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. 

To: Savannah River Site Work Group

From: SC&A, Inc.

Date: March 11, 2022 

Subject: March 2022 Update of Issues Matrix for the SRS SEC Petition and Petition 

Evaluation Report

On behalf of the Savannah River Site (SRS) work group, SC&A maintained and updated a 

Special Exposure Cohort (SEC) issues matrix, starting in September 2009, that compiled all 

identified exposure potential issues at SRS based on the work group’s review of Petition 

SEC-00103. The original 2009 matrix (SC&A, 2009a) was based on issues that were unresolved 

from the SC&A review of the SRS site profile and SC&A’s preliminary review of NIOSH’s 

evaluation report (ER) (NIOSH, 2008). The initial 2009 matrix listed 25 issues of SEC 

relevance; an additional issue was added later, for 26. 

SC&A issued an updated 2014 SEC issues matrix (SC&A, 2014) in February 2014 following the 

designation of an SEC class for all SRS employees for 1953–1972. This designation rendered 

moot some SEC issues, while others needed additional research to address questions related to 

latter time periods, including those for construction trade workers (CTWs), nuclide-specific 

issues (e.g., neptunium, special tritium compounds, and thorium), and co-exposure modeling. For 

this current review, SC&A reviewed the 2014 matrix (the latest generated) to confirm any 

outstanding issues for which documented resolution is not apparent. 

Of the 26 SEC-relevant issues listed in the 2014 matrix, three issues lacked a documented 

resolution: issue 3 for “Recycled Uranium,” issue 22 for “Badges not capturing dose,” and 

issue 26 for “additional worker and worker representative issues.”

The original recycled uranium (RU) issue, which was identified in SC&A’s 2005 site profile 

review (SC&A, 2005), found that a timeline for RU operations had not been issued and it was 

not clear when and how RU (with trace radiological contaminants) may have been handled at 

SRS. NIOSH issued trace contaminant data for RU in 2010 (NIOSH, 2010b), and SC&A 

responded with a memorandum about remaining RU issues in 2014 (SC&A, 2014b). While there 

is no confirmation of an outstanding SEC issue, no final resolution was apparent in the work 

group records on this matter. 

For issue 22 (and subsumed issue 23), SC&A had found that worker interviews indicated that 

some workers kept their badges out of higher radiation areas in order to not exceed dose limits 

(SC&A, 2011c) and that badge dose readings may have been under-recorded or not recorded. 

NIOSH was to review SC&A’s report of these worker interviews and provide a response.
SC&A, Inc.

SRS SEC Issues Matrix, page 2 March 11, 2022

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

For issue 26, SC&A had compiled and categorized a number of worker and petitioner comments 

about specific workplace issues for which a specific NIOSH response has not been received to 

date. However, as noted in SC&A’s updated matrix in this memo, a number of the comments are 

addressed in existing SEC issues reviewed by the work group and NIOSH. 

A number of other SEC-relevant issues from the 2014 matrix have either been closed, resolved, 

subsumed under other issues, or superseded by the 2011 Board action to recommend an SEC for 

1953–1972 (issues 1, 8, 12, 15, 16, 17, 18, 19, 21, 23, 24, and 25). Still others are being 

addressed by the development of co-exposure models under ORAUT-OTIB-0081, “Internal 

Dosimetry Co-Exposure Data for the Savannah River Site”: issue 2 for thorium via ORAUTRPRT-0070 (NIOSH, 2017a) and ORAUT-RPRT-0081 (NIOSH, 2017d); issue 4 for trivalent 

actinides and thorium; issues 6 and 7 for fission and activation products; issue 9 for tritium; and 

issue 13 for comparing intakes for CTWs versus non-construction workers. Issue 5 for 

neptunium (Np)-237 has been addressed by NIOSH in ORAUT-RPRT-0065 (NIOSH, 2016a), 

ORAUT-RPRT-0077 (NIOSH, 2016b), and ORAUT-RPRT-0080 (NIOSH, 2017c) and is being 

handled by the work group as an ongoing issue. Issue 10 for special tritium compounds, which 

are being addressed as “Metal Hydrides” in ORAUT-RPRT-0072 (NIOSH, 2017b), is also 

ongoing. Issue 11 (exotic radionuclides), issue 14 (special exposure conditions), and issue 20 

(tank farm geometry) have reached the resolution stage and are ready for work group review for 

closure. 

Other than the three specific outstanding items—issues 3, 22, and 26, none of which have been 

judged SEC-significant to date—SC&A has determined that the relevant SEC issues have flowed 

down to and have been included in subsequent priority action lists presented by NIOSH to the 

work group. Their status is summarized in SC&A’s informal internal update of SEC-00103 

issues status in October 2021 (SC&A, 2021). 

Given how long ago this 2014 issues matrix was last updated and the challenge faced by SC&A 

in reconstructing several status items, SC&A recommends to the work group that the 2022 

updated matrix1 included in this memo be reviewed and corroborated by NIOSH and the work 

group. 

