2.0 TASK 2 - SITE PROFILE REVIEW
This sectionpresentsSC&A' s proposal for perfonning Task 2 of the TORP. Much of the material presentedaboveregardingproject management Task 1 applies to this task also and is for not repeatedhere.
2.1
UNDERSTANDINGOF THE TASK AND ITS OBJECTIVES
It is our understandingthat this task includes the following subtasks: Preparea site profile review procedure(delivered to NIOSH within one month from authorization to proceed) Review the conditions, processes, practices,and incidents at selectedDOE and A WE facilities coveredunder EEOICPA to evaluatethe adequacyof the information available in the NIOSH site profiles for 10 to 12 DOE facilities and 2 to 4 A WE facilities. (3) Evaluateworst-casedoseestimatesresulting from the site profiles to detennine adequacyof the data and validation of the data and assumptions. Conduct meetingsand interviews with site expertsas authorizedby the Board
Prepare reports, including:
(4) (5)
Site profile review procedure Monthly summaryof progressfor all site profile reviews A final report for eachsite profile review A final summaryreport with aggregatefindings
2.2
TECHNICAL APPROACH
In order to accomplishthe objectivesof this task, SC&A will preparea site profile review procedureand then, following approval of the procedureby the Board, use the procedureto accomplishthe following:
(1)
Identify and evaluatethe approachtaken in compiling the site profiles through a comprehensive processof independentlyidentifying the selectedsite's operational history Review all relevant data sources,such as occurrencereports, inspection documentation,safety analyses,etc. Interview worker representatives, worker advocacygroups,and other individuals having knowledge or expertiseon site operationalor radiological history
(2)
(3)
"2--1
(4)
Evaluate worst casesdosesresulting from the site profiles to detemline adequacy of the data and validation of the data and assumptions
Preparea Site Profile ReviewProcedure
SC&A will usethis proposalof work as the basis for preparing a site profile review procedure. We believe that the technical approachfor performing site profile reviews as describedin the following sectionsconstitutesa draft framework for a review procedureand representsa draft deliverable for this subtask. Reviewing Site Operational History For many DOE and A WE sites,reliable dosimetry recordsmay be lacking, particularly for workers from the 1940sthrough 1960s. In theseinstances,historic operat!c::.al infomlation that includesthe nature of operations,radiological sourceterms in use,processmaterial concentrations, and location and time periods of worker activities may be the only data available for doseestimations. Such infomlation can be extractedfrom historic recordsand documentation being collectedby (or accessiblefrom) the Departmentof Energy, including operational records, material inventories,safety and health inspectionsand assessments, occurrencereports and routine memorandumand facility reports. This possible sourceof infomlation will be surveyedat the DOE site or AWE recordscollection point to ascertainwhether the site profiles adequately reflect at leastthe following information, where feasible: Operational processes over time, including improvements,up~des, modifications and terminations (important becauseworker exposuresare often higher during major process changes). Historic radiological inventory, sourceterms, and movementthrough facility ("mass balance") to include feed material, products,and byproduct and waste streams. Any unplannedevents,including radiological over-exposures, contaminations, releases,spills, criticality incidents, and unusual occurrences. Changesin contractor management and attendantchangesin safety policies, proceduresand practices (important becausenew contractors import new radiation protection programs). Applicable standardoperatingprocedures,memoranda,directives or recorded practicesgoverning onsite management radioactive materials and processes. of Actual historic operationalpracticesestablishedby first hand accounts(e.g., worker representatives, "experts," etc.) (important becauseactualfacility site practices often variedfrom official procedures).
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Historic radiation protection programsin place, including personnelmonitoring requirements,protective equipmentpractices,dosimetric techniquesand equipmentin use,and procedural enforcementhistory (important to determine whether and to what degreethe dosimetryprogram reflected actual potential exposures possible, given source terms involved). Worker rosterswith identifiers, work assignments and location, as well as summaryof work histories sufficient to determinewhat categoriesof workers were assignedto what type and locations of radiological work. It would be useful to have data on the number of monitored workers, number of workers with doseshigher than the minimum detectablelevels, averagemeasurable recordeddoses,minimum detection levels, and whether dosesbelow the detection limit were recordedas zero. Even better would be to have data on number of workers in specified doseranges. The reviews will check if this information is provided or if it appearsfeasible for the site profiles to include such information. The foregoing information will be usedin a comparativemannerto ascertainwhether the site profiles are complete in how they characterize,from a historic standpointat a particular site, what radiological materialswere presentand in what concentrationsand chemical forms, what worker groups may have been in proximity with sourcesof exposureand whether certain activities or unplannedeventsmay have made suchexposurelikely, and what administrative procedures, operationalpractices,protective equipmentuse,and facility conditions may have influenced the likelihood of suchexposure. 2.2.3 Reviewing Relevant Data Sources SC&A will detennine whether the NIOSH contractor appropriately identified, evaluated,and incorporatedall relevant data sourcesby comparingthe extent to which such information is presentin the profile with what can be identified via an independentreview of suchsourcesof infonnation. Data sourcesthat will be scannedinclude the following:
Department Energy of Field Offices Operating contractors Institutionalhistories Inspector General files Headquarters field oversight and reports Radiation exposure assessments Atomic Weapons Establishment Centers Disease for Control NuclearRegulatory Commission Environmental Protection Agency General Accounting Office Defense NuclearFacilitiesSafetyBoard Congressional HearingRecords
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Stateenvironmentaland safety regulatory agencies National Academy of Science Administrative!court records Departmentof Defense Environmental Monitoring Laboratory (fonnerly HASL) Workers compensationrecords Worker and public advocacygroups Historic recordsin private hands It is anticipatedthat a baselineof relevant information containedin theseand other data sources will be establishedat the onset,facilitating subsequent comparisonswith site profile information. 2.2.4 Interviewing Sources of Site Knowledge SC&A, as necessary, will conduct one-on-oneor group interviews with selectedsourcesincluding worker representatives, worker advocacyorganizations,individuals with site "expertise" due to past employmentor familiarity with operationalhistory, and otherswho can verify the adequacy of site-profile information that has been collected by the NIOSH contractor. Interviews will be conductedwhere convenientfor thesegroups,including near the actual site in question. Lines of inquiry will include the following: How did actual radiation protection practice comparewith documentedpolicy and procedures? Were there instancesof obvious "missed dose," e.g., not wearing or improperly wearing dosimeters,non-recordingof dose,etc.? Were there any incidents involving potential radiation exposure,whether reported or umeported? Were there special work activities or facility modifications which constituted processchangesthat increasedradiation exposurepotential? Were workers concernedabout past exposureor radiation protection practices? How did management respondand what, if any, changesoccurred in onsite practice? Did workers wear protective equipment,as required? Were radiological jobs plannedfor exposureminimization (e.g., ALARA)? What was the generalhousekeepingin the facility; was radiological contamination common during the history of the facility?
