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ALLIANCE ANNUAL REPORT
Occupational Safety & Health Administration (OSHA), Kansas City Area Office (KCAO) and
Ozark Underground Laboratory (OUL)
December 4, 2008

  1. Alliance Background

    Date Signed: August 21, 2003

    Dates Renewed: August 21, 2006 and September 28, 2007

    Overview

    This Alliance Agreement was initially signed in August 2003. The core purpose was to assist the Ozark Underground Laboratory (OUL) in helping the National Caves Association (NCA) deal with concerns about naturally occurring alpha radiation in caves and to develop strategies for concurrently protecting show caves, show cave employees, and show cave businesses

    Implementation Team Members

    Tom Alley, President, Ozark Underground Laboratory
    Mark Banden, Compliance Assistant Specialist, KCAO

    Evaluation Period

    September 1, 2007 – September 25, 2008

     
  2. Implementation Team Meetings

    None

     
  3. Events and Products

    Training and Education
    • Events

      In October 2007 Tom Alley attended the annual meeting of the NCA in San Antonio, Texas, and presented training to attendees on the cave radiation issue. He also met with several cave operators about their specific concerns and needs. He previously conducted training sessions at the NCA annual meetings in 2002 at Red Wing, MN; 2003 at Redding, CA; 2004 at Put-in-Bay, OH; 2005 at Bowling Green, KY; and 2006 at Hamilton, Bermuda. He also made a presentation on the issue to the International Show Cave Association at their 2006 convention (they meet every 4 years). Their meeting was held in Bermuda the week following the NCA annual meeting. He will conduct another training session in October 2008 in Entriken, PA.
    Outreach and Communication
    • Events

      Tom Aley made a 3-day trip to one of the large show cave operations in the Eastern U.S. to do detailed alpha radiation monitoring in a building directly connected to their cave. This monitoring aided in the design of modifications needed to keep cave air from entering the building.

      Requirements for new or continued membership in the NCA include having a professional monitor alpha radiation in each member cave and for each member cave to prepare, maintain, and follow a Cave Radiation Management Plan. These plans are reviewed by Tom Aley and, if they meet all requirements of the NCA Cave Radiation Management Program, they are certified by the President of the NCA. As of September 24, 2008:
      • 65 of the 74 private for-profit member caves in the United States have met all requirements and have been certified. At least 6 additional plans are in preparation and we expect them to be certified. Including these, 96% of the current private for-profit members are in compliance (or soon will be in compliance) with the industry standards adopted by the NCA. We are hopeful that the remaining 4% of the operations will also come into full compliance with the NCA standards; all of these caves have been monitored for alpha radiation and only lack the development and implementation of a Cave Radiation Management Plan.
         
      • 4 of the 5 caves (80%) that operate as non-profits or are local or county parks have met all requirements. We are hopeful that the remaining local park cave will come into full compliance by the end of September 2008; it has received alpha radiation monitoring.
         
      • The NCA has one foreign show cave member in Bermuda. Their two caves have been monitored but they have not yet prepared a cave radiation management plan. We expect that they will prepare such a plan.
         
      • There are 9 state-owned show caves that are members of NCA. All of these are in full compliance with the NCA cave radiation management standard.
         
      • There are five federally owned and operated show caves that are currently members of NCA. All of these have conducted at least some alpha radiation monitoring. One of the caves (Wind Cave, Wind Cave National Park) is fully in compliance with the NCA standards. The others have apparently taken the stance that industry health and safety standards do not apply to federal facilities. The President of NCA has informed me that the membership of the four non-compliant caves will not be renewed in October 2008 since compliance with the NCA cave radiation management strategy has been made a requirement for NCA membership. Three of these four caves have elevators that connect the caves with visitor centers. The federally-operated show caves that are current members of NCA but are not in compliance with the NCA Cave Radiation Management Standards are Mammoth Cave, Kentucky; Carlsbad Caverns, New Mexico; Jewel Cave, South Dakota; and Blanchard Springs Caverns, Arkansas. Blanchard Springs Caverns is operated by the U.S. Forest Service and the other three caves are operated by the National Park Service.
      The NCA President has mailed certified letters to all member caves that have not submitted cave radiation management plans. This letter informs them that their membership in the NCA will not be renewed if the required plans are not submitted by October 1, 2008.

      In the private and state show-cave sector I estimate that NCA members operate caves where 85 to 90% of all show-cave workers are employed. Most of the show caves that are not members are small operations with few employees.