1 Please note that the structure of the 2014 matrix has been updated and the text proofread and reformatted to 

comply with current NIOSH requirements for Section 508 compliance.
SC&A, Inc.

SRS SEC Issues Matrix, page 3 March 11, 2022

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Table 1. March 2022 update of issues matrix for the SRS SEC petition and petition ER

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

1 Thorium up to 1965 7.1.1.8 Thorium work was carried out in a 

number of areas and dose 

reconstruction methods need to be 

specified. NIOSH had reserved the 

issue for further research up to 1960 

in the ER (NIOSH, 2008), but 

extended the date to 1965 when it 

published an addendum to the ER in 

May 2010 (NIOSH, 2010a). 

NIOSH published Addendum 

2 to its ER in August 2011 

(NIOSH, 2011a) 

recommending that workers 

with certain area and 

dosimetry codes who worked 

between Jan. 1, 1953, and 

Sept 30, 1972, be added to 

the SEC because of the 

infeasibility of thorium dose 

reconstruction in certain 

buildings in this period.

SC&A did an analysis of the 

completeness of area and dosimetry 

codes in the records of 10 claimants (not 

a random sample) (SC&A, 2011e). 

Update – February 21, 2014: This issue 

is resolved.

Resolved. Board 

recommended addition of all 

workers from Jan. 1, 1953, 

to Sept. 30, 1972, to the 

SEC. Includes CTWs and 

non-construction workers 

(NCWs). 

2 Thorium, 1965 onwards 7.1.1.8 Thorium 1965 and after. No coworker 

model or specific approach to 

bounding dose was provided in the 

ER.

Refer to issue 1 up to 

September 30, 1972. NIOSH 

is researching the thorium 

issue after that date.

SC&A has provided draft reports to the 

Board indicating some thorium work after 

Sept. 30, 1972.

Update – February 21, 2014: NIOSH 

has published Addendum 3 to its ER 

(NIOSH, 2012a). NIOSH has also 

published its internal coworker dosimetry 

data in NIOSH 2013a and a revision of 

that document (NIOSH, 2013b). SC&A 

has reviewed NIOSH 2012a and the 

data relating to thorium that NIOSH 

proposes to use (SC&A, 2013a). NIOSH 

has responded to SC&A’s review 

(NIOSH, 2014a). SC&A is reviewing the 

new information in NIOSH 2013b and 

NIOSH 2014a and provided its 

comments during the Work Group 

meeting held on February 5, 2014, and 

will provide further comments during the 

conference call scheduled for February 

26, 2014. SC&A’s review of NIOSH SRS 

coworker models is connected with its 

review of NIOSH’s proposal to aggregate 

internal monitoring data according to a 

“One Person-One Sample” (OPOS) 

method, as described in NIOSH 2012b. 

SC&A’s review of the OPOS method, in 

Resolved up to Sept. 30, 

1972. Open after that.
SC&A, Inc.

SRS SEC Issues Matrix, page 4 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

general, has been issued to the SEC 

work group. SC&A’s review of OPOS 

includes some SRS-specific matters. 

SC&A’s SRS-specific finding is that SRS 

NCW data cannot be used for the 

estimation of unmonitored CTW internal 

doses for a variety of reasons. NIOSH 

disagrees and contends that it can.

Update – March 2022: NIOSH issued 

ORAUT-RPRT-0070, “Evaluation of 

Method for Assessment of Thorium-232 

Exposures at the Savannah River Site 

from 1972 to 1989” (NIOSH, 2017a). 

This document discusses a new method 

for bounding potential internal doses 

from thorium using known inventories 

and routine air monitoring data. 

Following issuance of Addendum 3, 

NIOSH learned that the method used to 

analyze urine samples for trivalent 

radionuclides was changed in 1990 to 

alpha spectroscopy, which rendered the 

proposed use of trivalent radionuclide 

bioassay coworker data impracticable. 

SC&A provided comments in an October 

2018 response (SC&A, 2018), with one 

finding re alternate sampling methods as 

applied to decontamination and 

decommissioning and off-normal 

sources. NIOSH responded in December 

2018 and agreed with SC&A’s finding 

and clarified that “the intake rate 

associated with these data should only 

be used for normal conditions,” with a 

50th percentile co-worker intake applied 

for off-normal circumstances (NIOSH, 

2018, p. 5). This issue appears to be 

resolved, although work group closure is 

needed.
SC&A, Inc.

SRS SEC Issues Matrix, page 5 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

3 Recycled uranium (RU) 7.1.1.2 This issue is in part a carry-over from 

the SC&A technical basis document 

(TBD) review (SC&A, 2005, p. 71). A 

timeline for the RU operations has not 

been published.

Some revised trace 

contaminant data were 

provided in July 2010 

(NIOSH, 2010b) using U.S. 

Department of Energy (DOE) 

RU publications and a 1984 

SRS document as references.

A start date of 1955 for RU 

was provided.

SC&A started a review of the NIOSH 

ratios and associated reference material.

Report preparation was stopped pending 

resolution of issues related to ER 

addenda.

