated 

with an Area II dispatch location. They’re routinely performing Area IV site 

remediation duties at radiological locations where historically radiation 

monitoring was required. [ABRWH, 2019, p. 91]

Response 

In a letter dated April 20, 2001 (Boeing, 2001), Boeing offered data to support its position that it 

did not meet the 100 mrem/year committed effective dose equivalent limit requiring participation 

in the DOELAP program for internal dosimetry. The data represents alpha emitters in ambient 

conditions from 1991 to 2000. In building 20 (RIHL), “the primary source of the airborne 

contamination was related to the cleaning and demolition of the cells, which had been used for 

decladding of nuclear fuels. This work was completed by mid-1996” (Boeing, 2001, p. 3). No 

alpha emitters have been detected in building 59 or building 24. In the RMHF, “while some 

projects involve relatively low levels of alpha contamination, the media (drainline and tank 

debris) are of large particle size and are not readily respirable (as demonstrated by previous 

experience with the materials). As the facility nears the end of its life, it will be decontaminated 

and decommissioned” (Boeing, 2001, p. 3). Boeing also states that 236 persons participated in 

the bioassay program from 1989 through 1999 (Boeing, 2001, p. 5).

PDF pages 108 through 128 of “09_DOELAP_COMPLIANCE_emcbc-2018-00694-f blaze.pdf” 

provided by the petitioner is a DOE letter dated August 14, 1998 (DOE, 1998), with an attached

review report stating that SSFL’s internal dosimetry program is in compliance with DOE 

requirements. PDF pages 129 through 132 of the same petitioner-provided file is a Rockwell 

International internal letter from October 11, 1995, that shows that, with some adjustments, the 

SSFL radiation worker training programs meet DOE Rad Worker II Training requirements

(Rockwell, 1995a). Other documents in this petitioner-provided file include radiation procedures, 

radiation protection plans, analyses to determine whether SSFL’s radiation protection program 

meets DOE requirements, and approvals of these documents that indicate a well-documented 

radiation protection program was in place that was consistent with DOE requirements. SC&A is 

not in a position to comment on any specific remediation worker’s monitoring protocol. 

However, SC&A acknowledges that workers would often rotate between SSFL site areas as 

needed, and so their affiliation with a specific area may not reflect the day-to-day operations.

References: Boeing (2001b), DOE (1998), Rockwell (1994, 1995a)
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Comment 9

Petitioner comment 

They are not currently being monitored for radiation. But the waste that is being 

generated from their activities, is surveyed for radioactivity. 

DOE and Boeing have abandoned these subcontractor employees. They refuse to 

acknowledge that this subcontractor is even present at the work site. And these 

workers are summarily disqualified from EEOICPA today. 

Even when they submit photos showing that they’re performing site remediation 

at Area IV radiological locations. One of them was transitioned to subcontractor 

status, sent in to Area II to be administratively affiliated with that. And his 

radiation protection ended within a few weeks of filing his initial EEOICPA 

claim. Right now today, while we’re having this meeting, he's doing site 

remediation at Area IV. [ABRWH, 2019, pp. 91–92] 

Response 

SC&A is not in a position to comment on any specific individual, their radiation monitoring, or 

their potential for exposure while working at SSFL. Nor is it under SC&A’s purview to comment 

on how any individual’s eligibility or employment is established under the Energy Employees 

Occupational Illness Compensation Program Act (EEOICPA). However, section 2.1 discusses

the SSFL monitoring program in the post-1988 time period, which is germane to a portion of the 

petitioner’s concern.

