SC&A DRAFT FOR WORKING GROUP REVIEW 

February 6, 2007 

COMPLETENESS OF RECORDS FOR 1969 AND 1970 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted.

 
COMPLETENESS OF RECORDS FOR 1969 AND 1970 

During the course of SC&A’s review, a number of former workers from RFP were interviewed. 

Many of them expressed particular concern over the May 11, 1969 fire and its relevance to their 

dose reconstruction. Where available, DOE records were reviewed for individuals raising this 

particular concern. In some cases, it was noted that on the Occupational Dose Report 

(handwritten external data summary), the shallow and deep dose were blank. Computer 

printouts of deep dose results within the Health Physics file were recorded as zero when 1969 

results were listed, in place of the blanks. Hence, some records contain blanks and zeros, while 

others, for the same worker and the same badging period, contain zeros only. SC&A has verified 

that this situation applies to a number of claimants whose employment period included 1969. An 

additional observation made by SC&A was that doses during 1970 were significantly lower than 

those for 1968 or 1971. 

SC&A interviewed workers with 1969 gaps asking them if they were assigned a dosimeter in 

1969. The individuals indicated that there was no break in their monitoring, and that they did 

enter radiological areas during 1969 and 1970. Because this situation was encountered in several 

individual files, a review of the number of zeros in the RFP Coworker Data Stat (NDRP 

included, HIS20 Data) (NIOSH 2006x) was conducted. It was found that there was a sudden 

increase in the percentage of zeros from 1968 to 1969. The high percentage of zeros continued 

during 1970 then dropped significantly in 1971. 

These facts about the 1969 and 1970 (first part) of the external dose record raise some questions:

• What was the reason for the blanks in the records? 

• How were blanks recorded in dosimetry logs and HIS_20? 

• Was there a common reason for increase in blanks and zeros in 1969 in the individual 

raw data files? 

• What were the reasons for the increase in the zeros recorded in 1969 (relative to 1968)? 

• What were the reasons for the increase in the zeros recorded in 1970 (relative to 1968)? 

• Did the blank records that were assigned zeros correspond to exposure potential below 

the limit of detection (LOD) for the badges of the time? 

• How are the zeros in the dose records from unread and read badges to be distinguished, 

assuming that the zero results for read badges are less than the LOD? 

As a result of the preliminary concerns raised by SC&A, NIOSH evaluated potential hypotheses 

to explain the gaps and if they were related to the May 11, 1969 fire and its subsequent cleanup. 

Summary of the NIOSH Analysis of the 1969 Data Gap 

In response to SC&A’s concern, NIOSH determined that 136 claimants had gaps in dosimetry 

records for 1969. Further analysis of these individuals indicated they held a wide variety of jobs 

from administrative to production. In a few cases, the individual arrived at RFP within the last 

month of 1969, and may not have had dosimetry results for 1969. They investigated the 

radiation files of each worker in an attempt to ascertain reasons for the apparent “gap.” The 

RFETS SEC Petition Review 2 Working Draft – February 15, 2007 
investigation centered on 136 claimant files that had been identified as missing data for 1969. Of 

the 136, 35 had no external dosimetry data at all for 1969 for reasons that could not be readily 

explained. As NIOSH stated (NIOSH 2006x2): 

Only 26% of the records tentatively identified as “missing” were completely missing. 

Four of those in the table were not RFP employees during 1969 and another 17 were 

employed for less than a calendar quarter. For nearly 60% of the records there was some 

data reported, albeit sometimes only a single zero entry of a badge coding of “01” which 

indicated that the badge was not returned. Therefore, the putative gap is considerably 

smaller than it seemed originally. 

A number of hypotheses were tested by NIOSH to explain the gap, including data having been 

lost as a result of the 1969 fire, a computer reporting problem, and the possibility that some 

badges were simply not read. Since data exists for first responders and employees who 

participated in clean-up operations related to the 1969 fire, NIOSH concluded the gap was not 

connected with the May 11, 1969 fire. NIOSH stated (NIOSH 2006x2): 

The external dose monitoring patterns observed in 1969 are consistent with a 

combination of the policy to not read badges for staff in non-Pu areas on quarterly badge 

exchange cycles, and a computer problem that arose during this period resulting in dose 

being reflected only in cumulative dose totals. The programming error that reportedly 

resulted in a loss of monthly and quarterly detail data for 400 workers certainly would 

have created an apparent gap in the records for those staff, but would not have impacted 

their cumulative doses because the gap was discovered and addressed. 

NIOSH concludes (1) the 1969 data gap is much smaller than originally estimated, (2) 

the patterns observed in the 1969 dosimetry data are consistent with the administrative 

decision to not read film badges from employees stationed in non-Pu areas with low 

exposure potential, and (3) a computer programming error may have contributed to the 

lack of detail in the dosimetry data, but this was discovered and corrected in the 

cumulative dose totals. Therefore, NIOSH concludes that dose reconstructions can be 

performed with sufficient accuracy for claimants employed at Rocky Flats in 1969.

SC&A was asked by the working group to review the NIOSH analysis. 