Update – February 21, 2014: SC&A is 

preparing a review of the RU ratios; the 

review is scheduled to be completed by 

June 2014.

Update – March 2022: SC&A issued its 

review in a memorandum of June 6, 

2014, that requested clarification of 

NIOSH’s ratios and associated 

supporting material. SC&A’s major 

concern was that there were “two 

different tables provided by NIOSH, and 

it is not obvious how the values in the 

tables were derived; therefore, it is 

difficult to evaluate them” (SC&A, 2014b, 

p. 2). SC&A recommended to the SRS 

work group that NIOSH (1) restate and 

justify their recommended RU 

components and their appropriate values 

and (2) provide a description of how the 

recommended values were derived, so 

that they can be independently verified. 

This would include the location in the 

documents where the values were 

obtained, any assumptions, conversion 

factors, and other information necessary 

to trace the values NIOSH recommends. 

While no NIOSH response was found, 

this issue may have been overtaken by 

other, broader reviews of RU. SC&A 

believes this to be a matter of 

clarification, not of SEC significance.

Relevant only after Sept. 30, 

1972.
SC&A, Inc.

SRS SEC Issues Matrix, page 6 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

4 Trivalent actinides 

americium (Am), curium 

(Cm), and californium (Cf) 

7.1.1.5, 7.1.1.6, 

7.1.1.7

Trivalent actinides: Am, Cm, and Cf.

There are no data for Cm-244 until 

1963 (ER figure 7-1). Data analysis 

and coworker models have not been 

provided for any period. Relevance of 

later data to earlier periods has not 

been established. Relationship 

between NCW and CTW intakes for 

trivalent radionuclides in the period 

before monitoring began and after 

monitoring began has not been 

established. Where NIOSH proposes 

to use gross alpha data (e.g., for Cf252, method for selecting workers for 

assigning dose and selecting the 

radionuclide) have not been 

scientifically established. The 

resulting dose estimates would need 

to be examined for validity and 

reasonableness. Cf-252 assignment 

would also need to be reviewed in 

relation to spontaneous fissionrelated organ doses (including 

neutrons from spontaneous fission 

after intake).

NIOSH proposes to use 

measured data or coworker 

models for estimating dose 

with sufficient accuracy (ER 

sections 7.1.1.5 to 7.1.1.7).

Since data were collected for 

all three trivalent 

radionuclides rather than 

each separately, NIOSH 

proposes to assign the result 

to Cf-252 as appropriate (ER, 

p. 51). NIOSH has not yet 

published its coworker model.

NIOSH has specified an 

International Commission on 

Radiological Protection 

(ICRP) model for Cf-252 

spontaneous fission.

SC&A awaits the coworker model and 

will review it when it is available. SC&A 

agrees with NIOSH regarding the ICRP 

model for Cf-252. 

Update – February 21, 2014: NIOSH 

has published a coworker model for 

trivalent actinides (NIOSH, 2012d). Many 

of the findings for thorium in SC&A 

2013a apply to NIOSH’s proposed 

methods for coworker trivalent actinide 

dose estimation because NIOSH 

proposes to use trivalent actinide 

monitoring data for thorium dose 

reconstruction. Therefore, SC&A has not 

reviewed NIOSH 2012d as such, 

pending resolution of the findings in 

SC&A 2013a that also apply to NIOSH

2012d. SC&A notes that SC&A 2013a 

does not address adequacy or 

completeness of SRS trivalent actinide 

data for coworker modeling of those 

three radionuclides (Am, Cm, Cf).

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, “Internal 

Coworker Dosimetry Data for the 

Savannah River Site,” with findings and 

observations discussed by the work 

group. Additional reviews were 

conducted regarding multiple imputation 

methods and trivalent bioassay 

variability. Remaining issues are before 

the work group for discussion and are 

summarized in the October 25, 2021, 

internal memorandum, “Updated Status 

of SEC-00103-Related Issues” (SC&A, 

2021).

SC&A has not checked the 

ending date for these 

radionuclides. Now only 

relevant after Sept 30, 1972.
SC&A, Inc.

SRS SEC Issues Matrix, page 7 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

5 Np-237 7.1.1.4 Data analysis and coworker model 

not provided. Adequacy of data for 

coworker model not established.

Applicability of back-extrapolation of 

data from 1960s and after to pre-1960 

period not established. 

NIOSH proposes to use data 

for the workers who were 

monitored to reconstruct their 

dose and a coworker model 

for the rest. Data available 

from 1960 onward in claimant 

database. NIOSH has not yet 

published its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

has published a coworker model for Np237 (NIOSH, 2012c), which SC&A has 

reviewed (SC&A, 2013b). NIOSH has 

responded to SC&A’s review (NIOSH, 

2014b). SC&A provided its comments 

regarding NIOSH 2014b at the meeting 

held on February 5, 2014, and will 

provide further comments during the 

during the work group conference call 

scheduled for February 26, 2014. 

