Working Draft 

ISSUES MATRIX FOR THE SAVANNAH RIVER SITE 

SEC PETITION AND PETITION EVALUATION REPORT 

Contract Number 200-2009-28555 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

September 2009 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
INTRODUCTION 

This is a draft issues matrix for the Savannah River Site (SRS) SEC Petition and Petition 

Evaluation Report (ER), prepared pursuant to the Advisory Board of Radiation and Worker 

Health’s charge to SC&A to review the SRS SEC Petition (Petition number SEC-00103) and its 

associated ER, published by NIOSH on November 14, 2008, and the request of the Chair of the 

Working Group, Mark Griffon, that a first draft of an SEC matrix be prepared. 

This matrix is based in part on issues that are unresolved from the SC&A review of the SRS Site 

Profile and appear to be SEC issues at the present time, SC&A’s review of NIOSH’s ER of the 

SRS SEC petition published in November 2008, and SC&A’s preliminary review of the petition 

that was performed prior to the publication of the NIOSH ER. It also draws on interviews 

completed by SC&A to date as part of its SEC petition review. 

NIOSH continues to work on a number of issues after the publication of the ER, including 

thorium up to 1960, which was reserved in the ER; neutron data; and development of coworker 

models. SC&A is conducting interviews and document research in parallel with NIOSH’s work 

(logistically coordinated with NIOSH, so as to enable DOE to use its support resources as 

efficiently as possible). Additional issues may be added or issues may be removed from this 

SEC matrix as SC&A and NIOSH research proceeds and analyses are presented and discussed in 

Working Group meetings. 

It should be noted that the latest officially issued revision of the SRS technical basis document 

(TBD) is dated April 5, 2005. This is Revision 03 of the SRS TBD (ORAUT-TKBS-0003). 

Subsequent work was done with the intention of revising the TBD, but no revision has been 

published. A revision number “04-E” dated November 6, 2006, is available on the O-Drive and 

was discussed during Working Group meetings. We have referred to this in preparing this 

matrix. However, this is not an official version and is not available to the petitioners, so far as 

SC&A is aware. The latest version referred to in the ER is the April 5, 2005, revision (though it 

is incorrectly identified as Rev. 02, ER, p. 84). 

Reference is made to these earlier documents (including documentation connected to the TBD 

comment resolution process) only as necessary to establish the status of the issue in the SEC 

context, if such a reference is necessary beyond the discussion in the ER. 

Savannah River Site Issues Matrix 2 SC&A – September 9, 2009 

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matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are conducted.
Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

SEC 

Comment 

No. 

Issue Brief ER Section No. Issue Description 

TBD Matrix 

No. or 

Review 

Section No. 

ER Position 

1 Thorium – 

pre-1960 

7.1.1.8 NIOSH has reserved thorium dose 

reconstruction for the period up to December 31, 1959. The ER states that there are 224 urinalysis samples for thorium in 1956. No bioassay samples have been found after that (ER, p. 53). No data or coworker models have been provided. Issue is, in part, a carryover from the SC&A site profile review. No data have been provided either for construction or non-construction workers. 

1c. The NIOSH ER reserves the 

thorium internal dose-related data prior to 1960. There are currently no data for doing internal dose reconstruction for thorium.

NIOSH coworkealternatiSEC cla

2 Thorium from 

Jan 1, 1960 on 

7.1.1.8 Post-1960 thorium. This issue is 

partly a carry-over from the TBD. NIOSH has not provided thorium data for the period starting on January 1, 1960. There is no analysis showing that the production worker intakes of thorium in this period can be bounded. No analysis of the relationship of bounding dose for production workers to that of construction and maintenance workers has been provided. No job-specific analysis has been provided for differences among types of construction workers. 

1c. The ER states that in-vivo data are 

available post-1960. NIOSH also states “representative air monitoring data” are available for unencapsulated thorium before 1961. These would be used to bound doses for production workers “and therefore, for construction and maintenance trade workers” (ER, p. 54). 

