Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A’S EVALUATION OF ORAUT-RPRT-0083, REVISION 00, 

“EVALUATION OF MONITORING OF CONSTRUCTION WORKERS 

IDENTIFIED IN HIGH-LEVEL CAVE JOB PLANS AT THE SAVANNAH 

RIVER SITE”

Contract No. 211-2014-58081

SCA-TR-2017-SEC012, Revision 0

Prepared by

Robert Barton, CHP

Ron Buchanan, PhD, CHP

SC&A, Inc.

2200 Wilson Boulevard, Suite 300

Arlington, Virginia, 22201

Saliant, Inc.

5579 Catholic Church Road

Jefferson, Maryland 21755

November 2017

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 Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE:

SC&A’s Evaluation of ORAUT-RPRT-0083, Revision 00, 

“Evaluation of Monitoring of Construction Workers Identified in 

High-Level Cave Job Plans at the Savannah River Site”

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-SEC012

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: November 21, 2017

TASK MANAGER: Joe Fitzgerald, MS, MPH [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S):

Joe Fitzgerald, MS, MPH [signature on file]

John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 11/21/2017 Initial issue
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TABLE OF CONTENTS

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

1.0 Introduction and Background ............................................................................................. 5

2.0 Overview of ORAUT-RPRT-0083 ..................................................................................... 5

3.0 SC&A’s Evaluation of ORAUT-RPRT-0083 ..................................................................... 7

3.1 Findings................................................................................................................... 7

3.2 Observations ........................................................................................................... 7

4.0 Summary and Conclusions ................................................................................................. 9

5.0 References ........................................................................................................................... 9
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

CTW construction trade worker

dpm/L disintegrations per minute per liter

HLCs high-level caves

mrem/y millirem per year

NIOSH National Institute for Occupational Safety and Health

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

PRID Payroll Identification (number)

RPRT report

SRS Savannah River Site
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1.0 INTRODUCTION AND BACKGROUND

In August 2017, the Advisory Board on Radiation and Worker Health tasked SC&A with a 

technical review of ORAUT-RPRT-0083, Evaluation of Monitoring of Construction Workers 

Identified in High-Level Cave Job Plans at the Savannah River Site, Revision 00, issued June 27, 

2017 (NIOSH 2017, referred to as “RPRT-0083”). In RPRT-0083, the National Institute for 

Occupational Safety and Health (NIOSH) evaluated if Savannah River Site (SRS) subcontracted 

construction trade workers (CTWs) were monitored differently from prime contractor (DuPont) 

CTWs when doing the same types of work during the 1980s. NIOSH concluded that, “As a 

result, radiation dose to subcontractor CTWs may be reconstructed using external and routine or 

event-driven bioassay monitoring data available for the worker, using coworker data, or using a 

combination of the two.”

This report presents SC&A’s evaluation of RPRT-0083.

2.0 OVERVIEW OF ORAUT-RPRT-0083

For evaluation purposes, it is advantageous to provide a brief outline of RPRT-0083, as follows:

 Introduction (Section 1.0) – The purpose of the document was to evaluate if SRS 

subcontracted CTWs were monitored differently from prime contractor CTWs when 

doing the same types of work during the 1980s. 

 Identification of Workers (Section 2.0) – The Oak Ridge Associated Universities Team 

(ORAUT, referred to as the “ORAU Team”) obtained job plans and safety permits for the 

high-level caves (HLCs) in Building 773-A for the period 1980–1986. Table 2-2 (page 9)

of RPRT-0083 summarized the total number of workers by year. A total of 397 DuPont 

CTWs (305 with potential for internal intake) and 650 subcontractor CTWs (350 with 

potential for internal intake) were identified.

 Evaluation of CTW External Monitoring (Section 3.0) – The ORAU Team searched 

the SRS dosimetry records for the 397 DuPont CTWs and the 650 subcontractor CTWs. 

Table 3-1 (page 11) of RPRT-0083 summarizes the percent of workers with recorded 

external monitoring data (monitored at least once during the calendar year). During the 

period 1980–1986, 99.5% of the DuPont CTWs and 96.8% of the subcontractor CTWs

were monitored for external exposure.

