Draft White Paper 

REVIEW OF THE WORKER COMMENTS FOR THE MAY 22, 2008, 

SAVANNAH RIVER SITE (SRS) WORKER OUTREACH MEETING 

AND PETITIONER SUPPORTING MATERIAL 

Contract Number 200-2009-28555 

Prepared by 

Lynn Ayers 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Kathryn Robertson-DeMers 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

February 2011 

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.
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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Document Description: 

Draft– Review of Worker 

Comments

Effective Date: 

Draft – February 15, 2011 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 0 (Draft) 

REVIEW OF THE WORKER COMMENTS FOR 

THE MAY 22, 2008, SAVANNAH RIVER SITE 

(SRS) WORKER OUTREACH MEETING AND 

PETITIONER SUPPORTING MATERIAL 

Page 2 of 23 

Task Manager: ___________________ Date: 

 Arjun Makhijani, PhD 

Supersedes: 

N/A 

Project Manager: _________________ Date: 

 John Mauro, PhD, CHP 

Reviewer: 

 Arjun Makhijani, PhD 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 02/15/2011 Initial issue 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

TABLE OF CONTENTS 

Introduction..................................................................................................................................... 4 

Comment Analysis.......................................................................................................................... 4 

Summary......................................................................................................................................... 5 

References....................................................................................................................................... 6 

Attachment 1: Worker Comments from May 22, 2008, Worker Outreach Meetings 

(NIOSH 2008)..................................................................................................................... 8 

Attachment 2: Worker Comments from Petitioner Sources........................................................ 19 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

INTRODUCTION 

At the Savannah River Site (SRS) Work Group meeting on May 5, 2010, a petitioner 

representative suggested that the Work Group consider information from two worker outreach 

meetings conducted in North Augusta, Georgia, in May 2008 (NIOSH 2008). Information 

provided in the meetings addresses the adequacy of radiological controls and personnel 

monitoring for several groups of SRS workers, topics which are relevant to data adequacy and 

completeness. The petitioner representative is not assured that NIOSH has considered this 

information in their evaluation of the Special Exposure Cohort (SEC) petition or during the 

petition appeals process. The petition Evaluation Report (ER) indicates that one set of meeting 

minutes had not been posted to the Site Research Database (SRDB) and one set had not been 

released by the Department of Energy (DOE) when the ER was completed. 

The Work Group tasked S. Cohen and Associates (SC&A) with analyzing the workers’ 

statements, identifying issues of concern, and comparing worker concerns with matrix issues 

from Issues Matrix for the Savannah River Site SEC Petition and Petition Evaluation Report 

(SC&A 2009) to determine the extent to which these concerns have been addressed (ABRWH 

2010a). SC&A also reviewed worker comments from the petition presentation at the Advisory 

Board on Radiation and Worker Health: 60th Meeting, held in Augusta, Georgia, in December 

2008 (ABRWH 2008) and additional documents provided by a petitioner representative. 

COMMENT ANALYSIS 

SC&A reviewed the documents and recorded worker comments in a spreadsheet. Separate tables 

were prepared to capture worker comments from the Worker Outreach meetings and those 

obtained through other sources. Although SC&A preserved statements covering similar issues 

with significant overlap, duplication of the same statement in both tables was avoided. Claimspecific statements from the petitioners’ material and comments not relevant to EEOICPA Part B 

(primarily related to chemical exposures) were excluded from this analysis. 

Attachments 1 and 2 of this memo contain the worker statements compiled for this evaluation. 

Attachment 1 contains comments derived from the May 22, 2008, worker outreach meetings, and 

Attachment 2 contains comments derived from the petitioner presentation and other sources 

provided by the petitioner representative. Each entry includes a description of the worker’s 

comment, the type of worker communicating and/or impacted by the issue (e.g., construction, 

operations, general population, not specified), and an indication of correspondence with matrix 

issue(s) and/or supplemental issue(s). Attachment 2 also contains a source reference, because 

the comments in this table were drawn from multiple documents. 

Correlation of worker concerns with SRS matrix items (SC&A 2009) was difficult. Some issues 

correspond well to existing matrix items. Some issues are very similar in substance, but include 

situations and worker groups that are not encompassed by the matrix issue description. The 

matrix item(s) most closely reflecting the nature of the worker’s concern were entered for these 

items. A significant number of worker comments may fall outside the scope of current matrix 

issues, but this may not become clear without further consideration. For instance, it is not clear 

from some worker comments whether an internal or external dose issue was involved. There are 
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matrix items relating to both. As another example, the internal dose adequacy questions may 

relate to specific situations involving radionuclides for which NIOSH has said it is preparing 

coworker models, but it is not possible to determine this at the present time. We have used the 

following supplemental issue codes to categorize these issues: 

S1 Radiological controls (e.g., HP coverage, contamination control, personal 

protective equipment, radiological postings) 

S2 Destruction or loss of records 

S3 Scope of the evaluated class 

S4 Internal dosimetry data adequacy 

S5 Other (radiological training, unequal status, retaliation, general information) 

It is unclear to what extent groupings S1, S2, S4, and S5 would be SEC issues. In regard to issue 

S3 in the list above (the scope of the evaluated class), SC&A has been authorized to make 

comments on issues that may relate to dose reconstruction feasibility for non-construction 

workers, provided they arise in the context of the construction worker SEC review (see below). 

Other codes entered in the “Matrix Item” column of Attachments 1 and 2 indicate worker 

comments that are relevant to EEOICPA Part B, but are not related to SEC issues: 

DOL Department of Labor issue (e.g., employment records) 

TBD/DR Issue related to technical basis document (TBD) and/or dose reconstruction 

(DR) process 

WO Worker Outreach (WO) / NIOSH responsiveness 

SUMMARY 

Participants in the May 2008 worker outreach meetings describe a number of concerns, citing 

specific examples of situations affecting diverse types of workers. Many similar concerns were 

raised for construction workers and non-construction workers. In many cases, it was difficult to 

determine whether or not the workers involved were monitored for external or internal exposure. 