Neither analysis been pro

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

3 RU 7.1.1.2 This issue is in part a carry-over 

from the SC&A TBD evaluation. While Table A-2 of the TBD contains some trace contaminant data for the FA line, it provides no references and no demonstration that they are bounding, or that data apply to all types of RU (involving both military and non-military isotope production), various enrichments of recycled uranium, and all periods. Some new trace contaminant data were published in Table 4-6 (p. 71) of Rev. 04-E of the TBD (unpublished). The data are from Crase and LaBone 2000. The issues relating to this and other cited data discussed in the SC&A TBD review have not been addressed in the ER. A timeline for the RU operations has not been published. No analysis of the relationship of production worker to construction and maintenance workers has been published. 

1a. ER does not contain trace 

contaminant data. It refers to the TBD for activity fractions (p. 46). 

In the Seresolutioplanning contamirevision largest iimpuritienriched that a geissued foto the Junotes, “OReconstRecycled be compnot yet b2009, th

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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NOTICE: All information protected by Privacy Act 5 USC §552a

Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

4 Trivalent 

actinides Am, 

Cm, Cf 

7.1.1.5, 7.1.1.6, 

7.1.1.7 

Trivalent actinides: americium, curium, and californium. There are no data for curium-244 until 1963 (ER Figure 7-1). Data analysis and co-worker models have not been provided for any period. Relevance of later data to earlier periods has not been established. Relationship between non-construction worker and construction worker intakes for trivalent radionuclides in the period before monitoring began and after monitoring began has not been established. Where NIOSH proposes to use gross alpha data (e.g. for Cf-252, method for selecting workers for assigning dose and selecting the radionuclide) have not been scientifically established. The resulting dose estimates would need to be examined for validity and reasonableness. Californium-252 assignment would also need to be reviewed in relation to spontaneous fission related organ doses (including neutrons from spontaneous fission after intake). 

1d. NIOSH proposes to use measured 

data or coworker models for estimating dose with sufficient accuracy (ER Sections 7.1.1.5 to 7.1.1.7). Since data were collected for all three trivalent radionuclides rather than each separately, NIOSH proposes to assign the result to Cf-252 as appropriate. (ER, p. 51) 

Remains reviews

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matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are con
Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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NOTICE: All information protected by Privacy Act 5 USC §552a

Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

5 Np-237 7.1.1.4 Data analysis and coworker model 

not provided. Adequacy of data for coworker model not established. Applicability of back-extrapolation of data from 1960s and after to pre1960 period not established. Relationship between construction worker and non-construction worker data not established. 

NIOSH proposes to use data for the workers who were monitored to reconstruct their dose and a coworker model for the rest. Data available from 1960 onward in claimant database. 

6 Fission and 

activation 

products 

7.1.1.9 Validity of back-extrapolation of 

Sr-90 data has not been established. Adequacy of fission product monitoring data for coworker model has not been established. Relationship of non-CW intake estimates to CW intake estimates for fission products has not been established. The proposed coworker model has not been published. 

ER states that strontium radioisotope monitoring began in the “late 1950s.” 

7 Co-60 7.1.1.10 Validity of use of FP data prior to 

1960 has not been established; relationship of non-CW data to CW data has not been established. Coworker model has not been published. 

1e. Individual bioassay data or 

coworker model based on claimant data will be used. Targets were encapsulated (comment in TBD matrix). 

The poteof encapJuly 7, 2notes. Taction itnot addr

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

8. Po-210 7.1.1.11 The coworker model has not been 

published. Incidents are not addressed. Relationship of CW to non-CW intakes has not been established. 

1e. Some bioassay data are available 

for the few workers involved, and a coworker model will be developed for those without individual data. 