 Evaluation of CTW Internal Monitoring (Section 4.0) – The ORAU Team reviewed 

the SRS plutonium bioassay logbooks for each of the workers who were identified as 

having a potential for exposure to determine if the workers were monitored for internal 

intake at least once in the year following the potential exposure. The ORAU Team found 

255 unique subcontractor CTWs who did not have records of the required bioassay in the 

allotted time. The ORAU Team randomly selected 110 subcontractor CTWs, resulting in 

133 CTW-job pairings (some CTWs worked on multiple jobs). Of these 133 CTW-job 

pairs, 88 required the use of respirators. The distribution of the crafts involved is 

illustrated in Figure 4-2 (page 12) of RPRT-0083. The ORAU Team searched the SRS 

dosimetry databases to determine if the subcontractor CTW-job pairs had records on file 
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of the required bioassays, per the time schedule as listed on pages 13–14 of RPRT-0083

for the radionuclides involved on the job. Table 4-2 (page 14) of RPRT-0083 summarizes

the results; Figure 4-3 (page 15) illustrates the results on a yearly basis. For the period 

1980–1986, 59 out of the 88 CTW-job pairs (67%) had the required bioassay within the 

required time period. Of the 88 CTW-job pairs, 34 subcontractor CTWs were on routine 

bioassay monitoring during the job plan’s work period.

 Evaluation of Workplace Monitoring (Section 5.0) – This section indicates that 

Building 773-A was surveyed and swiped for contamination on routine, defined 

frequencies. The section provides copies of completed radiation survey logsheets for 

1981–1986.

 Evaluation of Incident Monitoring (Section 6.0) – The ORAU Team located some 

subcontractor CTW contamination incidents in the radiation survey logsheets and worker 

bioassay history records. NIOSH concluded that these documents indicated that the types 

of work performed and the potential for radiation exposures were similar for both DuPont 

and subcontractor CTWs. Examples of these incidents are provided on page 22 of 

RPRT-0083. Examples of documents showing health physic monitoring for subcontractor

CTWs are shown on pages 23–26.

 Conclusions (Section 7.0) – From its analyses, NIOSH concludes that:

The Team finds subcontractor CTWs were monitored for both external and 

internal radiation exposure by external dosimetry, bioassay, continuous 

air monitoring, contamination monitoring, and radiation surveys. Work by 

subcontractor CTWs was preplanned. Instructions for work and protective 

measures and clothing were specified in the same manner and on the same 

forms as work to be by DuPont CTWs.... While some subcontractor CTWs

might not have been monitored by bioassay, the report has shown their 

coworkers were monitored. As a result, radiation dose to subcontractor

CTWs may be reconstructed using external and routine or event-driven 

bioassay monitoring data available for the worker, using coworker data, 

or using a combination of the two.

 Types of Forms (Attachment A) – This attachment provides examples of various forms

used for work involving subcontractor CTWs.

 Job Descriptions (Attachment B) – Attachment, Table B-1, lists the descriptions of jobs 

by selected CTW. Table B-2 lists the job number (a total of 133 CTW-job pairs), job plan

date, respirator requirements, alpha and fission product air concentration monitoring 

results, status of health physics monitoring, plutonium bioassay date, fission products 

bioassay date, and in vivo bioassay date.
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3.0 SC&A’S EVALUATION OF ORAUT-RPRT-0083

The following is a summary of SC&A’s evaluation of RPRT-0083.

3.1 FINDINGS

SC&A did not identify any specific findings with the methodology and statistical analyses in 

RPRT-0083.

3.2 OBSERVATIONS

SC&A did identify areas that require clarification or further development. The following 

observations list these areas than need to be addressed.

Observation 1. The title of RPRT-0083 is Evaluation of Monitoring of Construction Workers 

Identified in High-Level Cave Job Plans at the Savannah River Site. [Emphasis added.]

The introduction on page 6 of RPRT-0083 states:

This report addresses if Savannah River Site (SRS) subcontracted construction 

trade workers (CTWs) were monitored differently from prime contractor 

(DuPont) CTWs when doing the same types of work during the 1980s. [Emphasis 

added.]