Issues raised at the worker outreach meetings generally fall within the following categories: 

 The adequacy and completeness of internal and external monitoring data 

 Radiological incidents and unusual occurrences 

 Lack of radiological controls or characterization 

 The scope of the evaluated SEC class 

In addition to these concerns, documents provided by the petitioner representative communicate 

frustration with NIOSH’s responsiveness to worker input, which is closely linked to their 

decision to restrict the evaluated class. Petitioners have been told that they have not presented 

sufficient evidence to qualify non-construction workers for evaluation, but the workers feel that 

the evidence they have provided (particularly the statements offered at the May 2008 worker 

outreach meetings) was not given adequate consideration. NIOSH has stated that, “during that 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

two-day meeting there wasn’t any information provided that we felt would qualify production 

workers for inclusion in the class during that time period” (ABRWH 2010b, pp. 20–21). The 

petitioner representative maintains that the review panel denied due process by failing to perform 

an independent evaluation of the workers’ statements and NIOSH’s conclusion. This issue is 

beyond the scope of SC&A’s review mandate. Since the issue of independent review may also 

be beyond the scope of the SRS Work Group to evaluate, the SRS Work Group might consider 

forwarding this issue to the Worker Outreach Work Group, since there appears to be a different 

interpretation of the input during the May 8, 2008, meeting on this issue by the petitioner 

representative and by NIOSH. As an alternative, the SRS Work Group might consider advising 

the petitioner representative of some other appropriate channel for seeking resolution of this 

concern. 

As regards the scope of the ER, it is SC&A’s understanding that the ER did not cover nonconstruction workers because they were not part of the qualified SEC petition. This issue was 

discussed at some length during the January 19, 2010, SRS Work Group meeting. Specifically, 

the SRS Work Group asked SC&A to comment on non-construction worker issues if they came 

up in the course of construction worker issues. NIOSH stated that it would be open to modifying 

the scope of the SEC, should the situation indicate that that was warranted (ABRWH 2010b, 

pp. 11–27 and pp. 70–77). 

In the context of this report, SC&A notes that it has begun identifying non-construction worker 

dose reconstruction issues as they come up during the construction worker SEC review. We 

have done that in the review (SC&A 2011) of NIOSH’s supplement to the Evaluation Report 

(NIOSH 2010). However, evaluating the technical merits of issues concerning non-construction 

workers outside of the context of the construction worker SEC review is beyond the scope of 

SC&A’s current authorization. This report simply compiles the worker comments and attempts 

to associate them with existing matrix issues, in accordance with the Work Group’s request. As 

with other issues in the S1 to S5 list, SC&A is not making any conclusions at this time about 

their potential to be SEC issues to the extent that they do not overlap with existing issues in the 

SRS SEC matrix (SC&A 2009). 

Issues of exposures to the public and to non-DOE, non-contractor or sub-contractor personnel 

were also brought up by petitioners, their representatives, or in the May 2008 meeting. These are 

also noted for completeness. The population that may have been exposed according to the 

comment is also noted. Evidently, neither of these belongs in a list of SEC issues. 

REFERENCES 

ABRWH (Advisory Board on Radiation and Worker Health) 2008. Transcript of the 60th

Meeting of the Advisory Board on Radiation and Worker Health, December 16, 2008, pp. 215–

241. 

ABRWH (Advisory Board on Radiation and Worker Health) 2010a. Transcript of the Savannah 

River Site Work Group Meeting of the Advisory Board on Radiation and Worker Health, May 5, 

2010, pp. 336–342. 
Effective Date: 

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 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

ABRWH (Advisory Board on Radiation and Worker Health) 2010b. Transcript of the Savannah 

River Site Work Group Meeting of the Advisory Board on Radiation and Worker Health, January 

19, 2010. 

[Redacted] 2010. E-mail from [Redacted] (Petitioner Representative) to K.A. RobertsonDeMers (SC&A), Subject: Incidents and Test Reactors at SRS, [Redacted] Offices of 

[Redacted], P.A., Black Mountain, North Carolina, March 16, 2010. 

DOL (Department of Labor) 2005. Transcripts of Proceedings, Department of Labor, 

Department of Energy Employees Occupational Illness Compensation Program, North Augusta, 

South Carolina, March 17, 2005. [See Exhibit 9.] 

NIOSH (National Institute for Occupational Safety and Health) 2008. Transcript of the SEC 

Worker Outreach Meeting for the Savannah River Site (SRS), May 22, 2008 (1:00 p.m. and 

6:00 p.m. meetings). 

NIOSH (National Institute for Occupational Safety and Health) 2010. SEC Petition Evaluation 

Report Petition SEC-00103, Addendum, April 28, 2010. 

SC&A 2009. Issues Matrix for the Savannah River Site SEC Petition and Petition Evaluation 

Report, SC&A, Inc.,Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. September 2009. 

SC&A 2011. Joyce Lipsztein, SC&A review of the NIOSH Addendum to the Savannah River 

Site Special Exposure Cohort (SEC-00103) Evaluation Report, S. Cohen & Associates, Vienna, 

Virginia, January 2011. 

SEC Petition, 2007. Special Exposure Cohort Petition for the Savannah River Site, SEC-00103, 

November 2007. [See Exhibit 9] 

[Redacted] 2010. Letter from [Redacted] (petitioner representative) to M. Griffon (ABWRH), 

Re: Documents/Statements Not Used in Review, [Redacted] Offices of [Redacted], P.A., Black 

Mountain, North Carolina, April 22, 2010. 

[Redacted] 2008a. Request for Review of Proposed Finding, For SEC Tracking Number: 

SEC00103, April 23, 2008. 

[Redacted] 2008b. Request for Administrative Review of Findings For SEC Tracking Number: 

SEC00103, July 31, 2008. 
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ATTACHMENT 1: WORKER COMMENTS FROM MAY 22, 2008, WORKER OUTREACH MEETIN

Matrix 

Item Worker Type Description 

9 General 

HP said workers had annual whole-body count & urine bioassay "regularly" if they worked around trizone requiring plastic suits, they left a urine sample each day and had handheld devices to frisk when 

in clean areas left a sample weekly or monthly. 

