Review of Rocky Flats Plant 

Technical Basis Documents: 

Revisions and Issues

Advisory Board on Radiation & Worker Health

December 8, 2022, Meeting

David Kotelchuck, Chair, Rocky Flats Plant Work Group

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Report on RFP WG meeting: Oct.4, 2022

Members of the Rocky Flats Plant (RFP) Work Group (WG):

• R. William Field

• David Kotelchuck, Chair

• Loretta Valerio

• Paul Ziemer

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R. William Field, PhD, MS (1954 – 2022)

It is with great sadness that the Rocky Flats Work Group 

of the Advisory Board on Radiation and Worker Health 

observes the passing of Board and WG member 

Bill Field. We acknowledge his many important 

contributions over the years to this WG and to the 

Board.

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Background

• At its 3/23/2017 meeting, the Advisory Board decided it had 

sufficient information available to do individual dose 

reconstructions with sufficient accuracy for RFP claimants 

exposed after 1/1/1984. Thus, the Board decided not to 

extend the status of Special Exposure Cohort (SEC) 192 

beyond 12/31/1984.

• At the 10/4/2022 meeting of the RFP WG, we considered 

updates and changes to the technical basis documents 

(TBDs) that make up the Rocky Flats site profile.

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Revisions to Rocky Flats Plant TBDs

Five RFP TBDs have been revised as of January 2021:

• Site description (TBD-2): ORAUT-TKBS-0011-2, rev. 02, 2020

• Occupational medical dose (TBD-3): ORAUT-TKBS-0011-3, rev. 03, 

2019

• Occupational environmental dose (TBD-4): ORAUT-TKBS-0011-4, 

rev. 03, 2020

• Occupational internal dose (TBD-5): ORAUT-TKBS-0011-5, rev. 04, 

2020

• Occupational external dose (TBD-6): ORAUT-TKBS-0011-6, 

rev. 03, 2019

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SC&A reviewed five revised RFP TBDs

• SC&A reviewed all five RFP TBDs that had been revised as of 

January 2021 

• SC&A’s review was to determine if previous issues identified by 

SC&A’s original 2005 site profile review had been resolved by the 

revised TBDs, the RFP WG proceedings, and NIOSH

• SC&A also performed a general review of the five revised TBDs

• SC&A provided the RFP WG with a review report on Dec. 3, 2021

• NIOSH issued a response paper to SC&A’s December 2021 review 

on July 22, 2022

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SC&A and RFP Work Group discussion

• SC&A presented its review results to the RFP WG on 

October 4, 2022

• The RFP WG, NIOSH, and SC&A discussed the results 

of SC&A’s review and the current status of the 

previous findings and any new findings or new issues 

that were presented

• The following slides outline the review of the 

findings/issues and their current status

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SC&A’s issues for TBD-2, “Site Description,” 

resolved by revised TBDs

• SC&A finds that all previous TBD-2 issues have been addressed in rev. 02.

• Rev. 02 is more comprehensive in scope and depth and includes more 

details on site closure and decommissioning (SC&A’s observation 1), as 

well as information about specific operations and their operational 

timelines, including recycled uranium and uranium-233 (SC&A’s observation 2).

• SC&A recommended closure of finding 8 (inadequate information about 

recycled uranium), based on updated treatment of the issue in the 

internal dose TBD-5. The RFP WG discussed and closed this finding.

• SC&A recommends that TBD-2 be revised to be consistent with TBD-5:

• NIOSH plans to address this recommendation in future TBD revisions.

• SC&A concurs with NIOSH’s response and plans to review such future 

revisions.

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SC&A’s issues for TBD-3, “Occupational 

Medical Dose,” resolved by TBD revision

• TBD-3 finding 5 was about radiation exposure from occupationally necessitated medical x-rays.

• SC&A finds all remaining issues for finding 5 have been 

addressed and resolved in rev. 03 of TBD-3 and recommended 

closure. The RFP WG discussed and closed this finding.

• General review of rev. 03 did not identify any new findings.

• Observations: SC&A identified some incorrect tables listed on 

page 2 of the revised TBD-3:

• NIOSH plans to address these errors in future TBD revisions.

• SC&A concurs with NIOSH’s response and plans to review such future 

revisions.

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SC&A’s finding 9 for TBD-4, “Environmental 

Dose,” resolved by TBD revision

• TBD-4 finding 9 was about inadequacies in addressing potential environmental exposure from routine and ambient airborne 

releases and resuspension of contaminated soil.

• SC&A finds that rev. 03 of TBD-4 resolves finding 9:

• NIOSH has provided better justification of its basis in available site 

monitoring data.

