2.0 TASK 2- SITE PROFILE REVIEW 

This section presents SC&A's proposal for performing Task 2 of the TORP. Much ofthe 

material presented above regarding project management for Task 1 applies to this task also and is 

not repeated here. 

2.1 UNDERSTANDING OF THE TASK AND ITS OBJECTIVES 

It is our understanding that this task includes the following subtasks: 

Prepare a site profile review procedure (delivered to NIOSH within one month 

from authorization to proceed) 

Review the conditions, processes, practices, and incidents at selected DOE and 

A WE facilities covered under EEOICPA to evaluate the adequacy of the 

information available in the NIOSH site profiles for 10 to 12 DOE facilities and 2 

to 4 A WE facilities. 

(3) Evaluate worst-case dose estimates resulting from the site profiles to determine 

adequacy of the data and validation of the data and assumptions. 

(4) Conduct meetings and interviews with site experts as authorized by the Board 

(5) Prepare reports, including: 

Site profile review procedure 

Monthly summary of progress for all site profile reviews 

A final report for each site profile review 

A final summary report with aggregate findings 

2.2 TECHNICAL APPROACH 

In order to accomplish the objectives of this task, SC&A will prepare a site profile review 

procedure and then, following approval of the procedure by the Board, use the procedure to 

accomplish the following: 

(l) Identify and evaluate the approach taken in compiling the site profiles through a 

comprehensive process of independently identifying the selected site's operational 

history 

(2) Review all relevant data sources, such as occurrence reports, inspection 

documentation, safety analyses, etc. 

(3) Interview worker representatives, worker advocacy groups, and other individuals 

having knowledge or expertise on site operational or radiological history 

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( 4) Evaluate worst cases doses resulting from the site profiles to determine adequacy 

of the data and validation of the data and assumptions 

Prepare a Site Profile Review Procedure 

SC&A will use this proposal of work as the basis for preparing a site profile review procedure. 

We believe that the technical approach for performing site profile reviews as described in the 

following sections constitutes a draft framework for a review procedure and represents a draft 

deliverable for this subtask. 

Reviewing Site Operational History 

For many DOE and A WE sites, reliable dosimetry records may be lacking, particularly for 

workers from the 1940s through 1960s. In these instances, historic operat!e:.:.al information that 

includes the nature of operations, radiological source terms in use, process material 

concentrations, and location and time periods of worker activities may be the only data available 

for dose estimations. Such information can be extracted from historic records and documentation 

being collected by (or accessible from) the Department of Energy, including operational records, 

material inventories, safety and health inspections and assessments, occurrence reports and 

routine memorandum and facility reports. This possible source of information will be surveyed at 

the DOE site or A WE records collection point to ascertain whether the site profiles adequately 

reflect at least the following information, where feasible: 

Operational processes over time, including improvements, upgrades, modifications 

and terminations (important because worker exposures are often higher during 

major process changes). 

Historic radiological inventory, source terms, and movement through facility 

("mass balance") to include feed material, products, and byproduct and waste 

streams. 

Any unplanned events, including radiological over-exposures, contaminations, 

releases, spills, criticality incidents, and unusual occurrences. 

Changes in contractor management and attendant changes in safety policies, 

procedures and practices (important because new contractors import new 

radiation protection programs). 

Applicable standard operating procedures, memoranda, directives or recorded 

practices governing onsite management of radioactive materials and processes. 

Actual historic operational practices established by first hand accounts (e.g., 

worker representatives, site "experts," etc.) (important because actual facility 

practices often varied .from official procedures). 

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Historic radiation protection programs in place, including personnel monitoring 

requirements, protective equipment practices, dosimetric techniques and 

equipment in use, and procedural enforcement history (important to determine 

whether and to what degree the dosimetry program reflected actual potential 

exposures possible, given source terms involved). 

Worker rosters with identifiers, work assignments and location, as well as 

summary of work histories sufficient to determine what categories of workers 

were assigned to what type and locations of radiological work. 

It would be useful to have data on the number of monitored workers, number of workers with 

doses higher than the minimum detectable levels, average measurable recorded doses, minimum 

detection levels, and whether doses below the detection limit were recorded as zero. Even better 

would be to have data on number of workers in specified dose ranges. The reviews will check if 

this information is provided or if it appears feasible for the site profiles to include such 

information. 

The foregoing information will be used in a comparative manner to ascertain whether the site 

profiles are complete in how they characterize, from a historic standpoint at a particular site, what 

radiological materials were present and in what concentrations and chemical forms, what worker 

groups may have been in proximity with sources of exposure and whether certain activities or 

unplanned events may have made such exposure likely, and what administrative procedures, 

operational practices, protective equipment use, and facility conditions may have influenced the 

likelihood of such exposure. 

2.2.3 Reviewing Relevant Data Sources 

SC&A will determine whether the NIOSH contractor appropriately identified, evaluated, and 

incorporated all relevant data sources by comparing the extent to which such information is 

present in the profile with what can be identified via an independent review of such sources of 

information. Data sources that will be scanned include the following: 

Department of Energy 

Field Offices 

Operating contractors 

Institutional histories 

Inspector General files 

Headquarters and field oversight reports 

Radiation exposure assessments 

Atomic Weapons Establishment 

Centers for Disease Control 

Nuclear Regulatory Commission 

Environmental Protection Agency 

General Accounting Office 

Defense Nuclear Facilities Safety Board 

Congressional Hearing Records 

2-3 
State environmental and safety regulatory agencies 

National Academy of Science 

Administrative/court records 

Department of Defense 

Environmental Monitoring Laboratory (formerly HASL) 

Workers compensation records 

Worker and public advocacy groups 

Historic records in private hands 

It is anticipated that a baseline of relevant information contained in these and other data sources 

will be established at the onset, facilitating subsequent comparisons with site profile information. 