9/23 Construction Worker (CW) In 100K Area, workers walked right across the "swimming pool" over spent fuel rods to get to their sh

12 CW [Redacted] stated that he sometimes had nasal smears or oral swipes or gave urine samples if the mon

“hot canyons,” but there were also instances when an HP was not present to monitor. 

12 CW 1950s spill incident. All personal belongings were confiscated. Worker detained for decontamination 

No record of incident or worker's exposure. Co-worker thought spill was covered up because it affect

12 CW When filters were taken off old tanks, alarms went off. CWs were told that a power surge had caused 

CWs were told to get back to work. 

12 CW Surveyors had boat in L Area pond using prism rod in the water. Water would get all over them when 

in boat. Monitors went off as they left the area, because their prism rod became contaminated. 

12 CW CW/claimant did not receive written records of incidents in which he was involved. 12 CW 

Contaminated water spilled on parking lot & highway when workers moved a pump from H Area wasseal. A worker drove his company truck into the same area & was told to leave, but he was not monitchecked. The contaminated parking lot and the road were excavated and replaced. 

12 General Several attendees agreed that it was common for an HP to say the equipment was broken if an alarm w

foot scan showed contamination. 

12 General 

Someone took pallet of tools painted for RZ areas (indicating not to be removed from rad zone) to CenShop workers left area & called in HP to survey. Tools sat on pallet 3 weeks before workers in plastic 

to burial ground. [Redacted] men who had handled the tools were deconned at HP office in Central Sbioassay samples. ~1992–93 

12 General 

Working on welding machines in maintenance shop. Blew off dust w/air hose before finding out it wmachines were sent to burial grounds. Two crews of electricians in shop, no bioassay or nasal smear. considered clean area - primarily for fabrication. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Matrix 

Item Worker Type Description 

12 Not Specified 

1979 air reversal/intake - It was common practice to replace experienced hood operators on 221-H B-operators as they neared 2R annual exposure (3R/yr limit). Less experienced crew failed to verify abs

opening barn doors to bring in crane, causing air reversal. Field HP took nasal smear - worker was noNo special bioassay - worker was on routine monthly program. Worker had occasional chest counts w

but did not know what they were looking for. 

12 Not Specified 

[Redacted] did not want incident recorded [1979 air reversal on 221-H B-line], because he didn't wandocumented in log book. Months later, HP’s logbook was stolen (forced entry into locked desk) while [Redacted]. 

12 Not Specified 

Escort went with AT&T workers to do maintenance in 105 C reactor area. A worker dropped a box owent off when he pulled it out. Workers were removed so alarms could be shut off; they were sent bawithout PPE or TLDs. This occurred in late 1980s or early 1990s. 

12 Not Specified 

A test was shut down after the 1st run because U oxide solution had melted PVC pipes and gotten all o

going out to H waste area, the waste backed up into the sludge pump. The entire building was shut do

the building was demolished and the area was paved over. 

12 Not Specified Contaminated water spilled out of a heat exchanger onto workers during change-out. 12 Not Specified Contaminated worker [K Area Reactor] waited 30 minutes for HP to show up after setting off alarm o12 Operations RCTs surveying & monitoring work sites were often exposed to elevated levels of contamination befo

protected. Survey, discover problem, withdraw to don appropriate PPE and respiratory protection. 

12 Operations Alarms went off all the time. Workers were told that if they left the area for a time and the all clear w

go back to work. If the alarms went off again, they were to contact an HP, but it was sometimes diffic

12 Operations RCT was called in to respond to incidents. Events are not mentioned in the RCTs' dose records. 12 Operations Large volume of "hot" water spilled on worker unloading spent fuel from railcars. Night shift - no HP

& showered - does not remember testing. 

12 Operations Incident - contaminated/leaking cooling lines in Area F Tank Farm. RCT surveyed; contamination ex

Submitted bioassay & nasal smears, but results are not in dose record. 

12 Operations 

Incident - H Area Tank Farm. [Redacted] RCT present with Operations workers changing filter on sa

operator opened a valve that diverted some waste in the wrong direction. Sludge dumped on ground o

rad monitors. After using step-off pad, removing PPE & respirators per procedure, they realized highthey were standing (instruments off scale). Major incident, documentation, bioassay, nasal & saliva sDOE documents not available to workers who were involved. No mention in personal files. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Matrix 

Item Worker Type Description 

12 Operations A railcar loaded with spent fuel rods derailed and tore up the tracks. [Production] workers were kept 

was rebuilt. To the best of his knowledge, the incident was not recorded. 

12 

United States 

Forest Service 

(USFS) 

No record of incident when HPs told foresters to leave contaminated stream, even though HPs took th

contamination. 

12 USFS 

Unmonitored foresters were in a contaminated stream "cruising" timber down to storage location. No passing by told them to get out of stream. HPs took their boots because of contamination. Don't remecollected. Did not recall nasal smear or other samples taken. 

12/13 CW 

1987 release in H Area. Production workers evacuated to parking lot for several hours, some were taktreatment. CWs in S Area - separated only by chainlink fence, continued to work without protection dwere never told specifics of the release. 

12/13 General 

Insulators were dispatched to any area where repairs were needed, ruptured line in Tank Farm, "3", "7orders were for problems. Tanks were buried - workers would only be down around them if a leak or attention. If buried tank was leaking, Tank Farm personnel [Prod Workers?] would dig up the problemreport to fix it. 

12/DOL Subcontractor 

Subcontracted worker became contaminated while escorting [Redacted] CWs who worked on pipes imin. Set off alarm at exit monitor. The [redacted] was taken to HP for decontamination that lasted ngo home after several showers and a "normal" scan with a hand monitor, but they confiscated all of hiDOE has not found any of his records or a report of the incident. Had difficulty verifying employmenproduced pay stubs. 

14 CW CWs assisted riggers changing out massive heat exchangers. Huge undertaking to rig heat exchangers 

reactor area. "Hot" work without any records. 