Evidence of Systemic Data Gaps 

SC&A identified a sudden jump in zero entries from 1968 to 1969. The high proportion of zeros 

continued into 1970 and then fell back in 1971. These data were compiled from the RFP dose 

data posted on the O-drive [ABdoc review->RF->coworker data->RFP coworker data Stat 

(NDRP included, HIS20 data) posted 4/17/06]. Table X-1 below provides a summary of the 

number of zero entries each year in the HIS-20 database. As can be seen in this table, the 

percent of zero entries increases dramatically for these two years. 1969 and 1970 both had over 

36% zero entries for penetrating (neutron + photon) external doses while the previous 5 years 

(1964-68) showed an average of 9.7% zero entries and the post 5 years (1971-75) had an average 

of 10.5%. This is especially relevant considering that numerous workers were involved in a 

major fire that occurred during the second quarter of 1969. 

RFETS SEC Petition Review 3 Working Draft – February 15, 2007 
Table X-1 

 

Pene. Dose 

w/zeros 

Pene. Dose 

w/o zeros 

Year # of entries # of entries # of Zeros % of Zeros

1952 42 42 0 0.0 

1953 319 290 29 9.1 

1954 353 273 80 22.7 

1955 529 426 103 19.5 

1956 781 662 119 15.2 

1957 918 804 114 12.4 

1958 1062 927 135 12.7 

1959 1063 1011 52 4.9 

1960 1284 1065 219 17.1 

1961 1638 1461 177 10.8 

1962 2003 1779 224 11.2 

1963 2176 2047 129 5.9 

1964 2834 2610 224 7.9 

1965 2826 2639 187 6.6 

1966 2888 2658 230 8.0 

1967 2902 2530 372 12.8 

1968 3101 2690 411 13.3 

1969 3471 2197 1274 36.7 

1970 3308 2096 1212 36.6 

1971 3398 2995 403 11.9 

1972 3282 2621 661 20.1 

1973 3020 2465 555 18.4 

1974 2687 2658 29 1.1 

1975 2489 2461 28 1.1 

1976 2424 2271 153 6.3 

1977 3740 2347 1393 37.2 

1978 4176 1781 2395 57.4 

1979 3893 2441 1452 37.3 

1980 3752 1760 1992 53.1 

1981 4060 1496 2564 63.2 

1982 4851 2490 2361 48.7 

1983 5360 3631 1729 32.3 

1984 5673 3607 2066 36.4 

1985 6140 3993 2147 35.0 

1986 4942 4603 339 6.9 

1987 2583 2354 229 8.9 

1988 2778 2503 275 9.9 

1989 5296 2891 2405 45.4 

1990 3369 2602 767 22.8 

1991 5641 4951 690 12.2 

1992 5831 5429 402 6.9 

1993 5313 4534 779 14.7 

RFETS SEC Petition Review 4 Working Draft – February 15, 2007 
 

Pene. Dose 

w/zeros 

Pene. Dose 

w/o zeros 

Year # of entries # of entries # of Zeros % of Zeros

1994 4839 3198 1641 33.9 

1995 4130 2502 1628 39.4 

1996 3454 2761 693 20.1 

1997 3718 2452 1266 34.1 

1998 3470 2036 1434 41.3 

1999 3655 2138 1517 41.5 

2000 3576 1256 2320 64.9 

2001 3443 1518 1925 55.9 

2002 3502 1147 2355 67.2 

2003 3373 947 2426 71.9 

2004 2758 559 2199 79.7 

2005 955 562 393 41.2 

SC&A investigated whether this sudden increase and then decrease in the number of zero was 

indicative of data entry/credibility problems and what its implications might be for dose 

reconstruction. 

It was also noted that similar sudden jumps in zeros are indicated from 1976 to 1977. The high 

proportion of zeros persists until 1985, and then drops in 1986. SC&A has not investigated these 

additional years with high proportions of zeros in detail; however, there were several changes in 

the dosimetry program that occurred around this time. In 1976, the dosimetry group 

implemented the Health Sciences Database (Langsted 2004). At about that time, a decision was 

made change the background subtraction method for TLD dose determination (Lagerquist 1975). 

Beginning January 1, 1976 we will be subtracting background from all external radiation 

measurements of our employees. 

This background will be the average of the environmental measurements that we have 

made on plant site and in nearby communities.

Langerquist (1976) indicated that an average background of 0.34 mrem/day was subtracted from 

the badge. There was also a proposal to record zero for doses less than 10 mrem (Lagerquist 

1976): 

We are considering converting all employee readings of less than 10 mrem to zero also, 

but we want to look at the 1976 data first. 

Further, americium operations changed in 1976 and americium recovery was stopped in the late 

1970s (Rocky Flats Site Profile, Vol. 2, pp. 11-12). This would be expected to significantly 

reduce external dose in some plutonium areas. It should also be noted that SC&A did not 

discover comparably large gaps for entire years in this period in its random sampling (see 

Chapter 8).

RFETS SEC Petition Review 5 Working Draft – February 15, 2007 
Claimants with Data Gaps 

NIOSH identified 136 claimant files that were identified as “missing data for 1969,” with 26% 

of these files determined to have no external dosimetry for all of 1969 and others having data for 

portions of the year. NIOSH listed only one “Fire Protection Engineer” and no firefighters. 

Table X-2 contains a subset of the 136 individuals, all with blanks for four quarters of data on 

their 1969 Health Physics External Radiation Exposure Report (HPERER) in the Health Physics 

File. These 19 individuals worked all four quarters during 1969 and most continued employment 

into 1970. Each also had at least one badge reading in the 1969 Dosimetry Processing logs 

where there was no indication of a late or unreturned badge. 

