We evaluated the length of time (in days) between the reported monitoring End Date and the date of submission to REMS Of the 33 sites (including Service Centers), 14 have reported Special Individual activity since Of those 14 sites, all but a few have reported consistently in the three-year period. Of the 14 reporting sites, 6 of them have had turnarounds (number of days between end of monitoring and file submission) greater than 50 days in at least one of the three analyzed years. 45 days appears to report SI records appears to be a reasonable time frame to expect the sites to be able to collect and process and report the records Special Individual (SI) Reporting Analysis Summary 1

Using DNFSB personnel rosters as an indicator of the presence of Special Individuals (SI), we found fairly consistent reporting of SI’s where there was DNFSB personnel dose records. –There were at least three sites that reported DNFSB records at the end of the year in 2010, but did not submit the interim records during the year. The DOE O 231.1B directs them to submit during the year and at the end of the year. This issue appears to have improved for 2011 and –There was at least one site that reported interim DNFSB activity during a year but did not submit the annualized records of said activity. We are examining this more closely Special Individual (SI) Reporting Analysis Summary (continued) 2

Our initial focus for contacting sites centered on the sites that had no SI reports submitted in the last three years. Of the 19 in this category, all but 5 have responded to our inquiry. Of those that responded, 6 sites reported they do not badge Special Individuals at their site. They may issue regular visitor badges that are processed with the annual submittal. 7 sites state that they have no process to submit SI individuals 1 site states that if SI visits, they are not badged – because they will not be in exposure areas. Several sites mentioned that SI is a gray area and causes confusion. All sites would benefit from further communication regarding the requirements for reporting Special Individual (SI) Reporting Analysis Summary (continued) 3

Areas of concern: Awareness of the requirements Clarification of the distinction between reporting interim records versus reporting an annualized summary record and the requirement to report both Defining and identifying Special Individuals Reconciliation of interim records to annual records 2012 Special Individual (SI) Reporting Analysis Summary (continued) 4