Comment 10

Petitioner comment 

In conclusion, we believe that the new documentation shows that americium and 

thorium were used in an operational capacity to at least 2008. And that this 

information even more firmly supports the original Class Definition that was 

intended to acknowledge all Department of Energy contractor and subcontractor 

employees at the site, based on issues that have already been verified. [ABRWH, 

2019, p. 92] 

Response 

SC&A concurs that thorium material and TRU waste was present and managed at SSFL after 

1988. SC&A also concurs that measurable amounts of TRU nuclides were emitted after 1988. 

However, these activities are related to management of legacy facilities and wastes, the 

decommissioning of facilities, and environmental remediation activities. No post-1988 

“operational” activities involving these radionuclides have been identified by SC&A. 

Nonetheless, exposure to these contaminants must be properly accounted for during dose 

reconstruction in a sufficiently accurate and scientifically defensible manner.

Dose reconstruction methods for americium and thorium are currently under development by 

NIOSH and will be taken under consideration by the SSFL work group and the Advisory Board. 
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Methods for reconstructing intakes to plutonium, uranium, and fission products have been 

developed based on operational urinalysis data and are discussed in ORAUT-OTIB-0080. 

Comment 11

Petitioner comment 

Page 14, Paragraph 2: 1989 - There are references to drums of TRU waste that 

were opened and repackaged in 1989, after the current SEC period. [CORE

Advocacy, 2019, p. 1] 

Response 

Section 2.1, page 14, of the referenced document states that, “The drums comprising this waste 

stream were repackaged in their current form in 1988-1989 based on the requirements of WIPP 

WAC Revision 2” (Boeing, 2002, PDF p. 17). However, section 2.2, page 14, states that, 

“Analytical data for this waste stream are limited to analyses conducted at the time the waste was 

packaged (1984-88) or repackaged (1988)” (Boeing, 2002, PDF p. 17). Section 4.1, page 22, 

states that 11 drums were reduced to four drums of solidified oil, with a fifth drum of TRU waste 

being repackaged in 1988. Shipment of all five of the drums in the waste stream was supposed to 

be completed in January 1989, but this did not occur due to a moratorium from the State of 

Idaho. Section 3.1, page 18, states that these drums were repackaged in December 1988 (PDF 

p. 21). It appears that repackaging was completed in 1988, with shipment planned in January 

1989. Additional documentation suggests that such material was not repackaged and shipped 

offsite until the early 2000s (Kneff et al., 2004, p. 8). Radiological controls in place during the 

repackaging operation are described in section 2.3 of this report. 

Reference: Boeing (2002), CORE Advocacy (2019), Kneff et al. (2004) 

Comment 12

Petitioner comment 

Page 18, Paragraph 3: 1993 to 1995 - Hot Lab D&D activities generated new 

TRU waste due to contaminated drain lines. [CORE Advocacy, 2019, p. 1] 

Response 

The cited paragraph states: 

Most product nuclear material, other nuclear material residue, and contaminated 

items were removed from the SSFL site by the end of 1989. The exceptions were 

several drums of transuranic-bearing waste from NMDF and Hot Laboratory 

operations, originally package for shipment to Rockwell Hanford and 

subsequently repackaged in December 1988 for shipment to the DOE Idaho site. 

One new waste stream, consisting of residue removed from the hot cell drain 

lines, was accumulated between 1993 and 1995 during the D&D of the Hot 

Laboratory. [Boeing, 2002, PDF p. 21) 
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Based on this paragraph, SC&A agrees that TRU waste was generated in 1993–1995 during 

typical D&D activities. This information is also confirmed and described by Kneff et al. (2004). 

Such exposures must be accounted for in dose reconstruction. Methods for reconstruction of 

americium exposure are currently under development. Methods for reconstructing plutonium 

exposure are contained in ORAUT-OTIB-0080. 

References: Boeing (2002), CORE Advocacy (2019), Kneff et al. (2004) 

Comment 13

Petitioner comment 

Page 22, Paragraph 1: During D&D, no distinction was made between waste 

materials that had been generated during various site programs. DOE / DOD 

waste was co-mingled. [CORE Advocacy, 2019, p. 1] 

Response 

SC&A acknowledges that wastes were comingled and that DOE determined that the waste was 

therefore acceptable for disposal at the Waste Isolation Pilot Plant (WIPP). TRU waste produced 

as a result of D&D activities was eventually sent to Hanford in the early 2000s. Any potential 

exposures to such material must be accounted for in dose reconstruction. Methods for 

reconstruction of americium exposure are currently under development. Methods for 

reconstructing plutonium exposure are contained in ORAUT-OTIB-0080. 