SC&A’s review of NIOSH SRS coworker 

models is connected to its review of 

NIOSH’s proposal to aggregate internal 

monitoring data according to an OPOS 

method (NIOSH, 2012b). SC&A’s review 

of the OPOS method, in general, has 

been issued to the SEC work group. 

SC&A’s review of OPOS includes some 

SRS-specific matters. SC&A’s SRSspecific finding is that SRS NCW data 

cannot be used for the estimation of 

unmonitored CTW internal doses for a 

variety of reasons. NIOSH disagrees and 

contends that it can.

Update – March 2022: NIOSH issued 

RPRT-0065 (2016a, neptunium 

operations), RPRT-0077 (2016b, codes), 

and RPRT-0080 (2017c, Plutonium Fuel 

Form Facility), with SC&A and NIOSH 

exchanging responses for all three 

reports. The outstanding issues await 

work group discussion and resolution 

and are summarized in SC&A’s October 

25, 2021, memorandum, “Updated 

Status of SEC-00103-Related Issues”

(SC&A, 2021). 

Now relevant only after 

Sept. 30, 1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

6 Fission and activation 

products

7.1.1.9 Validity of back-extrapolation of 

strontium (Sr)-90 data has not been 

established. Adequacy of fission 

product monitoring data for coworker 

model has not been established. ER 

states that strontium radioisotope 

monitoring began in the “late 1950s.”

The proposed coworker model has 

not been published.

NIOSH has not yet published 

its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

has published a coworker model for 

mixed fission and activation products 

(NIOSH, 2012e). Some of the findings 

for thorium and neptunium in SC&A 

2013a and SC&A 2013b apply to 

NIOSH’s proposed methods for mixed 

fission and activation products. SC&A 

has not reviewed NIOSH 2012e as such, 

pending resolution of the findings in 

SC&A 2013a and SC&A 2013b that also 

apply to NIOSH 2012e. SC&A notes that 

SC&A 2013a and SC&A 2013b do not 

address adequacy or completeness of 

SRS mixed fission and activation product 

data for coworker modeling of those 

radionuclides.

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in SC&A’s informal, internal 

October 25, 2021, memorandum, 

“Updated Status of SEC-00103-Related 

Issues” (SC&A, 2021).

Now relevant only after 

Sept. 30, 1972.
SC&A, Inc.

SRS SEC Issues Matrix, page 9 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

7 Co-60 7.1.1.10 Validity of use of fission product data 

prior to 1960 has not been 

established. Coworker model has not 

been published. ER does not address 

the issue of incidents. Individual

bioassay data or coworker model 

based on claimant data will be used.

Targets were encapsulated (comment 

in TBD matrix). The potential 

similarity of the irradiation of 

encapsulated sources is noted in the 

July 7, 2007, work group meeting 

notes.

NIOSH has not yet published 

its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

covered cobalt (Co)-60 in its report on 

“exotic radionuclides” (NIOSH, 2012f). 

NIOSH states that whole body counting 

data are available. There is no indication 

of production after October 1, 1972, in 

NIOSH 2012f. SC&A has not reviewed 

NIOSH 2012f. 

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in SC&A’s informal, internal

October 25, 2021, memorandum, 

“Updated Status of SEC-00103-Related 

Issues” (SC&A, 2021).

Now relevant only after 

Sept. 30, 1972.

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

published. Incidents are not 

addressed. Relationship of CTW to 

NCW intakes has not been 

established.

NIOSH published a paper on 

polonium (Po)-210 in January 

2011 (NIOSH, 2011b). The 

Po-210 program at SRS 

ended in 1970.

No review needed.

Update – February 21, 2014: NIOSH’s 

report on exotic radionuclides (NIOSH, 

2012f) includes further information on 

Po-210 and does not provide any 

indication of production of Po-210 after 

October 1, 1972. SC&A has not further 

checked the ending date for Po-210 

production at SRS. SC&A recommends 

that this issue be tentatively closed.

Update – March 2022: Awaits work 

group action.

Resolved by the Board SEC 

vote. Ending date may need 

to be checked.
SC&A, Inc.

SRS SEC Issues Matrix, page 10 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

9 Tritium 7.1.1.1 NIOSH has not demonstrated that the 

TBD approach of applying 

environmental doses to unmonitored 

workers (no badge, no bioassay) and 

reporting level to workers with 

external monitoring only is suitable for 

unmonitored CTWs. NIOSH has not 

demonstrated that it has a bounding 

dose approach for tritium for CTW.

NIOSH published a report on 

use of tritium data for CTW 

exposure estimation in 

November 2010 (NIOSH,

2010c). NIOSH is preparing a 

second part of this report that 

specifically addresses CTW 

vs. NCW exposure.

SC&A published a report that included 

tritium, comparing CTW and NCW data, 

in January 2010 (SC&A, 2010b) and 

another in November (SC&A, 2010c) 

using a larger tritium bioassay database 

provided by NIOSH. Both indicate that 

CTWs had higher bioassays than NCWs 

in some areas, some periods, and some 

job types. SC&A will produce a single 

review of NIOSH’s tritium report when 

the second part is published.