14 General HPs tried to keep workers <150 mR/month. There were times when that limit could be exceeded in le14 General 

Worker commented that they were trying to get bldg [Bldg 235] in safe mode since it was shut down. was involved in a fire, "we would all get 300 R in just a few minutes and not even have to go in there building." 

20 General Tank top shielding - half-moon shaped lead shields covered the piping on the "hot tanks." In response 

or gaps, workers said the shields were "bumped together." 

20 General In Tank Precipitation (ITP) facility: highly contaminated liquid waste from B Line and Canyons was s

tanks until it went through vitrification process. Radiation levels were very high in this area. 

21 CW SRS maintenance personnel (who were monitored) often took unmonitored CWs with them on jobs ar

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Matrix 

Item Worker Type Description 

21 CW CWs were often unmonitored (no dosimetry badges) while working in areas where SRS employees w

had pencil while other workers had TLDs. 

23 CW Installed new tanks in deep hole by old tanks full of rad waste. Worked unmonitored 50-60 feet below 

period of time. 

23 CW They got daily dose rate cards & pencil dosimeters. Argued with HP to have it calibrated to "0". A w

but did not trust it - it never left the site (left hanging on board when worker left) and he never saw an

23 CW 1978, installing 6 new tanks in H Area. Workers in vicinity, but outside the immediate operations are

any other monitoring. 

23 General Pencils often read off scale while working on top of tanks. Workers were often told that they must ha

does not seem to account for situations when many workers in the same location had offscale readings 

23 General 

Pencil dosimeters at Tank Farms gave inconsistent results - [redacted] electricians working very shordosimeter readings would differ by >250 mrem in a matter of seconds. Under drought and dusty condelevated; when it rained and dust settled, readings went back down to 0. 

23 Not Specified Worker is concerned about multiple gaps of 1–3 years in his radiation exposure records 23 Operations 

[Redacted] worker 1955–1963 was sent out to various areas. Went to radiation areas to deliver paychroutine badge - got visitor badge to enter certain areas. No records were provided for the visitor badglikely to be exposed). 

23 Operations Workers picked up film badge at gate at beginning of shift. They would go right in (assume they didn

supervisor not there. Guards let them in on security badge - not checking for film badge. 

23 Operations 

Workers did not have film badges on weekends - they were collected Fri p.m. and returned Sun p.m. oseemed concerned that shift workers did not have badges during that time. During the week, wearing optional - supervisors never asked why someone was not wearing their badge. 

23 Subcontractor Subcontracted employee (cleaning company, escort) had great difficulty getting his records from DOE

radiation badge, he never received any reports of his dosimeter readings. 

23 Subcontractor Subcontractor employees were not routinely issued TLDs for years, even after they began to receive r

1980s. After taking classes, a worker was aware that he was going into radiation zones - finally reque

23 USFS Foresters had no PPE or film badges. Opening source at night to test rad effects on vegetation. 

23/S1 CW Common practice for trades workers to go to Central Shops or scavage needed materials from other ar

no one was aware that they were in the radiation area. 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Matrix 

Item Worker Type Description 

23/S1 CW R Area (had been shut down) - unmonitored CWs would go into buildings there to cannibalize parts n

made comment was not personally involved and did not know if workers had HP coverage. 

23/S1 CW All new construction worksites at S Area and Naval Reactor Area were right next to radiation areas an

CWs were monitored because the new construction was "clean." 

23/S1 General Supervisor sent [redacted] workers to HP Dept to have dosimeters read after they went off scale. HP 

them, and they should go back to work. Individual had to insist that HP take a counter to Tank Farm t

23/S1 Not Specified Escort took AT&T worker into evacuated/contaminated trailer to tag and remove contaminated teleph

TLDs. 

23/S3 Not Specified Truck drivers and employees who serviced vending machines are excluded from proposed SEC class. 

machines in 10 areas, including F, H, P, K, and 708 (1977–1981). Special security badge for access. 

23/S3 Operations Escorts accompanied CWs and outside maintenance workers who did not have clearance. They went 

went, because they were required to keep within sight. Escorts had no PPE or TLDs. 

23/S3 Subcontractor Subcontracted cleaning company employee worked in K Reactor area and delivered cleaning supplies 

around the plant. Never wore film badge or TLD. Late 1970s–early 1980s. 

23/S4 General How can NIOSH use co-worker data for administrative staff if no records were kept? 23/S4 Operations 

[Redacted] Operator working in R Area in 1950s was responsible for picking up SWP clothes left in b

RDZ. HP with Geiger counter accompanied him to check the clothing. If hot - clothing was tagged foburial ground. If not hot - it was sent to laundry. Worker was not monitored or assayed because it wa

23/S4 Operations 

Clerical worker did not get radiation training, give bioassay samples, or regularly wear a TLD, even th

because they went into Fabrication Laboratory. [Redacted] was told [redacted] did not need to particclerical worker. [Redacted] adjacent to Fabrication Lab had no barrier at ceiling level. Workers in laadmin worker could talk to tech from hallway through door with vented panel. 

23/S4 Operations 

Mechanics were like CWs - did not work in specific location, in and out of hot areas. E&I Mechanic bioassay in 400 Area - believes dosimetry records were not kept for that Area - many gaps in his dosim

serviced equipment in [redacted], where they reprocessed deuterium. Did use hand & foot monitor th

24 General 

The most disturbing thing about NIOSH dose reconstruction is that, if dose data are not available from assume that dose in documents they wrote after 2000? The modern HP program is much more thorougemployment. 

25 CW Surveyors walked through 2-mile swamp to K Area drainage ditch. Ate sourwood grass, blackberries

were growing on site. Ate lunches wherever they were - often did not have access to clean water to w

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Matrix 

Item Worker Type Description 

25 General 

Plant found cutting oil in water system in 1980s. Problem with solvents/degreasers from 1950s–1960

They tried to clean up with groundwater using steam injection. If the building was so contaminated it DOE should have reports on contamination levels in the water over time, but he has not been able to g

25 USFS Contaminated hardwood timber was burned. Softer timber, mostly pine, was chipped and buried. Som

found to be contaminated and were sent to the burial ground. 