Reference: CORE Advocacy (2019) 

Comment 14

Petitioner comment 

Page 22, Paragraph 3: 2002 to 2003 - Waste scheduled for shipment in 1989 was 

delayed due to shipping moratoriums in Idaho. Requests to ship the drums in 1991 

/ 1992 were unsuccessful. As of 2002, the drums of TRU waste remained at 

SSFL. [Supportive documentation suggests the drums were transported to the 

Area IV RMHF for repacking by the SSFL Site Closure Team. See 2002 Photo of 

the Site Closure Team posing with a cask of TRU Waste, c. 2002 / 2003]. [CORE

Advocacy, 2019, p. 1] 

Response 

SC&A acknowledges that TRU waste remained in storage at SSFL after 1988. Kneff et al. 

(2004) described the challenges associated with TRU waste storage, management, and eventual 

repackaging at SSFL. The radiological conditions associated with the repackaging operation are 

well documented and included double layers of personal protective clothing, air-supplied 

respirators, continuous air monitoring, frequent surveying, multiple plastic enclosures, and 

extensive personnel monitoring. The petitioner also submitted “acceptable knowledge” 

documents related to TRU wastes generated from 1980 to 1995 that were transported from SSFL 

to Hanford for storage in December 2002 (Fluor 2007, 2008; Kneff et al., 2004). All of these 

waste streams are expected to contain americium isotopes. Such exposures must be accounted for 
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in dose reconstruction. Methods for reconstruction of americium exposure are currently under 

development. Methods for reconstructing plutonium exposure are contained in ORAUT-OTIB0080. 

References: CORE Advocacy (2019), Fluor (2007, 2008), Kneff et al. (2004) 

Comment 15

Petitioner comment 

Page 32, Section 5.2.3: There is a reference to 1995 CT Scans of TRU Waste 

Containers to verify the contents of “retrievably stored TRU drums at ETEC.” 

This suggests that TRU waste storage / repacking operations were ongoing after 

1988, and that there was the need to scan the drums to identify contents due to 

dubious record keeping and uncertainty about radionuclide content, in drums 

storage onsite since the 1980’s. [CORE Advocacy, 2019, p. 1] 

Response 

Computed tomography (CT) scans are a noninvasive means of evaluating contents in waste 

packages. SC&A acknowledges that TRU waste packages were stored at SSFL and were 

prepared for shipment offsite after 1988. Such exposures must be accounted for in dose 

reconstruction. Methods for reconstruction of americium exposure are currently under 

development. Methods for reconstructing plutonium exposure are contained in ORAUT-OTIB0080. 

Comment 16

Petitioner comment 

Page 42 & 43: Flowchart / Sequence - There are references to removal of excess 

Pu-U as part of the process involving TRU waste handling. CORE Advocacy is 

uncertain whether this is a reference to TRU Waste Management and Separation 

Processes. However, if materials stored onsite since the 1980’s contained 

Plutonium (Pu), it seems that there may be some concern about rising levels of 

Americium-241 (Am-241). The flowchart describes waste handling and transport 

between various Area IV locations, and processes that involved repackaging of 

the materials. [CORE Advocacy, 2019, p. 2] 

Response 

As part of qualifying TRU waste streams for disposal, the generator must provide an estimate of 

the radionuclide content of the waste. The generator must account for the decay of plutonium 

isotopes. Given that americium is a decay product of plutonium, it is expected that the americium 

content would increase over time. Such exposures must be accounted for in dose reconstruction. 