Update – February 21, 2014: NIOSH 

published Part 2 of its tritium report in 

November 2011 (NIOSH, 2011c). SC&A 

has not resumed its review of tritiumspecific issues pending resolution of 

findings relating to issues 2, 4, 5, and 6, 

as well as general issues relating to the 

methods by which CTW and NCW 

monitoring data can be compared and/or 

combined (matrix issue 13).

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in the October 25, 2021, 

memorandum, “Updated Status of SEC00103-Related Issues” (SC&A, 2021). 

Only the data from Oct. 1, 

1972, onward will be 

evaluated. There have been 

tritium/tritides-related data 

capture visits and interviews 

(NIOSH and SC&A). SC&A 

tritium interview summary 

has been merged with a 

prior summary of other 

issues. Combined summary 

is being sent to DOE for 

classification review.
SC&A, Inc.

SRS SEC Issues Matrix, page 11 March 11, 2022

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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

10 Special tritium 

compounds for CTWs

NA ER refers to ORAUT-OTIB-0066

(NIOSH, 2007b) for special tritium 

compound exposure. Relationship of 

CTW to NCW exposure to special 

tritium compounds or some other 

means of bounding CTW exposure to 

them needs to be established. OTIB0066, which discusses a method to 

calculate doses due to exposure to 

special tritium compounds, is not 

specific to SRS and does not discuss 

dose reconstruction issues for such 

compounds specific to CTWs. 

The solubility of one—

lanthanum-nickel hydride—is 

under investigation at SRS.

NIOSH is completing a draft 

of its interview notes.

SC&A awaits the NIOSH approach to 

estimating tritide doses.

Update – February 21, 2014: NIOSH 

has not published any data regarding 

tritides since the last matrix update in 

2011.

Update – March 2022: NIOSH issued 

ORAUT-RPRT-0072, “Locations of 

Stable Metal Tritide Use at the 

Savannah River Site,” in 2017 (NIOSH, 

2017b). SC&A reviewed and provided 

comments in 2018 with a NIOSH 

response in 2019. No findings to date. 

Needs work group discussion and 

resolution.

Refer to issue 9 for interview 

status.

11 Exotic radionuclides 7.1.1.9 in part About 150 radionuclides were 

produced at SRS, and targets were 

fabricated there (NIOSH, 2006, 

p. 25). No analysis of the production 

processes is provided, nor are there 

any descriptions of incidents. The 

incident database is incomplete, 

which was one of SC&A’s findings in 

its TBD review. The lack of analysis 

may be parallel to the situation at Y12, where a large number of isotopes 

were produced, with the difference 

that at Y-12, they were produced in 

accelerators, and at SRS, they were 

produced in reactors. No 

documentation of the encapsulation 

processes is provided. The 

exceptions to the coverage of 

radionuclides by whole-body counting 

are not discussed. There is no 

discussion of whether any of the 

target materials were themselves 

radioactive.

NIOSH will respond to the 

SC&A report on exotic 

radionuclides. NIOSH will also 

sort out what other 

radionuclides were produced 

that are not in the SC&A 

report. NIOSH will specify 

dose reconstruction methods 

with due attention to the 

criteria for exotic 

radionuclides presented by 

Jim Neton to the Board during 

the November 2010 Santa Fe 

Board meeting.

SC&A provided the work group with a 

report on exotic radionuclides in 

December 2010 (SC&A, 2010d).

Update – February 21, 2014: NIOSH 

published a report on exotic 

radionuclides in 2012 (NIOSH, 2012f). 

SC&A 2010d raised a question whether 

an exotics production program that was 

proposed in 1969 was ever pursued. 

NIOSH did not find any evidence that it 

was (NIOSH, 2012f, p. 12). SC&A has 

not reviewed this finding. Most of NIOSH

2012f covers the pre-1972 period. SC&A 

has not further reviewed the periods of 

exotic radionuclide production beyond 

that in SC&A 2010d.

Update – March 2022: No further 

discussion of this issue is evident. No 

apparent SEC issues have been found. 

Awaits work group disposition.

Only relevant after Sept. 30, 

1972.
SC&A, Inc.

SRS SEC Issues Matrix, page 12 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

12 Internal dose due to 

incidents

5.2.3, 7.3.6 The Special Hazards Investigations 

list is incomplete. In its Tank Farm 

Fault Tree Databank, the site 

acknowledged that many early Tank 

Farm area incidents were not 

recorded (until 1965). The ER states 

that there are incident records, 

including the Special Hazards 

Investigation files, and that NIOSH 

has data relating to incidents (ER, 

p. 29). No evidence of cover up of 

incidents was found, and NIOSH can 

bound dose in any case (ER p. 71).

NIOSH will respond to the 

SC&A report. NIOSH may 

follow up with workers 

interviewed by SC&A.

SC&A prepared a report on extent of and 

potential gaps in incident documentation 

in worker records to elaborate on its TBD 

review finding (SC&A, 2011b).

