Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

SC&A DRAFT REVIEW OF ORAUT-RPRT-0080

Contract No. 211-2014-58081 

SCA-TR-2017-SEC010, Revision 0 

Prepared by 

Robert Barton, CHP 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, Virginia, 22201

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

August 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 document 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 Draft Review of ORAUT-RPRT-0080

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2017-SEC010

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: August 2, 2017

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

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

DOCUMENT 

REVIEWER(S):

John Stiver, MS, CHP [signature on file]

Joe Fitzgerald, MS, MPH [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 8/2/2017 Initial issue
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TABLE OF CONTENTS

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

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

2.0 Summary of ORAUT-RPRT-0080 Conclusions ................................................................ 6

3.0 Discussion of Area Radiological Controls .......................................................................... 7

3.1 Routine Contamination Surveys ............................................................................. 7

3.2 Ambient External Doses ......................................................................................... 8

3.3 Available Air Monitoring Data ............................................................................... 9

4.0 Individual Monitoring Records among Claimant Construction Workers ......................... 12

4.1 Case 1 .................................................................................................................... 12

4.2 Case 2 .................................................................................................................... 13

4.3 Case 3 .................................................................................................................... 13

4.4 General Discussion ............................................................................................... 14

5.0 SC&A Conclusions and Recommendations ..................................................................... 16

6.0 References ......................................................................................................................... 17

Appendix A: Example of a Daily/Weekly Survey Logsheet for Building 235-F ..................... 18

Appendix B: [Redacted in Full] ................................................................................................ 19
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

CATI computer-assisted telephone interview

CS Central Shops 

DOL U.S. Department of Labor 

EE energy employee 

FP fission products 

GM geometric mean

GSD geometric standard deviation 

IA induced activation

μCi/cm3 microcurie per cubic centimeter

mR/yr milliroentgen per year

NBL Neptunium Billet Line

NIOSH National Institute for Occupational Safety and Health

Pu plutonium 

PuFF Plutonium Fuel Form Facility

RWP Radiation Work Permit

SEC Special Exposure Cohort 

SRDB Site Research Database

SRS Savannah River Site 

SWP Safe Work Permit

TLD thermoluminescent dosimeter
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1.0 INTRODUCTION AND BACKGROUND

Since 2016, the National Institute for Occupational Safety Health (NIOSH) has released a series 

of reports that are specific to reconstructing neptunium exposures at the Savannah River Site 

(SRS). The three neptunium reports are as follows: 

• ORAUT-RPRT-0065, Revision 00, An Evaluation of Neptunium Operations at Savannah 

River Site (NIOSH 2016a)

• ORAUT-RPRT-0077, Revision 00, Evaluation of Health Physics Area and Health 

Physics Department Codes to Identify Neptunium Workers at the Savannah River Site 

(NIOSH 2016b) 

• ORAUT-RPRT-0080, Revision 00, Potential Neptunium Exposure to Plutonium Fuel 

Facility Construction Workers in Building 235-F at the Savannah River Site (NIOSH 

2017; hereafter “RPRT-0080”) 

The first report describes the historical production and separation of neptunium materials at SRS, 

which includes a timeline of operations as well as a discussion of radiological controls directly 

related to neptunium handling. The second report presents a quantitative comparison of Health 

Physics Area and Health Physics Department codes that are included in certain formats of SRS 

external dosimetry records. The purpose of NIOSH’s analysis in the second report was to 

demonstrate the correlation between the external dosimetry codes used to characterize the 

general work area and department for workers with elevated internal exposure potential to

neptunium. The purpose of this second report was to develop a method to identify other 

potentially exposed workers for assignment of unmonitored coworker intakes. SC&A delivered 

its review of these first two reports in March and April 2017 (SC&A 2017a and 2017b, 

respectively); therefore, those reports and SC&A’s responses will not be discussed further in this 

document. 