Methods for reconstruction of americium exposure are currently under development. Methods 

for reconstructing plutonium exposure are contained in ORAUT-OTIB-0080. 
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Comment 17

Petitioner comment 

Page 54, Section 13.2: 1994 to 2002 Pu / Am-241 - The Report indicates that, in 

2002, the measurements of Pu / Am in the onsite TRU waste had to be repeated, 

because the original source data from measurements that were taken in 1994 

could not be located. “... a firm determination of the qualification of each of the 

drums cannot be made...” confirms that drum packaging and processes occurred 

at SSFL after 1998, and that the original measurements of radioactivity could not 

be located as of 2002. Additionally, the statement strongly suggests that Boeing 

may not have had a good handle on the condition or contents of TRU waste 

drums that had been generated and packaged prior to Boeing’s takeover of 

site operations in 1996. [CORE Advocacy, 2019, p. 2] 

Response 

The development of the “acceptable knowledge” package is part of the waste certification 

process for TRU waste transportation and disposal. DOE uses acceptable knowledge and 

characterization technologies to assess the contents of TRU waste streams as part of the 

certification process for disposal. Such exposures must be accounted for in dose reconstruction. 

Methods for reconstruction of americium exposure are currently under development. Methods 

for reconstructing plutonium exposure are contained in ORAUT-OTIB-0080. 

Comment 18

Petitioner comment 

Pages 55 & 56 Tables: Radionuclide Summaries for Drums at SSFL verify 

Am-241, in 2002. [CORE Advocacy, 2019, p. 2] 

Response 

SC&A acknowledges that TRU waste processed and stored at SSFL contains americium until 

such time as the waste is transported for disposal or to another DOE site for continued storage. 

Such exposures must be accounted for in dose reconstruction. Methods for reconstruction of 

americium exposure are currently under development. Methods for reconstructing plutonium 

exposure are contained in ORAUT-OTIB-0080. 

Comment 19

Petitioner comment 

Pages 58-70: References 

Several documents that were used as references in the Report may contain useful 

information regarding the presence of Pu / Am / TRU materials and operations at 

SSFL Area IV, after 1988. Several verify that these materials and processes 

occurred, simply by the title and date of the document. Although several 

documents are listed, here are two examples [commenter lists two references]. 

[CORE Advocacy, 2019, p. 2] 
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Response 

SC&A acknowledges that TRU waste was handled as part of typical D&D activities occurring at 

the site, waste material was also stored at SSFL until the waste was transported to the Hanford 

site for disposal. Such exposures must be accounted for in dose reconstruction. As stated 

previously, methods for reconstruction of americium exposure are currently under development. 

Methods for reconstructing plutonium exposure are contained in OTIB-0080. 

Comment 20

Petitioner comment 

Pages 74-81: Waste Road Maps - Provides brief summaries of source documents. 

[CORE Advocacy, 2019, p. 2] 

Response 

This list shows the documents the generator used in developing its acceptable knowledge report. 

SC&A acknowledges that the storage and management of waste materials (including TRU 

materials) occurred at SSFL post 1988. Furthermore, SC&A acknowledges that D&D activities 

would generate new streams of waste material, which must be accounted for in dose 

reconstruction. Methods for reconstruction of americium exposure are currently under 

development. Methods for reconstructing plutonium exposure are contained in ORAUT-OTIB0080. 

Comment 21

Petitioner comment 

Page 82: Additional Documentation to be Reviewed - References TRU Materials / 

Processes, post-1988. [CORE Advocacy, 2019, p. 2] 

Response 

SC&A acknowledges that TRU waste was handled as part of typical D&D activities occurring at 

the site, and that waste material was also stored at SSFL until the waste was transported to the 

Hanford Site for disposal. Such exposures must be accounted for in dose reconstruction. 

Methods for reconstruction of americium exposure are currently under development. Methods 

for reconstructing plutonium exposure are contained in ORAUT-OTIB-0080.