• NIOSH has added more specific information and guidance about the 

contribution of resuspension of soil contaminants for occupational 

environmental exposures.

• SC&A recommended closure of this finding.

• The RFP WG discussed and closed this and other TBD-4 issues.

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SC&A’s findings 1 and 2 for TBD-5, “Occupational 

Internal Dose,” resolved by TBD revision

Finding 1

• TBD-5 finding 1 was that NIOSH’s 

suggested use of urine bioassay 

minimum detectable amount 

(MDA) values appears low

• SC&A finds that TBD-5 rev. 03 

resolves this issue and 

recommended closure 

• The RFP WG discussed and closed 

this issue

Finding 2

• TBD-5 finding 2 was that the TBD 

lacks definitive direction in some 

instances

• SC&A finds that TBD-5 rev. 03 

resolves this issue and 

recommended closure

• The RFP WG discussed and closed 

this issue

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SC&A’s finding 7 for TBD-5, resolved 

• TBD-5 finding 7 was that TBD-5 should include recommendations for 

ingestion intakes or direct reference to the appropriate ingestion-intake- related document.

• NIOSH response:

• TBDs are designed to contain site-specific guidance. ORAUT-OTIB-0060, 

“Internal Dose Reconstruction,” provides guidance in this area.

• There is no site-specific scenario identified in this finding that would warrant the TBD to provide site-specific guidance. Therefore, no changes to TBD-5 are 

recommended.

• SC&A accepts NIOSH’s clarification and recommended closure of TBD-5 

finding 7.

• The RFP WG discussed and closed this issue.

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SC&A TBD-5 observation about MDA units

• SC&A finds that table B-11, page 104, lacks units for the MDA 

values for Am-241; it appears that it should specify the unit 

of nanocuries

• NIOSH plans to edit TBD-5 to add units for MDA values 

• SC&A concurs with NIOSH’s response and will review the 

revised TBD-5 when available

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SC&A’s finding 3 for TBD-6, “Occupational 

External Dose,” resolved by TBD revision

• TBD-6 finding 3 was concerned with the interpretation of 

NTA film data for workers who were not included in the 

Neutron Dose Reconstruction Project

• Rev. 03 of TBD-6 addresses this finding by use of neutron-tophoton ratios, coupled with use of available coexposure data

• SC&A recommended closure of this finding

• The RFP WG discussed and closed this finding

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SC&A’s finding 4 for TBD-6 resolved by 

TBD revision

• TBD-6 finding 4 was concerned with treatment of personal 

dosimeter placement and angular dependence

• Rev. 03 of TBD-6 addresses this finding by analysis of angular 

dependence of the monitoring devices

• SC&A recommended closure of this finding

• The RFP WG discussed and closed this issue

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SC&A’s finding 10 for TBD-6 resolved by 

TBD revision

• TBD-6 finding 10 was concerned with hand and wrist doses

• Rev. 03 of TBD-6 addresses these extremity doses

• SC&A recommended closure of this finding

• The RFP WG discussed and closed this finding

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SC&A’s finding 11 for TBD-6 resolved by 

TBD revision

• TBD-6 finding 11 was concerned with the potentially 

significant doses from industrial x-ray and neutron 

generators used for research and development and 

nondestructive work

• Rev. 03 of TBD-6 addresses these issues

• SC&A recommended closure of this finding

• The RFP WG discussed and closed this finding

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SC&A observation on neutron dose factors in 

TBD-6

• SC&A observes that NIOSH needs to clarify the reason for 

the change in neutron dose multiplier factors listed in 

table 6-16 of TBD-6 rev. 03 compared to table 6-14 of rev. 00

• NIOSH responded that these multiplier factors were updated 

based on guidance in ORAUT-OTIB-0055 (2006), which was 

issued after TBD-6 rev. 00 (2004)

• SC&A concurs with NIOSH’s response and recommended 

closure

• The RFP WG discussed and closed this issue

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SC&A observation on neutron LOD values in 

TBD-6

• SC&A observes that the reason for recommending a limit of 

detection (LOD) value of 226 millirem (mrem) in table 6-18 

and table 6-19 needs clarification

• NIOSH will correct the LOD value for 1962 and 1963 in 

table 6-18 in future revisions to TBD-6

• SC&A concurs with NIOSH’s response and will review future 

revisions

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Conclusions: RFP WG report

• All differences between SC&A review findings and 

NIOSH responses resolved & approved by the RFP WG

• All SC&A observations discussed and NIOSH 

differences resolved and approved by the RFP WG 

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Questions?

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