25/S1 General 

Workers often used disposable plates & utensils in cafeteria when dishwasher could not be operated d

supply, but workers drank water from the same water supply on a daily basis. Statement was later cor

participant. 

S1 CW 

In reactor areas, worker wore TLD and gave monthly samples. Biggest problem was not having HP a

of problem areas. CWs are transient; often come & go w/out benefit of regular safety programs. Hurrbrought in for "hot" jobs. 

S1 CW On B-line, there were always HPs around. At Tank Farms, only safety instructions came from RWP p

listed protective clothing and equipment needed for the job. 

S1 CW Often, electricians worked without the benefit of any monitoring personnel on their jobs. S1 CW Lax contamination control. Surveyors' prism rod was given back to them after it was found to be contS1 CW Installing pipe line in F Canyon in 1981. Did not wear any protective gear, because signs had been tak

appeared to be clean. Hazard signs were re-installed after they were done. 

S1 CW Concerned that there are no records, and safety practices were inconsistent. Worked without protectio

but had to wear protective clothing & respirator on another building 1,000 yards away. 

S1 CW Unmonitored [redacted] operator working for subcontractor was told to dig under road to install a pip

hole under the road. After they'd already been digging, an HP told him the area was too contaminated 

S1 CW 

Big difference in HP treatment of CWs and operations personnel. In some instances, warning signs wCWs were brought in to do a job and posted again when their job was done. Improved somewhat in Cunless CWs got to know somebody, most of the time there was no HP looking out for their safety. Trmore experienced co-workers to look out for them. 

S1 CW A CW said there was no HP coverage in reactor areas because HPs were too busy. Improved over the 

remember seeing RWPs posted in reactor areas; did not have to sign in and out of work areas. 

S1 CW 

Tank Farms, late 1970s, tank tops being changed out to new design, trying to get sludge out of tanks. workers often did not monitor themselves when leaving the area. No documentation to inform workersurveyed. If they went to trailer to ask about specific area, they were told it had already been checked Tank Farm, there might be a big stack of lead that had not been there the day before. 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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Effective Date: 

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Revision No. 

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Page No. 

Page 14 of 23 

Matrix 

Item Worker Type Description 

S1 CW Late 1980s - workers often ate under a tree 10-15 feet from a train sitting in material storage area behi

train was roped off and removed. Worker had leaned against train on several occasions, not knowing 

S1 CW Stairwell up to 410 North is really crapped up. Workers were told to avoid walls & walk in middle of 

had drilled holes through 3" thick concrete walls in that stairwell to install conduit for security camera

S1 CW 

When irradiated slugs were transported from 100 Area to 200 Area, an HP walked along tracks and ev

shacks along the tracks to parking lots because cask cars were so "hot." Workers remained in parking Canyon and doors were closed. 

S1 General HP coverage at H B-Line: Operational area 4th level H Canyon was ~4,000 sq ft, divided into several 

who worked only there. Had CAMs. 

S1 General Heat exchangers from reactors were taken to Ford Building in Central Shops, overhauled (primarily b

crafts) over period of ~2 yr. Building was sealed and roped off afterwards - too contaminated to work 

S1 General 

Inexperienced RCTs were hired by Bechtel in 1989, trained for a short period, and sent out in the field exposure. Workers had little confidence in these techs’ ability to monitor or protect them. Popular sebagging groceries last week, and now he's doing our radiation protection." 

S1 General HP coverage at Tank Farms 1970s–early 1980s. Worked under a standing RWP for 2-3 weeks and on

beginning of the job. Had gamma monitors in cages ~15 ft above each tank, no CAMs. 

S1 General Worked without protection in "clean" areas; no barriers between "clean" and "hot" areas. S1 General Inconsistent practices for removing plastic suits. Sometimes removed after workers left hot area, othe

the room if readings were high. 

S1 General Lack of adequate monitoring was a routine topic at safety meetings ~1989. HP may or may not be pre

a hot tank. 

S1 General Worker always checked "clean" laundry before dressing out, because sometimes "clean" coveralls weS1 General 

After worker decontaminated masks, HPs & techs checked equipment and performed other maintenanchecked. Detection equipment for checking cleaned masks did not work properly. They "had to be bethem to work." 

S1 General 

Area outside Central Shops, welding machines from all over site came for maintenance. HP usually s

servicing, but machine may have been in yard several months. Workers in the area often leaned againbeen surveyed. 

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Matrix 

Item Worker Type Description 

S1 General 

Storage pit w/contaminated railroad ties discovered in F Area 1995. Safety procedures for moving tie- workers wore plastic suits. After that, SRS began removing contaminated ties from rail lines betwee

discovery of contaminated ties, unmonitored foresters often gathered & burned ties discarded along trany PPE. Contamination is believed to come from material transported when R and K reactors came owere potentially exposed for years before discovery. 

S1 General There were times when contaminated areas were taped or roped off on lower level of building, where 

room were located. Nothing but rope between contamination and workers. 

S1 General 

221 A-line was another "hot" building. Thick yellow uranium dust covered beams in that building as upgrade. A-line has been torn down except for 221-F. It is so hot they can't tear it down and it has to the building. 

S1 Not Specified 

Line Department within Electrical Department maintained high voltage lines. When they pulled electunderground part was often contaminated, esp. in F or H Area. Line crew pulled old electric poles at chainsaw, put in rubbish containers to be removed from area. No HP coverage. 

S1 Operations Night shift at canyon area (unloading railcars of spent fuel). 20-30 people in building without supervi

HP support. 

S1 Operations 

HPs were supposed to check laundry for radiation before it was washed, but sometimes piles of laundthe HP would come in & find that it was too contaminated to process. By that time, the laundry workit. 

S1 Operations Contaminated pests (cockroach, rodent) were found on separate occasions in proximity to work area o

worker. 