Update – February 21, 2014: NIOSH 

has not responded to SC&A 2011b. The 

issue remains open.

Update – March 2022: Work group 

closed this issue at February 26, 2014, 

meeting.

Interviews also indicate that 

there were unrecorded 

incidents. Only relevant after 

Sept. 30, 1972.

13 Overall CTW to NCW 

internal dose relation

7.1 ER states that ORAUT-OTIB-0052 

(NIOSH, 2007a) found NCW intakes 

“were generally higher than 

construction trades workers” (ER, p. 

39). OTIB-0052 suggests a 1:1 ratio 

for CTW to NCW intakes. SC&A 

analysis indicates that the assumption 

that NCW intakes (as indicated by 

bioassay data) would be generally 

higher than for CTW is not generally 

valid. The adequacy of bioassay data 

for constructing coworker models 

needs to be examined for different 

periods, areas, radionuclides, and 

types of CTWs.

NIOSH has produced an 

analysis of tritium data 

comparing CTWs to all 

workers (including CTWs) 

(NIOSH, 2010c). NIOSH is 

preparing a second part 

comparing CTWs to NCWs.

NIOSH is also revising OTIB0052. NIOSH included both 

CTWs and NCWs in its 

thorium SEC recommendation 

in the ER Addendum 2 

(NIOSH, 2011a). 

Besides the two reviews of CTWs vs. 

NCWs (SC&A 2010b and SC&A 2010c), 

SC&A also produced a report evaluating 

the plutonium database used in OTIB0052 (SC&A, 2010e). SC&A also 

published a master interview summary 

as part of SC&A 2011b; this summary 

contains some discussion of CTW vs. 

NCW matters. SC&A was to review 

NIOSH’s revision of OTIB-0052 when it 

is published. SC&A will await instructions 

on this issue, given the December 8, 

2011, Board vote on the SRS SEC to 

include CTWs and NCWs.

Update – February 21, 2014: This issue 

is being covered under the review of 

coworker models for specific 

radionuclides as well as in SC&A’s 

review of the NIOSH’s “One-PersonOne-Sample” aggregation of monitoring 

data. A number of findings relating to 

CTW dose reconstruction, comparison 

on NCW and CTW distributions of 

measurements, and NIOSH’s coworker 

models remain open.

Update – March 2022: This issue is 

subsumed under the work group’s 

review of OTIB-0081 and the extensive 

CTW vs. NCW resolved up 

to Sept. 30, 1972, by Board 

vote of 8 Dec. 1972 since 

both CTW and NCW were 

included in the SEC 

recommendation. Also, 

issues 19 (tentatively) and 

21 are closed. A 

considerable amount of 

work has been done by 

NIOSH and SC&A as 

indicated in the reports cited 

here. The work group had 

directed tritium data as the 

current focus of this issue to 

be followed by uranium. This 

is still an outstanding issue 

for the period after Sept. 30, 

1972. Issue may need reassessment in light of the 

inclusion of both CTWs and 

NCWs in the SEC up to 

Sept. 30, 1972.
SC&A, Inc.

SRS SEC Issues Matrix, page 13 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

work group deliberations in 2017–2021 

that led to an SEC class being 

designated for SRS subcontractors for 

1972–1990. 

14 Special exposure 

conditions

7.4.2 There are several areas of concern 

that can be described as “special 

exposure conditions,” including offnormal or unauthorized work 

practices, burning of spent tributyl 

phosphate in open pans in the early 

years (to 1971), and high exposure 

potential during certain authorized 

work practices, such as opening tank 

risers or cleanup of high-level waste 

leaks.

NIOSH has stated that it has 

air concentration data in the 

burning ground area, and that 

it will provide a dose 

reconstruction approach.

Refer to comment column.

Update – February 21, 2014: This issue 

has been subsumed under matrix issue 

12 for the period October 1, 1972, 

through 2007.

SC&A worker interviews 

done as part of the SEC 

investigation also indicate 

off-normal practices and 

high exposure potential 

during certain types of work, 

including in the Tank Farms.

A master summary of 

SC&A’s interviews 

(excluding tritides) is in 

SC&A 2011b. The burning 

ground issue is no longer 

relevant, since open pan 

burning ended in February 

1972 (WSRC, 2000, PDF 

p. 1068).

15 Construction worker job 

types

NA Worker intakes and coworker models 

may have to be built by CTW job type 

in order to ensure that the models are 

bounding doses (or more accurate 

than bounding doses).

NA Update – February 21, 2014: Refer to

update for matrix issue 13.

This issue is merged into 

issue 13.

16 OTIB-0075 validity for 

SEC use – internal dose

7.1, 7.3.4, 7.4.2 The use of ORAUT-OTIB-0075

(NIOSH, 2009b), which asserts 

representativeness of claimant data 

for the whole worker population, for 

SRS CTW SEC is questionable.

NIOSH also produced a 

report on data with a 

significant fraction of “lessthan” results that is general, 

but also applies to the SRS 

SEC (NIOSH, 2009a).