The third neptunium report (RPRT-0080) describes the construction of the Plutonium Fuel Form 

Facility (PuFF) in Building 235-F, which occurred from December 1973 into January 1977. In 

addition to the historical information related to the construction of the PuFF, RPRT-0080 

describes the radiological controls and monitoring techniques in place to protect the construction 

workers from the neighboring facilities in Building 235-F (notably the Neptunium Billet Line

[NBL] and the Uranium Alloy Line). The radiological controls included both passive controls 

(such as limits on access control and negative airflow from clean areas to controlled areas) and 

active controls (such as continuous air sampling, routine health physics contamination 

monitoring, and fixed ambient external dose badges). This report presents SC&A’s review of this 

third neptunium report (ORAUT-RPRT-0080), which identified three findings and three

observations that are discussed in the following sections. 
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2.0 SUMMARY OF ORAUT-RPRT-0080 CONCLUSIONS 

Section 5.0 of RPRT-0080 contains the summary conclusions about the internal and external 

exposure potential for construction workers involved in construction of the PuFF. With regard 

specifically to external exposure, RPRT-0080, Section 5.0 states: 

Because of the radiological controls in place at the NBL and around the 

construction of the PuFF and the procedures requiring film or TLD badges in 

areas where potential worker exposures could occur, it is reasonable to assume 

that construction workers would have been monitored for external radiation 

exposure either directly if warranted or indirectly through the area monitoring 

dosimeters. Therefore, the potential for undocumented external radiation 

exposures to the PuFF construction workers is very unlikely. [page 16; 

emphasis added]

Specific to internal exposures, RPRT-0080, Section 5.0 states the following: 

Internal exposure to PuFF construction workers from airborne contamination 

from the NBL line and the Alloy Line was unlikely due to routine, consistent air 

sampling and contamination monitoring.... 

From the air sample data and site documents obtained and reviewed, there 

appears very little likelihood that the construction workers building the PuFF 

facility in Building 235-F between 1973 and 1977 would have received 

inadvertent, unmonitored internal or external exposures. [page 17; emphasis 

added] 

Underpinning both of the previous statements is the assumption that both a comprehensive and 

diligent personnel monitoring program and a thorough and widespread area monitoring program 

existed. In the case of the former, NIOSH has assumed that all workers who should have been 

monitored were monitored both internally and externally, and that those records are available for 

dose reconstruction. In the case of the latter assumption, NIOSH presumed (1) that area 

monitoring (including ambient external dose monitoring, area contamination surveys, and 

continuous air sampling) is sufficient to identify any exposure potential and would have 

triggered appropriate personnel monitoring as required, (2) or that ambient external dose 

monitoring within Building 235-F would provide a means to assign appropriate external dose to 

workers who were not directly assigned a dosimeter

Observation 1: Based on the statements in RPRT-0080, Section 5.0, SC&A presumes that 

NIOSH does not intend to assign any unmonitored coworker intakes or external doses to PuFF 

construction workers. Therefore, any dose assigned to this subset of construction workers would 

be based solely on individual monitoring records (where available). 
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3.0 DISCUSSION OF AREA RADIOLOGICAL CONTROLS

3.1 ROUTINE CONTAMINATION SURVEYS

As indicated in the previous section and discussed in detail in Section 4.0 of RPRT-0080, daily, 

weekly, monthly and quarterly survey activities were routinely made by health physics personnel 

in Building 235-F. Specifically, NIOSH states:

A set of 16 weekly forms including the daily surveys for that week and 2 quarterly 

forms that included the monthly surveys for those quarters have been acquired for 

Building 235-F for the period between December 1973 and December 1974. 

[NIOSH 2017, page 13] 

Appendix A shows an example screenshot of a daily/weekly survey logsheet. The daily routine 

duties for Building 235-F in 1974 were as follows (Brown 2012): 

1. Perform 60 cycle, source & background checks on scalers.

2. Source check all count rate meters for proper operation. 

3. Source check all hand and shoe monitors for proper operation. 

4. Prepare instruments for return to Calibrations. (Order on 8-4).

5. Survey lunch room. (Clean zone guides.) 

6. Survey stepoff pads between regulated and clean zones. (Clean zone guides.) 

7. Survey process room exit stepoff pads. (Regulated zone guides.) 

8. Survey all cabinet glove ports in use and floors for billet line & Np process 

rooms and air locks. (Regulated zone guides.) 

9. Change routine air samples, per OSR 4-252, 253, count, calculate & record 

results on Forms OSR 4-251, 252 and 253. 