However, the last sentence of the conclusions on page 27 states:

As a result, radiation dose to subcontractor CTWs may be reconstructed using 

external and routine or event-driven bioassay monitoring data available for the

worker, using coworker data, or using a combination of the two. [Emphasis 

added.]

To go from determining the fraction of workers monitored for external and internal exposures to 

the use of that information for coworker data regarding prime and subcontractor CTWs requires 

addressing eight basic items:

1. The fraction of prime CTWs externally monitored (badged)

2. The fraction of subcontracted CTWs externally monitored (badged)

3. The external dose distribution for the prime CTWs as a function of time (i.e., mrem/y)

4. The external dose distribution for the subcontractor CTWs as a function of time

(i.e., mrem/y)

5. The fraction of prime CTWs monitored for intakes (bioassayed for the appropriate 

radionuclides)

6. The fraction of subcontractor CTWs monitored for intakes (bioassayed for the 

appropriate radionuclides) 

7. The internal intake distribution for the prime CTWs as a function of time (i.e., dpm/L)
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8. The internal intake distribution for the subcontractor CTWs as a function of time

(i.e., dpm/L)

This information can then be used in determining if there are sufficient data to create a coworker 

dose model: either separate models for prime CTWs and subcontractor CTWs, or a combined 

coworker dose model if the two distributions are similar.

However, RPRT-0083 only addressed Item 1 (fraction of prime CTWs externally monitored), 

Item 2 (fraction of subcontractor CTWs externally monitored), and Item 6 (fraction of 

subcontractor CTWs monitored for intakes). The remaining five items were not included in the 

report. Is additional quantitative information forthcoming to address these five items?

Observation 2. Page 10 of RPRT-0083 states:

Using the name, PRID data, and year, the Team searched SRS quarterly external 

monitoring reports for each worker to determine if the worker was monitored for 

external radiation at least once during the year. [Emphasis added.]

SC&A has the following comment concerning this statement.

Did the ORAU Team consider external monitoring for an individual that occurred anytime 

within the year of the job plan to be sufficient to be counted as monitored?

It would seem the temporal relationship between the actual job and available external monitoring 

data is necessary to make a proper connection. External monitoring during the fourth quarter is 

not relevant to a job done in the first quarter (and vice versa).

Observation 3. Page 13 of RPRT-0083 states:

Certain subcontractor CTWs are likely to have been sampled in relation to work

in other SRS areas during the same year as the year of the reviewed Job Plan or 

permit at Building 773-A, or as part of routine bioassay. SRS ran a plantwide 

bioassay program. Results of bioassay obtained in other areas is still under 

evaluation for use in reconstructing doses from work in Building 773-A.

Also, page 22 of RPRT-0083 states:

The types of work performed and potential for radiation exposures were similar 

for both DuPont and subcontractor CTWs.

SC&A has the following concerns:

1. How can routine, or job-specific, bioassays for different jobs and other areas of the site 

be applied when radionuclides may be different for different jobs and locations?

2. It should be emphasized that even if it is demonstrated that the type of work and the 

potential for exposure were similar for the two groups of CTWs, this cannot 
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automatically be projected to other facilities, work areas, and time periods at SRS without 

supporting evidence.

4.0 SUMMARY AND CONCLUSIONS

SC&A evaluated RPRT-0083 and had no specific findings with the methodology or statistical 

analyses. However, SC&A did identify areas that require clarification or further development. 

These areas are described in the three observations in Section 3.0 of this report.

SC&A would like to emphasize that even if it is demonstrated that the type of work and the 

potential for exposure were similar for the subcontractor CTWs and the prime CTWs at the 

HLCs during the period 1980–1986, this cannot automatically be projected to other facilities, 

work areas, and time periods at SRS without supporting evidence.

5.0 REFERENCES

NIOSH 2017. Evaluation of Monitoring of Construction Workers Identified in High-Level Cave 

Job Plans at the Savannah River Site, ORAUT-RPRT-0083, Revision 00, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. June 27, 2017.