Note that “Individual 19,” listed in Table X-2, is a fireman. He indicated in his CATI that he 

was involved in “suppressing the fire” and with subsequent fire watches. In fact, he received an 

in vivo count shortly after the fire for a “potential inhalation from the 776 fire.” There is no 

explanation for his missing data in 1969; however, one would assume that his badge was read, 

and that he was changed to a monthly dosimeter cycle with the other fireman. SC&A has not 

confirmed this. 

The case of an individual not listed in Table X-2 is also relevant.1

 In fact, he submitted an 

affidavit within the SEC petition in which he raised concerns that his film badge readings did not 

match his job duties. He worked as a Laboratory Technician supporting Non-destructive 

Analysis. According to the petition affidavit and the CATI, this individual performed duties in 

Buildings all over the site, including plutonium processing buildings. The 1969 dose on his 

HPERER was blank for all four quarters. The first three quarters on the 1970 HPERER were 

recorded as zero with a significant drop in annual exposure for that year compared to doses in 

1965-1968. No 1969 data at all were available for this individual on the Dosimetry by Individual 

report or in HIS-20 – that is, the year 1969 was missing altogether from the Dosimetry by 

Individual Report and the worker was not in the HIS-20 external dose database. The recorded 

deep doses for 1965, 1966, 1967 and 1968 were 1512, 1804, 4130 and 645 mrad respectively, all 

above the 10% limit. The personnel file indicates he was assigned to Building 444 in 1965 and 

1966. For portions of 1967 and 1968 the individual spent time in the plutonium areas. The 

individual stated in the CATI he was involved in the 1969 Fire Clean-up. Within the Health 

Physics file are reports indicating that he received an abrasion in 1969 and a puncture wound in 

1969 in Building 777. This would indicate that during at least some portion of 1969, he was 

working in Building 777. It is noteworthy that for at least three quarters in 1969, the individual 

was formally assigned to Building 444, which was a non-plutonium area even though he was 

performing work in a plutonium area. There were no densitometer readings in the dosimetry 

processing logs and zeros were entered for three quarters in the dose readings with arrows, 

indicating that his badges were not read. In the fourth quarter, there is a blank in the log, with a 

notation that the badge was not returned. He was still listed as being assigned to Building 444 in 

that quarter. He was on a quarterly badge cycle. This case raises questions regarding the policy 

of not reading badges for non-plutonium areas that was instituted in 1969. It shows also that 

individuals entered areas other than those to which they were formally assigned and illustrates as 

 

1

 He was not included in the table because his data are completely missing from the HIS-20 database, making a 

comparison with the other databases impossible. His name is slightly misspelled in the 1969 Dosimetry Processing 

logs. SC&A verified the data by reference to his badge number. 

RFETS SEC Petition Review 6 Working Draft – February 15, 2007 
well the complexities introduced into dosimetry issues by the fire and the earlier decision to 

selectively not read quarterly badges. 

On May 11, 1969, a large self-ignited fire occurred in Building 776 with contamination spread to 

Building 777. A total of 33 fireman and Security Guards were used at various time in fighting 

the fire. Personnel were contaminated at levels from a few hundred to greater than 100,000 dpm 

alpha/60 cm2

. Dow medical personnel, Radiation Monitors, Body Counter technicians, and six 

AEC personnel assisted in decontamination, monitoring, and contamination control. Following 

decontamination, the employee was sent to the in vivo counter. Forty-one employees were 

decontaminated and checked with the body counter in the first 24-hours. Initial counts indicated 

that 15 of the 41 employees counted had positive plutonium results. The only significant 

inhalation of plutonium attributed to the fire involved a fireman (AEC 1969). 

Several Radiation Monitors relayed to SC&A that they discarded contaminated badges, or 

badges on significantly contaminated clothing were discarded (See Attachment 5). Logbook 

entries reviewed for other time periods support the practice of destroying contaminated badges in 

the field (See Attachment 3). This would be a reasonable solution if badges could not be 

decontaminated because the facility would not have wanted to contaminate the Dosimetry 

Processing Laboratory. The destruction of contaminated badges may also have contributed to 

the gaps in 1969. The Dosimetry Processing logsheets for 776 are divided into 776A and 776B. 

For May 1969, 776A and 776B had a total of 90 and 192 individuals listed, respectively. 776A 

had 16 badges identified as “not returned.” 776B had 59 badges identified as “not returned.” 

This high level of “not returned” badges may be indicative of badge destruction in the field when 

badges were contaminated. This would not be restricted to specific areas on the plant site, and 

would have implications for plutonium as well as non-plutonium area workers.2

Computer Error 

Individuals responsible for data processing were actively involved in development of computer 

programs for TLD dose calculating programs, data management, and sample scheduling during 

the early part of 1969. In some cases they were experiencing difficulties. The Status Report – 

Dosimetry – February, 1969 (Mann 1969a), indicates a data processing error for the year end 

[presumably 1968] external exposure data. 

The year end external exposure data program appears to be correct now. Corrections 

necessary to the periodic film badge runs have not been made yet. We are not getting 

satisfactory service from this group (Data Processing). 