10. Take Radon-Thoron background air sample. 

The weekly routine duties for Building 235-F in 1974 were as follows (Brown 2012): 

1. Survey glove ports of cabinets not in use and which were not surveyed daily.

See items 8 of daily routines. (Regulated zone guides.) 

2. Make a smoke check to determine air flow direction at all doors of the Np & 

billet line process rooms.

3. Survey regulated service corridors and decontamination room. (Regulated 

zone guides.) 

4. Survey regulated Maint & E & I shop. (Regulated zone guides.) 

5. Survey regulated toilet. (Clean zone guides).

6. Take water samples from billet leak testing tanks and send to 772-F for alphabeta-gamma analysis. 
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SC&A reviewed the Brown 2012 reference provided in NIOSH 2017 and concurs that NIOSH 

obtained only a partial set of daily/weekly survey logsheets.1

1 SC&A counted 17 daily/weekly survey logsheets available in 1974 in the supplied reference (Brown 2012), while 

NIOSH indicates there were 16. SC&A assumes the discrepancy is the result of partial weeks reported at the start 

and/or end of the year.

Specifically, a complete set of 

daily/weekly logsheets is available from December 31, 1973, through March 22, 1974, with five 

additional daily/weekly logsheets available for 1974 for the weeks beginning April 1, June 24, 

September 23, September 30, and December 23. This represents only a very small percentage of 

the time during which the PuFF was constructed (~17 weeks out of ~146 total construction 

weeks,

2 or 11% of the total construction time). It is unclear whether additional daily/weekly 

survey logsheets are available and have not been captured or are currently unavailable for 

review. SC&A was unable to locate additional routine survey logsheets among the 9,774 

documents available in the Site Research Database (SRDB) for SRS. Without further 

information, it may be inappropriate to extrapolate the results of routine surveys from a relatively 

short period at the beginning of construction to the remainder of PuFF construction activities.

2 The total of 146 weeks for construction of the PuFF was calculated assuming a start date of December 1, 1973, an 

end date of January 31, 1977, with 3 months subtracted for which no construction work took place (March 12, 

1976–July 12, 1976). 

Furthermore, the routine daily/weekly survey forms note that when contamination is found that is 

above the clean and regulated control guidelines, the Health Physics department should fill out a 

“radiation survey logsheet,” which documents the situation and any “unusual conditions” 

(Brown 2012). SC&A noted that the Brown 2012 reference given in RPRT-0080 included eight

“radiation survey logsheets” that document 16 specific Health Physics activities. In each of the 

eight cases, there was no available daily/weekly survey report covering the relevant date of the 

unusual conditions. Without a full set of daily/weekly survey reports, it is impossible to know 

how many such situations occurred during the construction of the PuFF. 

Finding 1: The conclusion that routine daily and weekly contamination survey activities 

restricted all potential radioactive contamination to the prescribed limits is supported by survey 

documentation that only covers approximately 11% of the total PuFF construction time. It is 

unknown whether the currently missing daily/weekly survey logs are available and have not been 

captured or are unavailable. 

3.2 AMBIENT EXTERNAL DOSES

Regarding the monitoring of ambient external doses (beyond the contamination smear surveys 

described in the previous section), Section 4.0 of RPRT-0080 states the following: 

Daily, weekly, and monthly control surveys were performed at specified locations 

in Building 235-F. These were performed to monitor ambient exposure rates.... 

Areas within the corridors were monitored routinely for ambient exposure rates.

It is not certain they entered the PuFF construction area via the corridor outside 

the NBL facility to report for work. [pages 12, 15; emphasis added]

 
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This is echoed in DuPont 1966, which states:

In order to provide a record of potential radiation exposures of personnel who do 

not wear film badges but could be exposed intermittently to low levels of radiation 

during their work, Health Physics shall establish film monitoring stations so 

that radiation exposures of these people can be estimated. Film from these 

stations shall be processed, read, and the data permanently recorded at least 

once a month. [PDF page 2; emphasis added]

RPRT-0080 does not make further reference to the temporal availability, location, and magnitude 

of stationary film monitoring stations in Building 235-F. Nor does RPRT-0080 discuss how such 

potential information could be used for an individual claimant’s dose reconstruction. 