9 Tritium 7.1.1.1 NIOSH has not demonstrated that 

the TBD approach of applying environmental doses to unmonitored workers (no badge, no bioassay), and reporting level to workers with external monitoring only, is suitable for unmonitored construction workers. NIOSH has not demonstrated that it has a bounding dose approach for tritium for CW. 

8. Bioassay data are available and 

unmonitored worker tritium intakes can be estimated by using the approach in the TBD. 

SC&A’s that CW those of periods. type. Aexamina

10 Special tritium 

compounds 

for CW 

ER does not discuss exposure of CW to special tritium compounds. Relationship of CW to non-CW exposure to special tritium compounds or some other means of bounding CW exposure to them needs to be established. OTIB0066, which discusses a method to calculate doses due to exposure to special tritium compounds, is not specific to SRS and does not discuss dose reconstruction issues 

8 ER refers to OTIB-0066 for 

special tritium compound exposure. 

SC&A’s bioassay periods, It is unchigher ecompoulives, or specificacompoudecomm

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

for such compounds specific to construction workers. 

11 Exotic 

radionuclides 

7.1.1.9 in 

part 

About 150 radionuclides were produced at SRS, and targets were fabricated there (TBD unpublished Revision 04-E, p. 25). No analysis of the production processes is provided; nor is there any description of incidents. The incident database is incomplete, which was one of SC&A’s findings in its TBD review (see below). The lack of analysis may be parallel to the situation at Y-12, where a large number of isotopes were produced, with the difference that at Y-12, they were produced in accelerators, and at SRS, they were produced in reactors. No documentation of the encapsulation processes is provided. The exceptions to the coverage of radionuclides by whole-body counting are not discussed. There is no discussion of whether any of the target materials were themselves radioactive. 

1e. and 1f. No explicit discussion of these 150 

radionuclides is provided. Revision 04-E of the TBD states that “potential for intake was minimal” because targets were encapsulated and irradiated targets were shipped offsite for product recovery (p. 25). Whole-body counting would take account of “most” special radionuclides, including Tm-170 (TBD matrix, Sept. 06 version). 

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matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are con
Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

12 Internal dose 

due to 

incidents 

5.2.3, 7.3.6 The Special Hazards Investigations 

list is incomplete. In its Tank Farm Fault Tree Databank, the site acknowledged that many early tank farm area incidents were not recorded (until 1965). NIOSH has not addressed the evidence provided in the SC&A TBD review that there were incidents in the 200-Area tank farms that were not recorded. 

TBD review 

Section 5.6.2 

and matrix 

comment 4 

ER states that there are incident records, including the Special Hazards Investigation files. It states that construction workers in incidents were monitored and, hence, it can reconstruct the dose attributable to incidents (ER, p. 29). No evidence of cover up of incidents was found, and NIOSH can bound dose in any case (ER p. 71) 

Construindicate incidentTree Dainterviewno HP cincidentWater Calso menthis accinot discuissue of also raisalso raisincidentaddresseresearch incidentSpecial There is Tree Damany inhigh-levrecorded interest.

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matrix will not be freely distributed to the public until further reviews for Privacy Act-restricted information are con
Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

Savannah River Site Issues Matrix 10 S

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

13 Overall CW to 

non-CW 

internal dose 

relation 

7.1 OTIB-0052 did not contain an 

analysis specific to SRS for CW to non-CW radionuclide intakes. SC&A preliminary review of CW and non-CW claimant bioassay data compiled by NIOSH indicates that the assumption that non-CW intakes (as indicated by bioassay data) would be generally higher than for CW is not generally valid. The adequacy of bioassay data for constructing coworker models needs to be examined for different periods, areas, radionuclides, and types of construction workers. 

ER states that OTIB-0052 found non-CW intakes “were generally higher than construction trades workers” (ER, p. 39). OTIB-0052 suggests a 1:1 ratio for CW to nonCW intakes. 