S1 

Not a worker but a public exposure issue 

Bechtel ~1989 set up Excess Yard in Central Shops for tools that were not in use. Members of public fraction of commercial cost. Materials came from all over site, occasionally contaminated, so Bechtel 

before they left the yard. 

S1 

Not a worker 

but a public 

exposure issue 

An individual purchased tools from SRS that were later found to be contaminated - apparently sold be

S1 Subcontractor 

Subcontracted laundry workers often handled contaminated clothing and equipment without any proteDuPont workers who were at least partially protected. Rationale given was that DuPont workers were contaminated items, but the subs were in immediate vicinity of these items. The only divider was a rostated that this laundry facility [F Area] has been torn down, and legacy hotspots were marked on the 

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Matrix 

Item Worker Type Description 

S1 Subcontractor 

An area had not been roped off when contractors installed new phone system in 1980s. They dug undbuilding to put in phone system. No respiratory protection. Area was declared a CERCLA site soon aeventually done under special permit. Ground had become contaminated from rain washing residue onear tracks waiting (for days) to be loaded. 

S1 USFS 

Foresters did not have HP at their disposal unless one happened to come by the forestry office. Forestapprised of contaminated materials that were carelessly left about the area. Example: big pipe full of 

USFS area for ~8-10 years. 

S1 USFS Unmonitored foresters worked in L Area to prepare a building site. Also ate lunch without washing h

no means of checking for contamination. 

S1 USFS In early days, unmonitored foresters cleaned equipment on a concrete pad near Central Stores. Pad w

contaminated - workers hauling contaminated equipment to burial ground also used the same pad to c

S1 USFS 

Foresters cleared lumber from building site and prepared it for sale - worked on it for months without monitor their exposure. Prior to sale, HPs had to check the timber – foresters used chainsaw to harves

the lab. After working with the timber all that time, they found that it was too contaminated to sell. 

S1/S4 Operations 

Inventory workers in Central Shops were never monitored. Worked many years before learning that marea were contaminated - identified items were taken to burial grounds by employees in protective clowas present in area for days before HP surveyed and found it was contaminated. 

S1/S4 Operations Cleaning masks - washing machine & dryer. Use chemicals to decontaminate. Put on and breathe to 

Replaced filters, etc. Washed masks by hand - no way to know how hot they were. Worker did have 

S2 CW Many subcontracted employees have problems because DOE never received records for them. S2 CW CW/claimant was told that claim was in process 4-6 weeks ago. When he asked if NIOSH had reques

that DOE does not have the records. 

S2 General Destruction of records. Nov-1989 (DuPont/Westinghouse transition). Worker witnessed 2 crews of l

weeks destroying records from DuPont & subcontractors. 

S2 Operations Worker had monitoring records as lab worker, not as administrative worker. Medical records lost d/t 

burning down. 

S2 Survivor Worker exposed in [redacted] - [redacted]. Wife requested records for claim and was told they coulS3 CW 

Who is included in proposed class of CWs? Not all people doing construction-type jobs were hired thsecurity clearance and accompanied workers who did not. Not classified as CWs, but required to be in keeping the CWs in sight at all times. Practice started late 1970s to early 1980s - construction boom, clearance. 

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Page 17 of 23 

Matrix 

Item Worker Type Description 

S3 General Some workers are not Construction or Production. Escorts, security guards, laundry workers, janitors

others who were not directly employed by SRS. 

S3 Operations Unmonitored admin worker was sent into rad areas all over site to install computers. Limiting propos

unfair to many other workers whose exposures are undocumented. 

S3 Subcontractor Subcontracted workers often worked in same areas as CWs, yet they are not covered in proposed SEC S3 Subcontractor Other types of workers should be considered, especially those hired by temporary agencies to perform 

security personnel, laundry workers, cleaners, etc. 

S4 General HP area was painted twice a year; 300,000 dpm in area due to leaking expansion joints in equipment t

through that area regularly to get to their work area. 

S4/WO Not Specified 

Worker was initially told there were no monitoring records for him. Long search & bureaucratic prob

dosimetry records. When records were obtained, claimant found that he had [redacted] for Pu and 12 

never been informed of this. Worker showed these records to "a NIOSH official" at a DOL Town Halshould have gotten those papers. Statement made it seem like a cover-up. [Discussion and input from indicated that the "official" may have been a DOE representative.] 

S5 CW Common practice for SRS to bid "hot" jobs to construction trades so production workers did not have S5 CW Some earlier HPs had started as CWs and made sure they looked after their own. "Corporate mentalit

plant shifted toward more educated supervisors; shift caused CWs to be treated as a lower class of em

S5 CW Safety training prior to 1989 was limited to what could be learned from a co-worker who may not hav

Westinghouse and Bechtel (construction mgt) started formal training. 

S5 CW Lack of training was common for CWs because jobs are very mobile. S5 CW 

RZ painted tools coming to Central Shops was an example of communication and training deficits - thtaken them if they'd known the significance of the painted tools. CW is like a swinging door - workerleave, come back six months later for another job. Many did not receive any radiation safety training. 

were often new hires waiting for clearance. Even when Bechtel started providing training, people hire

training often did not follow up with construction trades for several years. Improved by mid-1990s, bpersonnel had become better trained by that time. 

S5 CW HPs fitted workers with full-face respirators, but they relied on co-workers to show them how to dress 

when Bechtel took over safety operations from Westinghouse. 

S5 General No formal training under DuPont (1951–1989). Many experienced workers left with them in 1989. 

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Page No. 

Page 18 of 23 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Matrix 

Item Worker Type Description 

NOTICE

wever, th

S5 General No official "dress out" training. Coworker would show you how. Learned years later at another facili

sealed gaps between suit and gloves and boots. 

S5 Operations Production worker hired in 1961 had a short class on security and radiation when transferred to produ

his head." 

S5 Operations Main duties decontamination (including mask cleaning) - no formal training in how to perform dutiesS5 Operations An HP issued Stop Work Order when they found contaminated railroad ties when remediating rubble 

writing the order and his company was blackballed from bidding on future contracts for Westinghouse

DOL CW D&D workers from late 1990s (tore down tower 400 Area) could not verify employment - subcontrac

business and not paid social security or income taxes. 