SC&A reviewed OTIB-0075 (SC&A,

2010b). SC&A also reviewed NIOSH

2009a (SC&A, 2010f).

Update – February 21, 2014: Refer to

update for matrix issue 13

This issue is merged into 

issue 13.
SC&A, Inc.

SRS SEC Issues Matrix, page 14 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

17 Early neutron dose to 

1961

7.2.2.2 Fig. 7-3 of the ER (p. 65) shows no 

neutron monitoring data for the 200-F 

Area until about 1958, and generally 

less than 20 badges per cycle until 

1962 (except for part of 1959). This 

was “one of the highest neutronexposure areas at SRS,” according to 

the ER (p. 64). The entire early period 

will have to depend almost 

exclusively on area neutron and 

photon monitoring data. The 

relationship of the neutron-to-photon 

(n/p) ratio data to workers and their 

personnel neutron exposure 

experience will need to be 

established with essentially no 

reference to actual monitoring data. It 

is unclear whether there are any early 

neutron monitoring data for CTWs.

NIOSH will use an approach 

based on n/p ratios. On Feb. 

3, 2011, NIOSH reported no 

progress on this item, which 

has been pushed down the 

list of priorities due to many 

other action items. NIOSH will 

provide a date when this will 

be done. NIOSH stated it has 

the data to do dose 

reconstruction.

Update – February 21, 2014: This issue 

has been resolved.

This issue is resolved by the 

Dec. 8, 2011, Board vote.
SC&A, Inc.

SRS SEC Issues Matrix, page 15 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

18 Neutron dose 1962–1971 6.2 and 7.2.2 ER acknowledges unmonitored dose 

at SRS due to neutrons, since 

monitoring was required only when 

area neutron dose rates were in 

excess of 1 mrem per hour. Neutron 

data are very sparse in general up to 

the mid-1960s, and sparse even after 

that. Representativeness of area 

monitoring for worker exposure and 

representativeness of available n/p 

data for all workers in the class needs 

to be assessed. Additionally, backextrapolation of post-1972 data was 

proposed in the TBD. It is unclear 

whether there will be backextrapolation to demonstrate 

bounding dose; if there is, the validity 

of such back-extrapolation may need 

to be examined.

Validity of assumption of low neutron 

doses in the reactor areas needs to 

be examined.

Validity of implicit assumption that 

CTW neutron doses were lower than 

NCWs needs to be examined in view 

of the higher bioassay results for 

some periods and radionuclides, 

including plutonium in some periods.

NIOSH had stated that it has 

paired neutron and photon 

data and may issue a report 

in March 2011.

Update – February 21, 2014: This issue 

has been resolved.

This issue is resolved by the 

Board vote of Dec. 8, 2011.

19 Test reactor neutron dose NA Neither the ER nor the TBD analyzes 

the neutron dose at the Heavy Water 

Components Test Reactor. Issue of 

an incident was raised in a worker 

interview done by SC&A.

NIOSH is addressing neutron 

doses as part of issues 17 

and 18.

SC&A research did not result in any 

specific information about this accident 

(such as date and accident description).

Update – February 21, 2014: No 

information that would warrant a 

reopening of this issue has come to light 

since the last matrix update.

One SC&A interviewee 

indicated an incident took 

place at this reactor (crack 

in the core). No further 

information was available 

from the interviewee, and no 

information on such an 

incident was found in 

document research done by 

SC&A. As a result, this issue 

has been tentatively closed.
SC&A, Inc.

SRS SEC Issues Matrix, page 16 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

20 Tank Farm exposure 

geometry

NA NIOSH to estimate the geometry of 

exposure in special work situations, 

such as those described in the F and 

H Area Tank Farm Fault Tree 

Databank, and the frequency with 

which these corrections may need to 

be applied to external dose. While 

correction factors can, in principle, be 

calculated, it is not clear that a 

scientifically valid set of scenarios, 

including time worked and 

radiological conditions, can be 

constructed. NIOSH has not 

addressed this issue in the ER.

NIOSH is preparing a model 

for developing adjustment 

factors due to geometry of 

exposure in the Tank Farm. 

SC&A will review the NIOSH report 

when it is published.

Update – February 21, 2014: NIOSH 

has stated that it is using MCNP 

modeling to address this issue. The final 

model has not been published. This 

issue was put into a low priority since 

external dose geometry issues have 

been satisfactorily resolved in the past 

and have not been SEC issues 

(ABRWH, 2013, pp. 57–64).

A more general issue of 

geometry, and specifically 

hand exposure, has been 

raised in worker interviews.

NIOSH is preparing a Tank 

Farm geometry report. Work 

group needs to address 

whether work beyond that is 

needed for SEC review.

Open pan burning issue is 

not relevant since it ended in 

Feb. 1972.

21 External exposure coworker data adequacy for 

CTWs 

7.2.1.3 ORAUT-OTIB-0052 (NIOSH, 2007a)

is claimant favorable for a large 

majority of CTWs. However, it is not 

claimant favorable for some 

categories. A bounding dose (or 

better) demonstration needs to be 

made for all CTW job types.