In Status Report – Dosimetry – April, 1969 (Mann 1969b), a computer error was noted. 

The entire film badge program is being rewritten to take care of recent programmer 

errors. We are furnishing accumulated dose to date data on 400 "lost" employees to update their master tape

 

2

 Note that partial year missing data, such as that created by discarding one or two badges in a year, is not included 

in SC&A’s minimal data completeness screening analysis in Chapter 8. 

RFETS SEC Petition Review 7 Working Draft – February 15, 2007 
NIOSH has associated the computer error with 1969; however, no definitive documentation was 

provided to substantiate this hypothesis. Specifically, it appears from the early 1969 dosimetry 

progress reports that they were having difficulties with the year end external data for 1968. 

Furthermore, letters in Health Physics files document a computer error occurring in 1968 (RI, 

1976). It is possible that the error NIOSH is associating with 1969 is actually related to 1968 

data. Adjustments to dose (cumulative or otherwise) were often documented on a letter and 

placed in the individual Health Physics file. There is no indication of an adjustment in 

accumulated dose for 1969; however, letters were present in the Health Physics files for 

adjustments made as a result of a computer error in 1968 (RI, 1976). 

Non-Plutonium Area Badges Not Processed 

SC&A concurs with NIOSH that RFP decided not to read non-plutonium area badges in early 

1969. In a letter to Mann, Vogel (1969) recommended that non-plutonium area film badges not 

be processed because most of the individuals received less than 10% of the in-plant working 

level. 

It is recommended that the film badge continue to be issued and worn as it has been but 

that the film not be processed except for a few specific groups or for particular 

circumstances.....The circumstances that might require processing of film for some 

individuals or groups would include accidents, special operations work involving special 

material, or to reaffirm the validity of this approach (Vogel 1969). 

Below is a listing of “non-plutonium” area buildings and a brief description of what activities 

occurred in these buildings. 

Table X-3: Description of Non-Plutonium Buildings as Determined by RFP Radiological Control 

Badge Storage Area 

Building No. 

Description of Activities 

111 Administrative Building 

121 Plant Security and Armory 

122 Emergency Medical Services Facility 

123 Analytical Health Physics Laboratory 

125 Standards Laboratory 

331 Vehicle Maintenance and Fire Station 

334 Central Shop and Maintenance 

440 Transportation Modification Center 

441 Production Support 

442 Filter Test Laboratory and Warehouse 

444 Depleted Uranium Processing 

551 General Warehouse 

705 Coatings Laboratory 

750 Production Engineering Support 

881 Manufacturing and General Support 

883 Uranium Rolling and Forming Operations 

865 Metal Research and Development Laboratory 

The specific groups in the non-plutonium areas who were exempted from this practice included 

Health Physics Electronics, Health Physics Operations, Nuclear Safety, Mfg. – Uranium 

RFETS SEC Petition Review 8 Working Draft – February 15, 2007 
Chemistry, Mfg. – Production Control, and Quality or Non-destructive testing. While it was not 

considered necessary to wear the film badge to measure this very low level chronic exposure, 

they felt it desirable to wear the film badge to measure accidental exposure. Vogel (1969) 

indicated that implementation of this policy would result in a reduction in film processing 

workload by at least 1,000 packets per quarter. 

The film was to be retained for a several weeks after the regular film badge change before it was 

discarded (Vogel 1969). 

The Status Report – Dosimetry – March, 1969 (Mann 1969c) indicates this practice was 

implemented. 

Quarterly badges for the non-Pu areas will no longer be read routinely, except for a few 

higher risk groups. The film will be changed as usual, but will not be read unless 

circumstances warrant. 

A memorandum from Mann to the Dosimetry Technicians (Mann 1969d) states the policy will 

be effective with the first quarter change of 1969. The memorandum continues: 

Film from the badges of all other groups [those not processed] is to be saved for three 

weeks after the exchange, then discarded. 

SC&A notes that this policy of not reading some workers’ badges was instituted before the May 

11, 1969 fire. SC&A partly concurs with NIOSH in that many of the gaps in data are not related 

to the fire. However, as noted above in the case of the fireman, it appears external dose data 

related to the fire may also be missing. 

Unread badges also appear to be indicated when zero is recorded for the dose result, but no 

density readings are listed for the particular badge as they are with those that are clearly read. 

After review of the Dosimetry Processing logs, it was noted that quarterly badge results are 

primarily recorded as zero for Buildings 111, 121, 331, 334, 441, 444, 750, 865, 881, and 883. 

The lack of density readings persisted through 1969 and 1970. Furthermore, badges from 

plutonium area workers did have density readings recorded. One difference between 1969 and 

1970 was that handwritten Occupational Dose Reports would indicate zero in 1970 rather than 

blank, which was the case in 1969. It is possible that the zeros in the dose columns for deep and 

shallow dose in the dosimetry processing logs were entered without a corresponding density 

entry as a matter of convenience. However, it is much more likely that they were zero entries 

when badges were not being read, since a policy to this effect was instituted in 1969. Other 

evidence, discussed below, clearly leads to this conclusion. NIOSH’s reading of these logs is the 

same as SC&A’s – that these zero entries represent unread badges: 