SC&A iworkers CW worthe hierawith grenon-CW 

percentiseveral (preliminquantitaDuPont workersoverlap these Duworkers employeinterviewthe H-Aradiation coveragindicatein tank fexposurraised in 

14 Special 

Exposure 

Conditions 

7.4.2 There are several areas of concern 

that can be described as “special exposure conditions,” including off-normal or unauthorized work practices, burning of spent tributyl 

TBS Review 

Section 5.10 

The ER states that NIOSH has evaluated source terms, and that NIOSH can reconstruct dose for workers in tank farms, including via use of coworker models (ER 

SC&A Wof the SEoff-normpotentiaincludin

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 1 – Internal Dose Issues 

TBD Matrix SEC ER Section 

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Comment 

No. 

Issue Brief No. Issue Description No. or 

ER Position Review 

Section No. 

phosphate in open pans in the early years (to ~1970), and high exposure potential during certain authorized work practices, such as opening tank risers or cleanup of high-level waste leaks. 

pp. 71–72). 

15 Construction 

worker job 

types 

Worker intakes and coworker models may have to be built by construction worker job type in order to ensure that the models are bounding doses (or more accurate than bounding doses). 

ER assumes that non-CW internal dose data will bound CW dose. 

Preliminindicate higher thCW intatype. Thespecial– see, fo

16 OTIB-0075 

validity for 

SEC use – 

internal dose 

7.1, 7.3.4, 

7.4.2 

The use of OTIB-0075, which asserts representativeness of claimant data for the whole worker population for SRS construction worker SEC, is questionable. 

Claimant samples are representative of the entire worker population. 

This is a ER. SCnotably 

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 2 – External Dose Issues 

SEC 

Comment 

No. 

Issue Brief ER Section No. Issue Description SC&A TBD Comment No. ER Position C

17 Early neutron 

dose to about 

1961 

7.2.2.2 Figure 7-3 of the ER (p. 65) shows 

no neutron monitoring data for the 200-F Area until about 1958, and generally less than 20 badges per cycle until 1962 (except for part of 1959). This was “one of the highest neutron-exposure areas at SRS,” according to the ER (p. 64). The entire early period will have to depend almost exclusively on area neutron and photon monitoring data. The relationship of the n/p ratio data to workers and their personnel neutron exposure experience will need to be established with essentially no reference to actual monitoring data. It is unclear whether there are any early neutron monitoring data for CW at all. 

n/p ratios are being developed (see also next row). 

This issupetitione

18 Neutron dose 6.2 and 7.2.2 ER acknowledges unmonitored 

dose at SRS due to neutrons, since monitoring was required only when area neutron dose rates were in excess of 1 mrem per hour. Neutron data are very sparse in general up to the mid-1960s, and sparse even after that. Work to determine n/p ratios is ongoing. Representativeness of area 

4. Also see 

SCA TBD 

Review 

Section 5.5 

ER states that work to determine n/p ratios is ongoing, and that a coworker model would also be developed. It also states that CW workers were “generally not assigned to work” in areas expected to have the most neutron exposure. 

The SRS neutron in the cocompensand bestThis issustates thneeds to 

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Part 2 – External Dose Issues 

SEC ER Section SC&A TBD Comment Issue Brief Issue Description ER Position 

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No. No. Comment No.

C

monitoring for worker exposure and representativeness of available n/p data for all workers in the class needs to be assessed. Additionally, back extrapolation of post-1972 data was proposed in the TBD. It is unclear whether there will be back extrapolation to demonstrate bounding dose; if there is, the validity of such back extrapolation may need to be examined. Validity of assumption of low neutron doses in the reactor areas needs to be examined. Validity of implicit assumption that CW neutron doses were lower than non-CW workers needs to be examined in view of the higher bioassay results for some periods and radionuclides, including plutonium in some periods. ER does not explicitly discuss how the general n/p ratios and coworker models will be applied to various types of construction workers. 

 has been redacted. Note, however, that future versions 

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 2 – External Dose Issues 

SEC ER Section SC&A TBD Comment Issue Brief Issue Description ER Position 

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No. No. Comment No.