DOL CW DOE could not find employment records for one of a CW's jobs (subcontractor). DOL Not Specified Wife had to file FOIA request to get deceased husband’s records. 

TBD/DR General When EEOICPA was first enacted, sick workers were told they would be compensated within 9 mont

paperwork. EE’s tracking number is among the first 100 filed, and the claim has still not been compe

TBD/DR General Many claimants are dying from their illnesses, and many survivors are frustrated by the slow bureaucrTBD/DR General Burial grounds are not listed in critical buildings & areas. 
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ATTACHMENT 2: WORKER COMMENTS FROM PETITIONER SOURCES 

Matrix 

Item Worker Type Description 

9 Operations 

Tritiated water was pumped into the system right out in the atmosphere at the DW plant. They pulled samples wearing just a lab coat and gloves. There were some jobs that required a plastic suit - when they replaced pumps or cleaned up a spill, but not for routine work. 

9 Operations Workers were told to drink beer to flush tritium out through the urine. Statements imply an understanding that this diluted the amount of tritium in the samples so it wouldn't show on record. 9 Operations Worker has been told that badges were not accurate. They wouldn't pick up tritium. They only picked up radiation. That would cover all the radiation you'd been exposed to but not tritium. 9 Operations 

DW plant (420D) separated tritium from water that had been drained from the reactor. They reconcentrated it and put it back in drums and sent it back to the reactor. They would pump it back in so they wouldn't have to contaminate new water. This had high concentrations of tritium in it. 

12 CW 

Monitors went off constantly, but were explained away by a power surge, or workers were told the device wasn't working properly. If these devices weren't working properly, how can NIOSH or SRS know what exposure the workers received? 

12 General 

Incident in 221 H. Airborne Pu from glove boxes in 410 North (where workers operated in full respiratory protection) to 410 South (where they did not). Supervisor did not want it documented because it looked bad. HP's log book was stolen while he was away. 

12 General ER on page 29 says there is no evidence of documentation of incidents that would have resulted in very high exposures. Of course there is no evidence - SRS wanted it that way. 12 General 

Incident #7 of "Dirty Thirty" mentions that 900 people needed to clean up contamination over 3 months. Workers who were there said people were brought in from all over the plant and were "maxed out" on their annual doses in a matter of minutes, yet this incident never seems to cause much of a blip in dose reconstructions. 

12 General 

Laborers filled water can from a barrel that caught leaking water from heat exchanger in 100 Area and used water to spray drilling area to control dust. The barrel had not been roped off. Everyone was contaminated when they sprayed the water. 

12 General 

ER on page 26 talks about Naval Fuels manufacturing facility operating from 1985 through 1989. Wrong. Naval Fuels never produced any fuel - the facility malfunctioned on initial start-up and the whole building was crapped up along with the workers in the building. The building was closed. 

12 Operations Workers doubt that unusual occurrences at DW are documented. If HP came down, there would be a report on that. But that was very, very seldom. 

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Matrix 

Item Worker Type Description 

12 Operations 

[At DW plant] they'd have a pump problem or tank overflow where they had to get in there and clean it up. They'd isolate it and it was important to get it cleaned up as quick as possible. Everybody that worked there was involved in these kinds of events at one time or another. It wasn't routine - it was supposed to be an unusual incident - but it happened more times than you wanted it to happen. 

12/S3 General 

The absence of information from DOE about radiation incidents is a continuing theme for both construction and non-construction SRS workers applying for EEOICPA benefits. DOE has not provided DOE critiques, notes and/or minutes of safety meetings and other documents related to after-action operations conducted after incidents. 

19 General 

New in-house publication, part of "Savannah River Site Cold War Historic Property Documentation" project, is specific to 330/M Area. We have heard for years about early test reactors, but this publication gives confirmation of some of their processes. 

19 General 

"Dirty Thirty" was a memorandum published in 1985 of the most significant reactor incidents at SRS up to that point. It was part of an in-house study of reactor safety based on the experience of an 11-man selection committee and sources of information available to them. 

19 General 

ER on page 18 says R Reactor started in 1963 and shut down in 1964 when demand for Pu and H3

decreased. NOT TRUE. R Reactor was shut down because of a meltdown. There was also a meltdown of one of the fuel rods in K Reactor. 

19/24 General 

305-M Test Pile was considered critical to SRP mission - used to test bare slugs, canned slugs, and control rods. Began construction June 1951, went critical September 1952. Un-cooled, natural uranium, graphite moderator, similar to what was used at Argonne and Hanford. "The slugs and cans were moved manually after testing back to the trays. Notably, no special shielding was used for the hot tested materials after irradiation although a potable (sic) Lucite shield was to be provided for worker protection." Clients say no one was monitored then; HPAREH summaries & NIOSH DRs almost never show dose before 1954. 

21 CW CWs and production workers literally worked side by side, separated only by a rope. DuPont production dressed out; CWs with no gear and no monitoring. 23 CW 2005 CPWR study of >2,300 CWs: a significant # have no deep dose or all recorded "zero" doses in HPAREH. Dose records appear deficient for 50%–90% of CWs employed at SRS. 23 CW 

If a site or project would read 3, they would rotate people in every few hours to keep readings/exposures low, because anything reading 2 or above would require a supervisor to go to Wilmington and explain. It's apparent that supervisors and HPs knew rules & regs, but they also knew how to adjust things to keep their records clean. 

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Item Worker Type Description 

23 General 

717 F Building - problem with dosimeters and film badges left on racks. Set dosimeters at "0" at end of shift - had a reading of 50 or more the next morning due to night shift work and x-ray work in the building. NIOSH will say the workers got higher doses recorded than they actually experienced and this is "claimant favorable," but petitioner sees it as another indication that the monitoring program lacked integrity and cannot be trusted. 