Monthly "Status Reports" prepared by John Mann, the manager of the Dosimetry 

Program addresses the issue of data sheets with zeros written at the top and with 

arrows down the entire page. The status report dated April 8, 1969, Item A.3 

states: "Quarterly badges for the non-Pu areas will no longer be read routinely, 

except for a few higher risk groups. The film will be changed as usual, but will 

RFETS SEC Petition Review 9 Working Draft – February 15, 2007 
not be read unless circumstances warrant.” [NIOSH, undated, Summary of 

Investigations Regarding 1969 Data Gap, published in 2006]

Table X-2 lists nineteen claimants with 1969 gaps from among the 136 individuals initially 

identified as having data gaps in the Occupational Dose Report. These individuals worked all 

four quarters during 1969 and most continued employment into 1970. SC&A examined four 

different data records for these 19 individuals for 1969: 

1. The Occupational Dose Report, which is the handwritten summary dosimetry report in 

the HP file; 

2. Dosimetry History by Individual, which is a computer print out generated prior to the 

HIS-20 database creation 

3. Health Physics External Radiation Exposure Report (HPERER), quarterly summary 

reports. 

4. The HIS-20 computerized database, which NIOSH is using for its co-worker model.3 The 

individuals also had dose values for 1969 in the RRFP Coworker Stats (NDRP Included, 

HIS-20) file located on the O-drive. In each case, all the blank values in the HPERER 

were recorded as zeros in the HIS-20 database. 

Examples of the Occupational Dose Report, Dosimetry History by Individual, and Health 

Physics External Radiation Exposure Report are available in the External Dosimetry TBD 

(Langsted 2005, pp. 52-55, 61). The individuals also had dose values for 1969 in the RRFP 

Coworker Stats (NDRP Included, HIS-20) file located on the O-drive. Each of the four external 

dosimetry sources (Occupational Dose Report, Dosimetry History by Individual, Health Physics 

External Radiation Exposure Report (HPERER) was reviewed to determine the dose values 

entered for 1969. 

In all 19 cases, the HPERER data show blanks for the entire year (indicated as “Null” in the 

Table X-2). Sixteen show blanks in the handwritten Occupational Dose Report in their Health 

Physics file, while three individuals did not have such a report in their Health Physics file. Note 

that a typed version of an Occupational Dose Report under a different name is not referred to 

here since it was available for only a few individuals. Null is indicated in Table X-2 only when a 

blank was documented for each quarter of 1969. Hence both Occupational Dose Report and the 

HPERER data show by their blank entries that the badges of these workers were not read. 

In contrast, the Dosimetry History by Individual computer printouts show the following (see 

Table X-2): 

• Zeros for ten individuals having 1969 data for the deep dose instead of blanks and a blank 

for the shallow dose. 

• No Dosimetry History by Individual in the Health Physics file for nine individuals 

(indicated by N/A). 

 

3

 At this stage SC&A has not established whether the external HIS-20 has been used in individual dose 

reconstruction . 

RFETS SEC Petition Review 10 Working Draft – February 15, 2007 
Finally, the HIS-20 database shows zeros in all 19 cases for both shallow and deep dose. This 

would demonstrate that in both the processing logbooks and the computerized databases, that 

unread film was entered as a zero. The entry of zeros for unread badges to the conclusion that 

the sudden increase in zeros in 1969 in the HIS-20 database (Table X-1 above) is very likely 

mainly due largely to a zero entry in the database in place of the blanks in the Occupational Dose 

Reports and the HPERER data. This conclusion is buttressed by the fact that the decision no to 

read a certain category of badges resulted in a large decline in the number of badges read (1,000 

packets per quarter – see above). 

The other bases for this conclusion include: 

• The increase in the number of zeros from 1968 to 1969 from 13.3 percent to 36.7 percent. 

• Quarterly cycles badges were not read starting in 1969 (Mann 1969c) 

• The blanks in some databases show up as zeros in others, notably the HIS-20 database 

and in the data showing Dosimetry History by Individual 

• Workers with blanks (subsequently zero in the HIS-20 database) were assigned to areas 

considered non-plutonium work and fit the profile of those referred to in the memo for 

non-reading of issued badges. While the fire caused a stoppage of plutonium operations, 

this cannot account for non-plutonium workers with gaps in their dosimetry records. 

• The same workers had densitometer readings in earlier periods, but none in 1969. 

The practice of recording zeros for dose and providing no densitometer readings in the 

Dosimetry Processing logs continues into 1970. The existence of non-zero doses for the same 

workers in the HPERER records in 1970 indicates that it may have changed before the end of the 

year. This is also reflected in the reduction in the percentage of zeros from 1970 to 1971. 

SC&A has not come across any document that allows a definitive date for the ending of the 

practice of not reading issued badges to be established. Further, it is to be noted that the nonreading of badges of at least some workers started earlier than 1969 and continued later than 

1970, as evidenced by the case of a secretary who had blanks in her dosimetry record from 1963 

to 1973, inclusive (November 6, 2006 Working Group meeting transcript, pp. 76-78). This 

raises the possibility that the 1969 policy change was a formalization or continuation of an 

earlier practice that may have affected a smaller number of workers. 