Table C-19 of ORAUT-TKBS-0003, Revision 03, Savannah River Site (NIOSH 2005), provides 

a method for estimating ambient external doses based on environmental releases for specific 

areas (in this case “F Area”). The ambient external doses presented in NIOSH 2005 are derived 

from a series of environmental monitoring reports that list the average annual penetrating dose 

for the corners of operating areas of the 200-F Area. However, it is not clear whether these 

measurements are representative of ambient exposure rates that are physically inside Building 

235-F. In addition, there is significant variability among the annual exposure measurements at 

the operating corners. For example, in 1974 the corner of operating area measurements ranged 

from 73 milliroentgen per year (mR/yr) to 737.3 mR/yr (DuPont 1975). 

Observation 2: RPRT-0080 is not clear about how (or if) stationary film monitoring stations 

found in Building 235-F will be utilized in individual dose reconstructions for workers who were 

not directly monitored for external radiation. Ambient exposure rates have been derived in 

NIOSH 2005 based on annual environmental monitoring, but it is not clear that they are 

representative of exposures experienced within Building 235-F. 

3.3 AVAILABLE AIR MONITORING DATA

Table 2-3 in Section 4.0 of RPRT-0080 (recreated as Table 1 below) compiles available air 

sampling data during the period of construction of the PuFF at SRS. As seen in the table, the 

construction area and the clean corridor were monitored via air sampling, along with the 

pertinent areas of the NBL and Uranium Alloy Line. Not surprisingly, many more air samples 

were taken in the regulated areas of the NBL and Alloy Line than were taken in the construction 

area. In addition, the maximum observed air samples were significantly higher in the actual NBL 

and Alloy areas than surrounding clean areas, which is to be expected. 

However, the calculated geometric mean (GM) alpha air concentration for the construction area 

was actually higher than the GM for the 107F – Regulated Corridor, which is directly adjacent to 

the NBL. In addition, the GM for construction areas was also higher than room 107B – NBL End 

(end of the NBL). At the calculated 50th percentile, the construction area air samples were 

numerically the same as the 107F – Regulated Corridor and comparable to the 50th percentile 

calculated for the 107B – NBL End. Figure 1 shows these two locations. 
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Observation 3: The calculated geometric mean and 50th percentile values for available air 

samples in the construction area are comparable and/or bound the calculated air samples from the 

107F – Regulated Corridor and the 107B – NBL End locations. These locations are either 

directly adjacent to the NBL (107F – Regulated Corridor) or inside the airlocks of the NBL 

(107B – NBL End). 

Table 1. Recreation of Table 2-3 from RPRT-0080 (NIOSH 2017) Showing Air Sample 

Results from 1973 to January 1977 

Location

Number 

of 

Samples

Maximum 

(μCi/cm3

 × 

1.0E-12)

50th

percentile 

(μCi/cm3

 × 

1.0E-12)

95th

percentile 

(μCi/cm3

 × 

1.0E-12)

GM 

(μCi/cm3

 × 

1.0E-12)

GSD

Construction Area 101 0.22 -0.045 0.169 0.0322 2.22

Clean Corridor East 729 1.20 -0.054 0.190 0.0384 5.15

107F – Regulated 

Corridor 1507 1.71 -0.045 0.230 0.0234 5.18

107A – NBL Operations 1004 11.5 -0.029 0.185 0.0422 9.98

107D – NBL 

Maintenance 953 1.83 -0.021 0.200 0.0381 5.49

107B – NBL End 697 1.10 -0.043 0.200 0.0253 5.65

160 – Alloy Line 

Operations 1624 10.7 -0.044 0.266 0.0366 4.66

162 – Alloy Line 

Maintenance 1623 174 -0.039 0.300 0.0928 10.8

Figure 1. Neptunium Billet Line Area Showing Locations of the Airlocks and Rooms 107B 

– NBL End and 107F – Regulated Corridor 

The air sampling results taken in the construction area by date were plotted in Figure 3-1, 

Section 4.0, of RPRT-0080 (reproduced below as Figure 2). Also plotted is the percentage of 

PuFF construction that had been completed at the time of the air sampling. It should be noted 

that most of the air samples shown to the right of the figure were taken after construction was 
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complete. Aside from a dozen air samples beginning in November 1976, all of the constructionrelated air sampling occurred before July 1974, when only 20% of the construction of PuFF had 

been completed. 