23 General Workers sometimes wore monitors with someone else's ID number. 23 General 

Workers at Tank Farms worked repeatedly in the area without a dosimeter badge. Several occasions when TLD badges left on board by guard gate were gone the next day. Tanker trucks spilled rad material on road, wiping out all of the TLDs. Workers sometimes did not get new badges for a day or two - worked without them. 

23 General 

Most jobs were done without HP personnel or supervision, and no records were kept. Workers were used to having no badges, especially on Saturday and Sunday when they weren't available, so work continued on as usual. 

23 Operations Security worker had access to entire site and sporadically wore a badge. Died at age 30 of lung cancer - non-smoker w/no family history of cancer. 23 Operations Workers in DW plant were not monitored at times. The monitoring wasn't done all the time [dosimeter/badge]. 23 Operations Even in the reactor, I'd walk all over the building and wouldn't be monitored. 

23/12 General 

Numerous statements from May 2008 minutes identify key issues for all SRS workers, especially in 

1950s and early 1960s:  Lack of monitoring records  Workers not being monitored or having monitors that did not work  Workers leaving badges outside radiation zones  No records of incidents where workers were exposed 

24 General 

313-M building, Nov 1952 – Jul 1953, "90,109 reactor grade uranium slugs were canned and a number of problems, such as voids, penetration, or bare slug quality were isolated for improvement." It is hard to imagine that the 64 unmonitored operators and 12 supervisors were not impacted, but there are no radiation records available before 1954. 

S1 CW Workers' safety was not taken seriously. The attitude at the site was if you can do it safely, do it, but if you can't, do it anyway. 

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Matrix 

Item Worker Type Description 

S1 General Worker in supposedly clean area was found to be contaminated; pants & shoes were taken. S1 Operations [At DW plant] normally we didn't have HPs. They only came down if we called them. Very seldom. S1 Subcontractor 

Subcontractor came on site in 1990 to tear down bubble towers in the 400 Areas. Workers had no protective clothing or monitoring equipment. There were no HP personnel to check the area. Workers were told to get in and get out. 

S2 CW 

Petitioner personally witnessed crews of laborers shredding records - time cards, log books, monitoring reports, everything from offices of DuPont and subcontractors. The law says if records were destroyed or missing, the SEC should be applied. 

S2 Operations Long-term worker - DOE had no external monitoring records since 1960. There were no tritium monitoring records for several years when there should have been. S3 Operations 

Many workers employed by operations or production performed jobs that would be considered construction or construction support. Petitioner has provided at least 18 examples: crane operators, back-hoe operators, power and reactor operators, riggers, maintenance workers, mechanics, inventory workers, truck drivers hauling waste to and from construction sites, delivery drivers, surveyors, workers who cruised or cut timber, workers who escorted construction workers into radioactive areas, laundry workers, cleaning personnel, instrument repair workers, workers who serviced vending machines in hot areas where construction workers were working, administrative 

and lab personnel who worked in construction areas or who delivered mail, checks or test samples from the construction workers, and others who performed similar jobs or worked in similar areas but were listed as working in operations or production. 

S4 Operations There was [redacted] that was diluting [redacted] urine samples to keep them from finding positive results. S5 General ER states that closure of Naval Fuels facility is under way. Wrong. Building was completely torn down several years ago; nothing is left. 

WO CW SRS Site Profile was revised a number of times in 2004 and 2005, but concerns raised by building trades in 2003 have not been addressed. WO General NIOSH believes the records, even though they are incomplete and unreliable, because there is nothing else to use. What about what the workers have said over the years? 

WO/S3 General Comments made by NIOSH rep at May 08 meeting indicated worker comments were relevant to petition review & administrative review of the petition may indicate a need to evaluate all workers. 

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: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Matrix 

Item Worker Type Description 

NOTICE

wever, th

WO/S3 General 

Dr. Howard's panel did not consider 29 pages of SRS worker testimony from May 2008 outreach meeting pertaining to evaluation of class definition. Minutes were not posted or available to the panel during its administrative review. Minutes contain significant testimony and information. Without consideration of this evidence, petitioner has been denied due process. 

WO/S3 General 

The review panel's conclusion that it had not received sufficient material to extend the class definition was premature and did not give petitioners fair or scientific consideration. Petitioners were denied the right to have panel consider relevant information, particularly evidence of missing DR-related records for all workers at SRS. 

WO/S3 General 

Petitioner requested administrative review of DHHS panel findings and requested copies of documentation relating to appointment of the panel, mission/objective given to panel, deliberations and conclusions of panel. Petitioner specifically questioned the process because the panel did not wait for minutes of May-08 outreach meetings to be available. Petitioner asked NIOSH to rescind Dr. Howard's decision and either extend the class definition to include all SRS workers or have another panel review the findings after having access to all relevant information. 

WO/S3 General 

NIOSH provided almost 500 pages in response to FOIA Request, but nothing addresses panel's lack of consideration of statements given at May-2008 outreach meeting. There are no panel findings or 

report or recommendation in the FOIA material. NIOSH denied release of 4 pages of documentation pertaining to pre-decisional internal communications. Petitioner's representative asks ABRWH and/or Work Group to address the failure of the panel to examine relevant evidence. 

DOL CW 

ER on page 35 says they were able to get a complete list of all construction workers for 1960. Hard to believe, considering subcontractors were in and out of that site on a daily basis. SRS didn't keep 

logs like that, so how did they come up with complete records? 

DOL Subcontractor A subcontractor did not pay taxes or social security for the workers. There are no records that the contractor was ever on site. 

TBD/DR General 

Lack of confidence in DR results. In October [2007], a DOL representative testified in a Congressional hearing that DOL had returned 2,811 DR cases in 2007 for re-work due to deficiencies identified in the work performed. After re-work, 385 claims that had been denied were approved (14% were wrong the first time around). DOL had another 9,400 cases that would be sent back for re-work, meaning that half of the cases completed would be sent back. 

TBD/DR General 

NIOSH says they used the telephone interview. Surviving spouses or children are at a disadvantage, because they don't have adequate knowledge of exposure history, monitoring, or 

incident involvement. Everything was secret.