      Several show caves that are not currently members of the NCA have contacted that organization to learn more about the cave radiation management strategy.

      Based upon management changes that have been made as a result of the Alliance Agreement we believe that total employee alpha radiation exposure has been reduced to levels that are consistent with the ALARA (As Low As Reasonably Attainable) strategy. We further believe that the reduction in total alpha radiation exposure has been in the range of 20 to 30% and up to 70% at some operations.
    Promoting the National Dialogue on Workplace Safety and Health
    • Events

      In October 2007 Tom Aley attended the annual meeting of the NCA in San Antonio, Texas, and presented training to attendees on the cave radiation issue. He also met with several cave operators about their specific concerns and needs. He previously conducted training sessions at the NCA annual meetings in 2002 at Red Wing, MN; 2003 at Redding, CA; 2004 at Put-in-Bay, OH; 2005 at Bowling Green, KY; and 2006 at Hamilton, Bermuda. He also made a presentation on the issue to the International Show Cave Association at their 2006 convention (they meet every 4 years). Their meeting was held in Bermuda the week following the NCA annual meeting. He will conduct another training session in October 2008 in Entriken, PA.

       
  4. Results
     
    Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
     National Cave Association Annual Convention-October 2007 in San Antonio, TX 100 Attendees

    Since the inception of this Alliance Agreement the OUL has conducted alpha radiation monitoring in 95 show caves. This has included boulder caves in New Hampshire, a sea cave in Oregon, lava tubes in Hawaii and New Mexico, and an incredible variety of caves in limestone, dolomite, and marble scattered across 19 states from California to Virginia and Texas to Minnesota. Two show caves in Bermuda were also monitored. The monitoring work took a little over three years to complete.

    A major report on the findings from the monitoring and a strategy for managing alpha radiation in show caves was presented at the 2005 National Cave and Karst Management Symposium and published in 2006. It was authored by Thomas Aley of the OUL, Kimberly Castillon of OSHA, and John Sagendorf, President of the NCA. The report was entitled “Strategy for managing alpha radiation in show-caves to protect caves, cave employees, and cave businesses”. Proc. of National Cave and Karst Management Symposium, pp. 62-71.

    An important finding from the OUL work was that 35 of the private and state-operated show caves have occupied buildings (such as visitor centers) that are connected to the caves. In several cases these connections are via elevators. Elevators connected to occupied buildings are also found at 3 of the federally owned and operated show caves that are currently members of the NCA. In some cases the connections between caves and buildings result in appreciable concentrations of cave air and associated alpha radiation in the buildings. For a number of reasons caves cannot be artificially ventilated to reduce alpha radiation concentrations. However, buildings connected to caves are a different matter. During our studies we found that total employee time spent in buildings connected to caves often exceeds the time spent in the associated cave

    As a result of this Alliance Agreement the NCA adopted an industry health and safety standard for the show-cave industry. To implement this industry standard the NCA has required all member caves to, among other things:
    • Have their caves and attached buildings monitored for alpha radiation by qualified professional using appropriate equipment. Tom Aley, a professional geologist licensed in four states and President of the OUL, has done most of this monitoring.
       
    • Develop a cave-specific cave radiation management plan, have it reviewed by the OUL for compliance with the NCA’s industry standards and for technical adequacy, and have it certified by the NCA President as being in compliance with the NCA strategy. Much of the implementation of this strategy has occurred in 2008.
       
    • Implement training to ensure that employees working in caves understand the cave radiation issue and that the persons providing the training have an adequate understanding of the issue.
       
    • Implement Best Management Practices (BMPs) to minimize total employee exposure to alpha radiation. Spreading the risk among a greater number of employees to minimize the exposure to some employees is not accepted by the NCA as a BMP.
       
    • Implement BMPs to reduce alpha radiation exposures to ALARA levels (As Low As Reasonably Achievable). Cave air must be prevented from entering occupied buildings if those buildings are attached to caves or connected to caves with elevators.

  5. Upcoming Milestones

    In conclusion, the parties believe this has been an extremely productive Alliance Agreement, and with the project complete, the alliance will be completed. Expenditures by the NCA in conjunction with this agreement have exceeded $100,000. Modifications made or currently underway of buildings connected to caves to reduce employee alpha radiation exposures have incurred a cost of about $1 million. Finally, the input to this program by OSHA has also been extremely valuable.