Figure 2. Screenshot of Figure 3-1 from RPRT-0080 (NIOSH 2017) Comparing Available 

Air Sampling to the Construction Progress of PuFF (with SC&A annotation) 

Finding 2: A temporal gap in currently available air sampling in the construction area exists 

from approximately July 1974 to early November 1976. During this temporal gap, more than 

75% of the total construction work for the PuFF was performed.
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4.0 INDIVIDUAL MONITORING RECORDS AMONG CLAIMANT 

CONSTRUCTION WORKERS

To characterize the individual external and internal exposure monitoring for SRS construction 

workers who could have potentially been involved in the construction of the PuFF, SC&A 

examined the available monitoring records for construction trade workers who were employed 

during the period of interest (December 1973–January 1977). Specifically, SC&A attempted to 

identify available claimants who indicated work in the (or, more specifically, ).

Wherever possible, claimants with short-term and intermittent employment were targeted, as it 

would be more likely that any mention of work in the area of interest could be attributed to 

construction of the PuFF as opposed to work in the facilities during other covered 

employment periods. While other location and temporal information found in the claim files was 

noted, it was very difficult to place a given SRS claimant in a specific area during a specific 

time. 

SC&A examined in detail 34 claims with a wide range of construction trade worker job types, 

such as Carpenters, Painters, Asbestos Workers/Insulators, Concrete Finishers, 

Ironworkers/Pipefitters/Welders, Electricians, and General/Construction Laborers. Of those 34 

claimant computer-assisted telephone interview (CATI) reports: 

• 18 mentioned at least some specific work locations in their CATI reports. 

• 6 simply stated that they worked all over the site. 

• 10 had no knowledge of work location or the CATI was declined. 

Of the 34 claimants, 21 had no evidence of potential work in and so are not discussed 

further in this report. Ten of the 34 claims described work in , but it was not possible to 

correlate the work with the time period of the PuFF construction. These 10 claims are 

summarized in Appendix B (see Cases 4–133

). As seen in those 10 case descriptions, there is a 

great deal of uncertainty in trying to establish the connection between available claimant records 

and actual work locations. 

3 Case numbers referenced in this report are arbitrarily assigned and do not represent actual claim numbers assigned 

by NIOSH, the U.S. Department of Energy, or DOL.

Only of 34 reviewed claims could be correlated with work in and/or 

during the period of interest with any degree of certainty. The following sections discuss these 

 claims (Cases 1–3). 

4.1 CASE 1

The energy employee (EE) worked as a from 

. The EE also had covered employment in the and from . 

The U.S. Department of Labor (DOL) case files indicate that the EE was during 

the period and worked as . The CATI was 

 
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performed with the EE and indicates that they worked but also specifically mentions 

Building .

Only an annual dose summary is available in the EE’s dosimetry file that does indicate external 

monitoring in . Additional external monitoring is not indicated until in the annual 

summaries. The EE was not monitored internally until , when a series of uranium 

samples were submitted for . No other relevant information was identified. 

4.2 CASE 2

The EE worked as a from , , and again on . 

The EE also had covered employment in the . The CATI was performed with the EE. It 

directly indicated work in and the during . The CATI described 

the following incident but did not provide a date: 

Once [redacted] was working on adding a new addition. He was working outside 

the contaminated area. They brought out an old piece of pipe from the 

contaminated area and had him weld it onto a new piece of pipe. Liquid shot out 

of the pipe onto his face. 

The description of the incident in the CATI indicated that no follow-up internal monitoring 

occurred as a result of the incident. The CATI also described working in and around 

in Building and indicated that work was done using Radiation Work Permits (RWPs) and 

Safe Work Permits (SWPs) “in the .” The DOL case files indicate that the EE worked 

for during the period of interest.