C

19 Test reactor 

neutron dose 

Neither the ER nor the TBD analyze the neutron dose at the Heavy Water Components Test Reactor. 

ER does not discuss this issue. SC&A i

took placore). Ininvestiga

20 Tank Farm 

exposure 

geometry 

NIOSH to estimate the geometry of exposure in special work situations, such as those described in the F and H Area Tank Farm Fault Tree Databank, and the frequency with which these corrections may need to be applied to external dose. While correction factors can, in principle, be calculated, it is not clear that a scientifically valid set of scenarios, including time worked and radiological conditions, can be constructed. NIOSH has not addressed this issue in the ER. 

5.6.3 ER does not discuss this issue. As part o

NIOSH exposure clean-up etc., whelevel thageometrexamplefor the F 

21 External 

exposure coworker data 

adequacy for 

CW 

7.2.1.3 OTIB-0052 is claimant favorable 

for a large majority of construction workers. However, it is not so for some categories. A bounding dose (or better) demonstration needs to be made for all CW job types. 

OTIB-0052 will suffice for coworker model. 

 has been redacted. Note, however, that future versions 

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 2 – External Dose Issues 

SEC ER Section SC&A TBD Comment Issue Brief Issue Description ER Position 

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No. No. Comment No.

C

22 Badges not 

capturing 

dose 

SC&A worker interviews suggest that workers kept their badges out of higher radiation areas in order not to exceed dose limits, or sometimes CW would be in radiological situations without knowing it (one incident is described when workers were working with radioactive tools thought initially to be clean). 

23 External dose 

recording 

accuracy and 

completeness 

7.3 Petitioners raise the issue of 

working conditions with high dose rates when badge dose may have been under-recorded or not recorded (such as weekend work) and/or pencil dosimeters were offscale, or when there are zero doses in the record. An issue connected to this would be whether the HPAREH database reflects actual work experience. Petitioners also state that in some cases, workers thought they were working in clean areas that were then determined to be contaminated. 

Coworker and missed dose approaches can bound dose. 

An evalubadge dodone befinvestigaconductiquestionThe abilcapture tthe petitTBD comwould nSEC pro

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 3 – Early Monitoring Data

SEC 

Comment 

No. 

Issue Brief ER Section No. Issue Description SC&A TBD Comment No. ER Position H

24 Early 

monitoring 

data 

Various The ER has addressed lack of 

early monitoring data for many workers and radionuclides by a number of devices, including building coworker models, using reporting levels, using air monitoring data, and estimating neutron to photon ratios. While each of these needs to be assessed in its own right (as described in the issues listed above), an overall assessment of early recordkeeping practices, adherence to procedures, and adequacy of data appears to be warranted. 

5 Various. Early w

an issue 

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Issues Matrix for the SRS SEC Petition and Petition ER 

Part 4 – Environmental Dose

SEC 

Comment 

No. 

Issue Brief ER Section No. Issue Description SC&A TBD Comment No. ER Position H

25 Environmental 

dose 

None Using dispersion modeling of stack 

source terms as described in the TBD and referred to in the ER (p. 72) is not appropriate for onsite SRS workers. For instance, thousands of gallons of solvents contaminated with fission products and plutonium were burned in the Burning Ground. Use of a Gaussain plume model is not appropriate here, especially for particles greater than half a micron. Furthermore, the resuspension factor does not appear to be claimant favorable and is not entirely appropriate for this class of problem. It may not be claimant favorable by three or four orders of magnitude. Even for stack releases, one potentially significant issue is the non-conservatism of the standard Gaussian model used in the TBD, where it pertains to “nonstandardized” short-term releases occurring during stable atmospheric conditions. 

7 Mentions environmental dose in 

passing and refers to the TBD. Resuspension is not discussed. 

NIOSH wopen pan TBD comcontains NIOSH aresuspen

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