A suitable adjustment has 

been made for all CTWs. No 

further work is needed.

SC&A agrees that existing databases 

can be used for CTW coworker external 

dose estimation with appropriate 

adjustment. This does not include issues 

22 and 23, which do not concern 

coworker data adequacy. Refer to

SC&A’s review of OTIB-0052 (SC&A, 

2007).

Update – February 21, 2014: This issue 

has been resolved.

No issue at this time.

22 Badges not capturing 

dose

NA SC&A worker interviews suggest that 

workers kept their badges out of 

higher radiation areas in order not to 

exceed dose limits, or sometimes 

CTWs would be in radiological 

situations without knowing it (one 

incident is described when workers 

were working with radioactive tools 

thought initially to be clean).

NIOSH will review the SC&A 

report.

SC&A prepared a report compiling

worker issues relating to radiation dose 

as it was experienced compared to dose 

that was recorded. This includes matrix 

issue 23 (SC&A, 2011c).

Update – February 21, 2014: NIOSH 

has not responded to SC&A 2011c.

Update – March 2022: SC&A did not 

find a response or disposition on this but 

acknowledges that this is not likely an 

SEC issue.

No issue at this time.
SC&A, Inc.

SRS SEC Issues Matrix, page 17 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

23 External dose recording 

accuracy and 

completeness

7.3 Petitioners raised the issue of working 

conditions with high dose rates when 

badge dose may have been underrecorded or not recorded (such as 

weekend work) and/or pencil 

dosimeters were off-scale, or when 

there are zero doses in the record. An 

issue connected to this would be 

whether the HPAREH database 

reflects actual work experience.

Petitioners also state that in some 

cases, workers thought they were 

working in clean areas that were then 

determined to be contaminated.

NIOSH will respond to the 

SC&A report.

SC&A 2011c covers both matrix issues 

22 and 23. 

Update – February 21, 2014: Refer to

update on matrix issue 22.

This issue has been merged 

with issue 22. SC&A 

prepared a single report on 

matrix issues 22 and 23.

24 Early monitoring data Various The ER has addressed lack of early 

monitoring data for many workers and 

radionuclides by a number of devices, 

including building coworker models, 

using reporting levels, using air 

monitoring data, and estimating n/p

ratios. While each of these needs to 

be assessed in its own right (as 

described in the issues listed in this 

matrix), an overall assessment of 

early recordkeeping practices, 

adherence to procedures, and 

adequacy of data appears to be 

warranted.

NA Update – February 21, 2014: This 

matrix issue has been resolved.

This issue had been merged 

with other issues but is no 

longer an SEC issue in view 

of the Board vote on Dec. 8, 

2011.
SC&A, Inc.

SRS SEC Issues Matrix, page 18 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

25 Environmental dose None Using dispersion modeling of stack 

source terms as described in the TBD 

and referred to in the ER (p. 72) is not 

appropriate for onsite SRS workers.

For instance, thousands of gallons of 

solvents contaminated with fission 

products and plutonium were burned 

in the burning ground. Use of a 

Gaussian plume model is not 

appropriate here, especially for 

particles greater than half a micron.

Furthermore, the resuspension factor 

does not appear to be claimant 

favorable and is not entirely 

appropriate for this class of problem.

It may not be claimant favorable by 

three or four orders of magnitude.

Even for stack releases, one 

potentially significant issue is the nonconservatism of the standard 

Gaussian model used in the TBD, 

where it pertains to 

“non-standardized” short-term 

releases occurring during stable 

atmospheric conditions.

Refer to issue 14. Update – February 21, 2014: Merged 

with issue 14. This matrix issue has 

been resolved for open pan burning.

This issue has been merged 

with issue 14. Now resolved 

since open-pan burning 

stopped in Feb. 1972. Refer 

to comment for issue 14.
SC&A, Inc.

SRS SEC Issues Matrix, page 19 March 11, 2022

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. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

26 Additional worker and 

worker representative 

issues

NA Worker and petitioner representatives 

raised various issues during work 

group meetings and comment 

periods.

NIOSH will respond to SC&A 

report.

SC&A compiled a report detailing the 

issues raised and categorized them, with 

an indication of where the issue was 

already covered by an existing matrix 

issue (SC&A, 2011d).

Update – February 21, 2014: NIOSH 

has not provided a specific response to 

SC&A 2011d. The issues raised in 

SC&A 2011d are broadly similar to 

matrix issues 12 and 22/23 in most 

cases, but workers provided specific 

additional examples, such as lack of 

Health Physics coverage in some cases.

Update – March 2022: While a number 

of these comments are addressed in 

other SEC issues reviewed by the work 

group and NIOSH, a full response is not 

evident. SC&A acknowledges that none 

of the issues to date are of apparent 

SEC significance.

No issue at this time.
SC&A, Inc.

SRS SEC Issues Matrix, page 20 March 11, 2022

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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