External dosimetry records provided with the claim indicate that monitoring occurred in 

(per the annual summary) and that a was accrued in . Internal 

dosimetry indicates that a sample was taken on 

, with the area designated as “ ” As SRS internal bioassay results do not 

generally indicate the reason for the sample, it is not known if the sample was the result of an 

incident or a planned bioassay based on the EE’s work. 

4.3 CASE 3

The EE worked as an from , to . The DOL case files 

indicate work with during this period. The EE also has 

other covered employment periods in the . The CATI was performed 

with the EE, who indicated work specifically in the areas during . 

Annual summary reports of external dosimetry indicate that external monitoring occurred in 

; the cycle dose reports for indicate exposures in . 

Relevant internal dosimetry included a taken on 

, with the area designated as “ .” Similar to Case 2, it is not discernable 

whether the was the result of a planned SWP/RWP or was the result of an incident.

The next internal monitoring result was a sample for fission products associated 

with . 
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4.4 GENERAL DISCUSSION

Case 1 specifically mentioned Building (as opposed to the more general “ ”) in the 

CATI report; however, the EE did not provide a timeframe for that work. Though it was clear 

that the EE was monitored externally during the period of interest ( ), no information was 

available to ascertain where the EE might have been monitored. There was no internal 

monitoring for the claim until . This represents a case where the EE was able to definitively 

say he or she worked in . However, there is no evidence to affirm or deny when 

such work happened. In such cases where there is no clear evidence of work location, it is the 

general practice under the auspices of the Energy Employees Occupational Illness Compensation 

Program Act to reconstruct doses in the most claimant favorable manner. This would generally 

involve the assignment of coworker intakes. 

Cases both had results for during the period of 

interest, and those results were actually labelled “ .” For Case , this sample 

appears to have resulted from the construction work, as the covered employment 

period ends shortly afterward. For Case , the situation is less clear. Although Case had a 

sample at covered employment in , the EE also external 

dose in that cannot be associated with any particular area of work. 

In both and , it is not possible to determine whether the samples were taken as endof-work samples (as might be specified in an SWP/RWP) or samples taken as the result of an 

incident. It is important to note that the topic of compliance with SWP/RWP bioassay 

requirements at SRS is an upcoming topic of discussion for the SRS and Special Exposure 

Cohort (SEC) Issues Work Groups. 

The 10 additional cases summarized in Appendix B further demonstrate the uncertainty in 

definitively trying to place a given worker in a site location for the purposes of assigning or 

denying the application of coworker doses. This is especially true for construction trade workers 

who may have worked intermittently at the PuFF construction area but were generally dispatched 

out of other areas, such as the Central Shops. 

Finally, SC&A is not aware of any credible way to differentiate workers who may have been 

doing maintenance in other sections of the F Area versus the subset of construction workers who 

were specifically in the PuFF area. For example, a worker may indicate he or she worked in F 

Area but was actually doing maintenance work on the NBL glovebox line instead of work in the 

PuFF. In such cases, application of unmonitored coworker intakes would clearly be warranted. 

Although in some instances CATI reports can be informative in establishing work locations, 

SC&A does not feel the onus should be on the claimant to inform the dose reconstruction process 

of what specific activities were undertaken and at what times. In cases where uncertainty in work 

location exists, assignment of coworker intakes should be the default option. 

Finding 3: Based on a review of a subset of construction trade worker claim files for SRS during 

the period of interest (December 1973–January 1977), SC&A feels that there is a considerable 

amount of uncertainty in trying to credibly place a worker at the PuFF construction operation 

versus any other location within F Area (let alone at other SRS site areas). Therefore, SC&A 
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does not see a credible way to restrict the assignment of unmonitored doses to claims based on 

work directly associated with PuFF construction. 
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5.0 SC&A CONCLUSIONS AND RECOMMENDATIONS

SC&A agrees that there were radiological controls and safeguards in place to limit the spread of 

contamination, and thus potential exposures to workers involved in the construction of the PuFF, 

to within acceptable levels. However, SC&A does not agree that the lack of monitoring records 

for an individual worker indicates that no exposures occurred as was indicated in Section 5.0 of 

RPRT-0080. 

The air sampling and routine contamination survey data presented in RPRT-0080 represent only 

fraction of the period covering the construction of the PuFF (Findings 1 and 2). Furthermore, the 

analysis of air sampling data presented in RPRT-0080 showed comparable levels of alpha 

activity at the median and 50th percentile for construction areas versus the regulated corridor and 

NBL End Room (Observation 3). 