In summary, based on information in dosimetry correspondence, the site implemented a practice 

of not reading the assigned quarterly dosimetry badges of non-plutonium workers. As NIOSH 

has stated, the Dosimetry Program addresses unprocessed dosimeters by recording zeros on the 

log sheet and/or arrowing down the page, with zeros recorded at the top. Figure 4-1 is an 

example of a log sheet where arrowing down the page is shown. In the evaluation of nineteen 

claimants with 1969 data gaps, it was determined that the HIS-20 and Dosimetry History by 

Individual data files contain zeros in cases where badges were not read, contributing to the 

significant increase in the number of zeros from 1968 to 1969. This brings into question the 

integrity of those data records and partially substantiates worker claims that RFP recorded zeros 

when badges were not read (and not just when they were not handed in). Moreover, as discussed 

below, some job types among this group of workers clearly had significant dose potential. This 

is also illustrated by the case of the worker not included in Table X-2, discussed above. 

RFETS SEC Petition Review 11 Working Draft – February 15, 2007 
The individuals whose badges were not read were assigned to “non-plutonium” areas as defined 

by Rocky Flats Radiological Control staff. As shown in Table X-2, many of these individuals 

were located in uranium areas where uranium was handled or processed (e.g., 444, 881, 883). 

Others were employees who were housed in non-plutonium area or administrative building, but 

visited Radiological Areas (including plutonium areas) as a part of their job responsibilities. 

To further evaluate the exposure to non-plutonium area workers, SC&A compared doses from 

the fourth quarter 1968 Dosimetry Processing sheet and the first quarter 1969 Dosimetry 

Processing sheet for eighteen individuals. The individuals were assigned to Buildings 111, 331, 

441, 444, or 883 during this period of time. The policy for not reading non-plutonium area 

badges was implemented the first quarter of 1969. A comparison the Fourth Quarter 1968 and 

First Quarter 1969 logsheets was completed. Also included in the table is the result recorded for 

Fourth Quarter 1968 and First Quarter 1969 from the HPERER in the Health Physics file. Table 

X-4 provides the results of this comparison. Figures 4-2 and 4-3 are examples of the Fourth 

Quarter 1968 logsheets and the First Quarter 1969 logsheet. With a few exceptions the same 

individuals are included on both sheets. All individuals were on a quarterly exchange cycle and 

there was no indication of a late or unreturned badge. The results from the 1969 First Quarter 

logsheet were all zeros or zero with an arrow down the page. As can be seen from the table and 

the figures, doses were not zero in the fourth quarter of 1968 prior to the implementation of the 

no-read policy. This review also indicated that although badges were not read in the first quarter 

of 1969, the individual may have readings for later quarters. In these cases, the annual dose for 

1969 would reflect the dose from the quarters where badges were read. This indicates gaps in 

1969 can occur for only a portion of 1969. Hence the problem of zeros in the 1969 data record 

when badges were not read is larger than that indicated when only blanks for the entire year are 

considered. 

External dose exposure potential, notably shallow external dose in some uranium areas, could be 

very high. This is noted in the Rocky Flats site history (Putzier, 1982): 

 

In earlier years in handling large quantities of depleted uranium, and to some 

extent this is true in more recent years, we did have a significant radiation control 

problem in Building 444. This was not experienced so much in the machining 

areas but in the part of the foundry operations we call burnout and breakout. 

Castings were removed by breaking them out of the molds. This operation and 

the recovery of the material from the casting and handling the molds themselves 

resulted in very high beta radiation levels. There was an extremely high level of 

beta radiation associated with this because the first two daughters of 238U are 

beta emitters and during the molten state of the uranium there is a tendency for 

these two daughters to flow to the top and also to show up at the interface of the 

uranium and the mold itself thereby enhancing the amount of beta radiation 

coming off from the chunk of the material. We used to use as a rule of thumb that 

clean uranium metal in equilibrium with at least its first two daughters would give 

off on the order of 200 mrad per hour beta radiation at the surface of a piece of 

the metal. This went up by at least an order of magnitude and probably more 

than that. We can say that we say readings as high as 2000 to 3000 mrad/hr on 

castings of depleted uranium that were in the foundry area. Then, too, the dusts 

RFETS SEC Petition Review 12 Working Draft – February 15, 2007 
which were generated in the burnout and breakout areas settled on various pieces 

of equipment and from that there were additional beta radiation fields generated. 

This also resulted in excessive dust in the atmosphere. The housekeeping of these 

areas was indeed a very important control problem, and as I recall, in those days 

was handled very well. [Putzier 1982, pp. 74-75 of the pdf file] 

This description of radiological conditions in at least some uranium areas from the 1950s into the 

early 1980s (though apparently with lower intensity of problems in the later years) shows that 

external shallow dose rates in some uranium areas were very high – much higher than the 

theoretical maximum of about 240 mrad/hour contact dose with U-238 metal in equilibrium with 

Th-234 and Pa-234m. The high dose rates and non-zero doses mean that the zeros that were put 

in place of blanks for unread badges cannot be generally interpreted as LOD or LOD/2. 

The non-reading of badges and zeros in the data records, including the HIS-20 database, in place 

of blanks raise four distinct issues of data integrity: 

• Not reading badges that were issued is not consonant with sound practice, especially 

since at least some of the workers concerned were known or should have been known to 

have prior exposures above the LOD of the badge. Throwing away the badge after a few 

weeks converted a problem of unsound practice to a problem of data integrity because it 

obviated any possibility of verifying the low exposure assumed in initiating the practice. 