2.2.4 Interviewing Sources of Site Knowledge 

SC&A, as necessary, will conduct one-on-one or group interviews with selected sources including 

worker representatives, worker advocacy organizations, individuals with site "expertise" due to 

past employment or familiarity with operational history, and others who can verify the adequacy 

of site-profile information that has been collected by the NIOSH contractor. 

Interviews will be conducted where convenient for these groups, including near the actual site in 

question. Lines of inquiry will include the following: 

How did actual radiation protection practice compare with documented policy and 

procedures? 

Were there instances of obvious "missed dose," e.g., not wearing or improperly 

wearing dosimeters, non-recording of dose, etc.? 

Were there any incidents involving potential radiation exposure, whether reported 

or unreported? 

Were there special work activities or facility modifications which constituted 

process changes that increased radiation exposure potential? 

Were workers concerned about past exposure or radiation protection practices? 

How did management respond and what, if any, changes occurred in onsite 

practice? 

Did workers wear protective equipment, as required? 

Were radiological jobs planned for exposure minimization (e.g., ALARA)? 

What was the general housekeeping in the facility; was radiological contamination 

common during the history of the facility? 
Were there special feed materials introduced or contaminants of concern identified 

from which radiation exposures may have resulted? 

Were there certain work activities at the facility that were considered "hotter'' jobs 

from the standpoint of potential radiation exposure? 

Were safety procedures followed literally and did management assure that they 

were enforced uniformly? 

In terms of conduct of operation, were workers permitted to smoke, eat or drink in 

control areas? Was protective clothing and equipment worn in these areas; was 

egress monitoring conducted? 

Were negative or "zero" doses recorded on periodic dosimetric records despite 

known exposure to significant radiation sources? 

Were records and other documentation of radiation exposure discarded or retained 

by management? 

Were there cases of over-exposed film and how were they treated? 

The information extracted from these interviews will be used to ascertain the completeness and 

representation of that in the NIOSH site profiles. 

2.2.5 Evaluate Wont Case Doses 

Using the site profiles and the information compiled under sections 2.2.2 through 2.2.4 described 

above, an evaluation of the worst case doses will be performed to determine adequacy of the data 

and data validation of the data and assumptions. This will be accomplished in a manner that 

parallels the blind dose .reconstruction procedures described above, with the exception that upper 

end estimates of the doses will be derived by using upper end dosimetry and bioassay data, area 

monitoring data, and process knowledge, as compiled in the site profile. 

2.3 TASK MANAGEMENT 

In addition to his role as Deputy Project Manager, j will serve as, lead worker 

and site profile reviewer. As explained earlier, knows the health and safety issues 

at DOE and A WE facilities and is therefore especially well qualified to provide independent 

reviews of worker and site profiles, as directed by the Board as Deputy 

Assistant Secretary for Health and Safety for DOE's Environmental Safety and Health (ES&H) 

division and is intimately familiar with DOE operations and radiation protection practices across 

the DOE complex. will be assisted by and•••••• 

Both and have over 30 years experience, a large portion of which consisted of 

working with on matters related to Environmental Safety and Health (ES&H) at 

DOE facilities. will also participate in the review of site profiles. a - is an expert in nuclear engineering and also a nationally recognized advocate for worker 
rights. In addition, in fulfilling his responsibilities under this can draw upon 

the expertise of any member 

a 

of the project team, or draw upon outside expertise if necessary. We 

anticipate thar? and may be called upon, along with the internal and external 

dosimetry expertise on the project team, to in all aspects of the site profile 

reviews. As the work on this task unfolds, it may be necessary to add additional personnel to the 

project team. Any new individuals brought aboard to participate on this project will first undergo 

our conflict of interest avoidance procedures and review by the Board. 

2.4 WORK HOUR ALLOCATION AND SCHEDULE OF DELIVERABLES 

Exhibit 2-1 presents the work hour allocation for this task. We set aside a modest level of effort 

for preparing the site profile review procedure, given the level of effort that has already been 

incorporated into preparing the technical approach to this section. Once the procedure is finalized 

and approved by the Board, it will be used to perform site profile reviews of 10 to 12 DOE and 2 

to 4 A WE site profiles. We assume that, on average, each review will require about-work 

hours. 

The ~aft procedure will be delivered within one month from authorization to proceed, which we 

assume will be February 2, 2004. Upon approval of our procedure by the Board, we will begin 

the site profile reviews. In accordance with the TORP, we have scheduled one year to complete 

the review of all deliverables, including monthly summary of progress for all site profile reviews, 

a final report for each site profile review, and a final summary report with aggregate findings. 

For the purpose of estimating the level of effort required to meet with site experts, we assumed 

that half of the 16 site profiles will require such meetings and that each visit will require two 

individuals for .hours each, for a total of.work hours. 

We recognize that SC&A obligations regarding this task also include support to Advisory Board 

meetings. The level of effort to support Board meetings provided in Task l includes addressing 

the status and findings ofTask 2 activities in addition to Task 1 activities. 

2-6 
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