RPRT-0080 indicates that workers who were not directly monitored for external radiation via 

film badge or thermoluminescent dosimeter (TLD) would have been monitored via fixed external 

monitoring stations located within Building 235-F. However, it is not clear how such data are

intended to be used in the context of an individual dose reconstruction. In the case of 

construction trade workers who may have been inside Building 235-F for the construction of the 

PuFF, it has not been established that ambient environmental exposures developed in 

NIOSH 2005 are representative and appropriate (Observation 2). 

A review of a sample of construction trade worker claim files demonstrated significant 

uncertainty in establishing the worker’s location, job duties, and exposure potential during the 

period of interest. As a practical matter, SC&A is not aware of a credible method for 

distinguishing construction trade workers who were involved in construction of the PuFF versus 

other maintenance activities within the F Area (Finding 3). Thus, it does not seem feasible or 

appropriate to restrict the assignment of coworker intakes based on involvement in this specific 

construction activity. Therefore, SC&A recommends that unmonitored external and internal 

doses should be assigned to all construction trade workers who had the potential to enter the 

facility.
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6.0 REFERENCES

Brown 2012. Radiation Survey Log Sheets December 31, 1973 through December 29, 1974, 

transmitted by K.T. Brown, Savannah River Nuclear Solutions, Aiken, South Carolina, to 

Timothy D. Taulbee, Office of Compensation Analysis and Support, National Institute of 

Occupational Safety and Health, Subj.: “Documents Requested for Special Exposure Cohort 

Petition Evaluation.” May 17, 2012. [SRDB Ref. ID 114646] 

DuPont 1966. Personal Monitoring, DPSTS-RH-0.07. E.I. du Pont Nemours and Company, 

Savannah River Plant, Health Physics Section. Aiken, SC. February 1966. [SRDB Ref. 

ID 89198] 

DuPont 1975. Environmental Monitoring at the Savannah River Plant – Annual Report – 1974, 

DPSPU 75-302, E.I. du Pont de Nemours and Company, Savannah River Plant, Health Physics 

Section, Aiken, SC. August 1975. [SRDB Ref. ID 11030] 

NIOSH 2005. Savannah River Site, ORAUT-TKBS-0003, Revision 03, National Institute for 

Occupational Safety and Health, Cincinnati, OH. April 5, 2005. 

NIOSH 2016a. An Evaluation of Neptunium Operations at Savannah River Site, ORAUT-RPRT0065, Revision 00, National Institute for Occupational Safety and Health, Cincinnati, OH. 

September 19, 2016. [SRDB Ref. ID 160054]

NIOSH 2016b. Evaluation of Health Physics Area and Health Physics Department Codes to 

Identify Neptunium Workers at the Savannah River Site, ORAUT-RPRT-0077, Revision 00, 

National Institute for Occupational Safety and Health, Cincinnati, OH. November 8, 2016. 

[SRDB Ref. ID 163179] 

NIOSH 2017. Potential Neptunium Exposure to Plutonium Fuel Facility Construction Workers 

in Building 235-F at the Savannah River Site, ORAUT-RPRT-0080, Revision 00, National 

Institute for Occupational Safety and Health, Cincinnati, OH. February 7, 2017. [SRDB Ref. 

ID 165590] 

SC&A 2017a. Memorandum – SC&A Review of RPRT-0065: An Evaluation of Neptunium 

Operations at Savannah River Site, SC&A, Inc., Arlington, VA. March 13, 2017. 

SC&A 2017b. SC&A Review of Dosimetry Coding Methods for Identifying Neptunium Workers 

at Savannah River Site, SCA-TR-2017-SEC006, Revision 0, SC&A, Inc., Arlington, VA.

April 10, 2017. 
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APPENDIX A: EXAMPLE OF A DAILY/WEEKLY SURVEY 

LOGSHEET FOR BUILDING 235-F 
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APPENDIX B: [REDACTED IN FULL]

[Appendix B is withheld in its entirety to prevent the disclosure of Privacy Act-protected 

information.]