• While the non-reading of badges may have been done with the intent of minimizing work 

related to reading badges of workers judged to have low exposure potential, the facts 

relating to at least some non-plutonium work indicate that this was an erroneous belief, 

notably for shallow dose. The non-reading of badges that were issued was therefore a 

practice that partly supports a claim in the SEC petition that workers with significant 

exposure potential had zeros entered in their badge records. 

• Entry of zeros in some data records when the badges were not read, and were in fact 

discarded, raises questions about the integrity of the data recording practices. It is 

important to note that SC&A has found no evidence that the intent was to fabricate data. 

However, SC&A also notes that a record containing zeros for badges that were not read is 

fundamentally flawed in as much as the records cannot be said to correspond to the 

reality of the working conditions of at least some of the affected workers. That part of 

the record for 1969 and 1970 cannot be said to meet the test of scientific integrity of data 

as it is commonly understood. 

• Some workers whose badges were not read appear to have worked in plutonium areas 

even though their formal assignments shown on the dosimetry processing logs are 

indicated as being to non-plutonium areas. Non-reading of such badges, especially 

during the post-fire period poses additional special issues. 

It is not clear whether the external dose data from plutonium areas can be used to create a coworker model for uranium areas, given the problems of high beta radiation discussed above. 

Uranium beta radiation in some areas was likely to have been much higher than in plutonium 

areas. At the same time, some plutonium areas in some periods had high external gamma 

radiation (in relation to high americium content of reactor grade plutonium processed in some 

RFETS SEC Petition Review 13 Working Draft – February 15, 2007 
periods and high fission product content on the surface of early Savannah River plutonium 

buttons – Putzier 1982). 

The problem of creating a co-worker model for the workers affected by the practice of entering 

zeros in place of blanks is further complicated by the involvement of some of them in the fire 

and cleanup in 1969. It should also be noted that SC&A has not investigated whether the same 

practice of entering zeros in the HIS-20 database affected other periods where significant 

numbers of zeros or blanks are observed in external dose records, notably the 1950s period (see 

Chapter 7 for a description of the completeness investigation other than for 1969). Finally, work 

with radionuclides other than uranium in non-plutonium areas may also have created similar 

issues. SC&A has not investigated this problem. 

Conclusions 

Based on their analyses of the problem, SC&A and NIOSH concur that there are gaps in the 

1969 external dosimetry data for some workers. A significant part of the problem arises from a 

policy of not reading quarterly badges (with some possible exceptions) instituted in 1969. 

SC&A has also pointed to gaps in 1970, but no similar detailed response has been forthcoming 

from NIOSH. 

NIOSH has concluded that although this data gap exists, dose reconstruction can be performed 

with sufficient accuracy in 1969. As things stand at present, SC&A is not in accord with this 

conclusion in as much as NIOSH has not demonstrated that it can do so, given the specific 

working conditions of the workers whose badges were not read. 

The assumption that workers in non-plutonium areas were not at risk of high external exposure is 

incorrect, especially regarding beta dose in some specific uranium work areas. There is, at 

present, no available method for addressing the dose reconstruction corresponding to the blanks 

in the dose records from 1969 onward that resulted from the practice of not reading issued 

badges. There also does not appear to be any straightforward method to use the HIS-20 database 

for a co-worker model; blanks corresponding to significant exposure potential may be mixed in 

with “other” zeros that were entered with actual zeros corresponding to a badge reading of less 

than the detection limit. SC&A has concluded that the integrity of at least a portion of the 1969 

and 1970 dose record has been significantly compromised by the practices discussed above. 

Further, as noted above the non-reading of badges of at least some workers appears to have 

started earlier than 1969 and continued later than 1970, as evidenced by the case of a secretary 

who had blanks in her dosimetry record from 1963 to 1973 (inclusive). Given that at least some 

groups of 1969 workers whose badges were not read likely had significant exposure potential, it 

is essential to investigate the starting and ending dates of the practice of not reading assigned 

badges and to explicitly determine the exposure potential of the groups of workers who were 

affected. 

Constructing a coworker model and demonstrating that it meets the test of dose reconstruction 

with sufficient accuracy under 42 CFR 83 for all members of the class affected by the practices 

RFETS SEC Petition Review 14 Working Draft – February 15, 2007 
and policies discussed in this section poses significant challenges and will likely be a non-trivial 

task. 

References 

AEC (Atomic Energy Commission), 1969, Report on Investigation of Fire Building 776-777 

Rocky Flats Plant, Golden, Colorado, May 11, 1969, Volume 1, U.S. Atomic Energy 

Commission, August 1969. 

Lagerquist, C.R., 1975, Memorandum from C.R. Lagerquist to E.A. Putzier, Background 

Subtraction on TLD Readings, Golden, Colorado, October 29, 1975. 

Lagerquist, C.R., 1976, Memorandum from C.R. Lagerquist to R.O. Williams, Significance of 

Low Level External Doses, Golden, Colorado, December 22, 1976. 

Langsted, J., 2004, Technical Basis Document for Rocky Flats Plant – Occupational External 

Dosimetry, ORAUT-TKBS-0011-6, Oak Ridge Associated Universities Team, Oak Ridge, 

Tennessee. 