2'"
Were there special feed materials introducedor contaminantsof concernidentified from which radiation exposures may have resulted? Were there certain work activities at the facility that were considered"hotter" jobs from the standpointof potential radiation exposure? Were safety proceduresfollowed literally and did management assurethat they were enforceduniformly? In terms of conduct of operation,were workers pennitted to smoke,eat or drink in control areas? Was protective clothing and equipmentworn in theseareas;was egressmonitoring conducted? Were negative or "zero" dosesrecordedon periodic dosimetric recordsdespite known exposureto significant radiation sources? Were recordsand other documentationof radiation exposurediscardedor retained by management? Were there casesof over-exposedfilm and how were they treated? The infonnation extractedfrom theseinterviews will be usedto ascertainthe completeness and representation that in the NIOSH site profiles. of
2.2.5 Evaluate Wont
Case Doses
Usjng the site profiles and the infonnation compiled under sections2.2.2 through 2.2.4 described above,an evaluation of the worst casedoseswill be perfonned to detennine adequacyof the data and data validation of the data and assumptions.This will be accomplishedin a mannerthat parallels the blind dosereconstructionproceduresdescribedabove,with the exception that upper end estimatesof the doseswill be derived by using upper end dosimetry and bioassaydata,area monitoring data, and processknowledge, as compiled in the site profile.
2.3
TASK MANAGEMENT
In addition to his role as Deputy Project Manager, ' lead worker and site profile reviewer. As explained earlier, . - mows thehealth andsafetyissues at DOE and A WE facilitiesprofiles, as directed by die Board. reviews of worker and site and is thereforeespeciallywell qualified to provide independent -servedas Deputy Assistant Secretaryfor Health and Safety for DOE's Environmental Safety and Health (ES&H) division and is intimately familiar with DOE operationsand radiation protection practicesacross the DOE -=--.oDd complex. Both haveover30 yearsexperience, largeportionof whichconsisted a of
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workingwith II
DOE facilities. I
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- - on mattersrelated to Environmental Safety and Health (ES&H) at - - - - .~. will also participate in the review of site profiles.
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expert in nuclear engineeringand also a nationally recognizedadvocatefor worker
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rights. In addition, in fulfilling his responsibilities under this task;
the expertiseof any memberof the projectmay be called upon, outside expertiseif necessary.We team, or draw upon along with the internal and external anticipate - thaL anddosimetry expertiseon the project team, to support-. in all aspectsof the site profile reviews. As the work on this task unfolds, it may be necessary add additional personnelto the to project team. Any new individuals brought aboardto participate on this project will first undergo our conflict of interest avoidanceproceduresand review by the Board.
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I - can draw upon
2.4
WORK HOUR ALLOCATION AND SCHEDULEOF DELIVERABLES
Exhibit 2-1 presentsthe work hour allocation for this task. We set asidea modestlevel of effort for preparing the site profile review procedure,given the level of effort that has already been incorporatedinto preparing the technical approachto this section. Once the procedureis finalized and approvedby the Board, it will be usedto perform site profile reviews of 10 to 12 DOE and 2 to 4 A WE site profiles. We assumethat, on average,eachreview will require aboutwork hours. The d:raftprocedurewill be delivered within one month from authorization to proceed,which we assume will be February 2, 2004. Upon approval of our procedureby the Board, we will begin the site profile reviews. In accordance with the TORP, we have scheduledone year to complete the review of all deliverables,including monthly summaryof progressfor all site profile reviews, a final report for each site profile review, and a fmal summaryreport with aggregatefindings. For the purposeof estimatingthe level of effort required to meetwith site experts,we assumed that half of the 16 site profiles will require such meetingsand that eachvisit will require two individuals for .hours each,for a total of.work hours. We recognizethat SC&A obligations regarding this task also include support to Advisory Board meetings. The level of effort to supportBoard meetingsprovided in Task 1 includes addressing the statusand findings of Task 2 activities in addition to Task 1 activities.
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