Mann, J.R.,1969a, Status Report – Dosimetry – February, 1969, The Dow Chemical Company, 

Rocky Flats Division, Golden, Colorado, March 7, 1969, 

Mann, J.R., 1969b, Status Report – Dosimetry – April, 1969, The Dow Chemical Company, 

Rocky Flats Division, Golden, Colorado, May 7, 1969. 

Mann, J.R., 1969c, Status Report – Dosimetry – March, 1969, The Dow Chemical Company, 

Rocky Flats Division, Golden, Colorado, April 8, 1969. 

Mann, J.R., 1969d, Memorandum from J.R. Mann to Dosimetry Technicians, Film Badge 

Processing for Non-Pu Areas, The Dow Chemical Company, Rocky Flats Division, Golden, 

Colorado, March 13, 1969. 

NIOSH 2006x, RRFP Coworker Data Stat (NDRP included, HIS20 Data), Office of 

Compensation and Analysis, Cincinnati, Ohio. 

NIOSH, 2006x2, Summary of Investigations Regarding 1969 Data Gap, Office of Compensation 

and Analysis, Cincinnati, Ohio. 

Putzier, E.A., The Past 30 Years at Rocky Flats, Rockwell International, Golden, Colorado, 

November 1982. 

Vogel, R.M., 1969, Memorandum from R.M. Vogel to J.R. Mann, Non-Plutonium Area Film 

Badge Recommendation, The Dow Chemical Company, Rocky Flats Division, Golden, 

Colorado, March 3, 1969.

RFETS SEC Petition Review 15 Working Draft – February 15, 2007 
Table X-2. A Comparison of Data Sources for Claimants with 1969 Gaps. 

ID Jobtitle Bldg Report 1969 

Occupational 

Dose 

Dosimetry 

History by 

Individual 

1969 

HPERER 

1968 

HPERER 

1969 

HPERER 

1970 

HIS_20 

1969 

In V

5/11/

12/3

1 Inspector Null N/A Skin Only Null 14 0 2 Maintenance Electrician

No 51-79 

datasheet N/A 362 Null 0 0 

3 Mechnical Maintenance

No 51-79 

datasheet 0 14 Null 0 0 

4 Accountant Null 0 Null Null 0 0 5 Cost Accountant Null 0 Null 0 0 6 Mechanical Development Null 0 92 Null 23 0 7 Truck & Labor Null 0 35 Null 0 0 8 Civil Engineer Null 0 10 Null 0 0 9 Tool Engineering Null 0 Skin Only Null 0 0 

10 QA Inspector Null N/A 7 Null 0 0 11 Sr. Material Specialist Null 0 24 Null 26 0 12 QC Inspector Null N/A 171 Null 0 0 13 Production Eng Null N/A 38 Null 150 0 14 Facility Engineer

No 51-79 

datasheet N/A 137 Null 19 0 

15 Sr. Fire Protection Engineer Null 0 14 Null 0 0 16 R & D Engineer Null N/A 187 Null 144 0 17 Sr. Research Mgr. Null N/A Skin Only Null 188 0 18 Inspector Null N/A 8 Null 55 0 19 Fireman Null 0 23 Null 77 0 

RFETS SEC Petition Review 16 Working 
Table X-4: Non-plutonium Area Worker Dose for Fourth Quarter 1968 and First Quarter 196

ID Jobtitle

Work 

Location 

Dosimetry Log 

Gamma Dose 

Q4 1968 

Dosimetry 

Log Beta 

Dose Q4 68 

HPERER 

Deep 

Dose Q4 

1968 

HPERER 

Shallow 

Dose Q4 

1968 

HPERER 

Deep Dose 

1969 

HPERER 

Shallow 

Dose1969 

101 Electrician 33 95 33 128 Null Null 102 X-Process Opr 142 1240 142 1382 Null Null 103 Journeyman Machinist 33 1880 33 1913 Null Null 104 Journeyman Machinist 96 300 96 551 Null Null 105 Tool Grinder 16 95 16 111 Null Null 106 Journeyman Machinist 16 95 16 111 Null Null 107 Journeyman Machinist 16 125 16 141 Null Null 108 Journeyman Machinist 42 80 42 122 Null Null 109 Inspector 42 80 42 122 Null Null 110 Journeyman Machinist 33 50 33 83 Null Null 111 Mtce Machinist 42 80 48 62 Null Null 112 Journeyman Machinist 16 95 16 111 Null Null 113 

Sr. Industry Photographer 74 77 75 77 Null Null 

114 

Advanced Facility Engineer 137 139 137 139 Null Null 

115 Vehicle Driver 164 173 167 173 Null Null 116 Designer I 89 98 92 98 Null Null 117 Equipment Opr 222 632 222 632 Null Null 118 Equipment Opr 152 832 152 832 Null Null 

RFETS SEC Petition Review 17 Working 
Figure 4-1: Example Logbook Sheet with Zeros Followed by Arrowing Down. Fourth Quarter 

1968 Dosimetry Logsheet for Individuals on a Quarterly Cycle from Building 111. 

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Figure 4-2: Fourth Quarter 1968 Dosimetry Logsheet for Individuals on a Quarterly Cycle from 

Building 111. 

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Figure 4-3: First Quarter 1969 Dosimetry Logsheet for Individuals on a Quarterly Cycle from 

Building 111. 

RFETS SEC Petition Review 20 Working Draft – February 15, 2007