05/06/2003 15:10 FAX 303 966 4317 USWA _LU_8031 Boos

DOE RADIOLOGICAL CONTROL MANUAL dune, 1992

Radiological Health Support Operations Chapter 5

§35 Half-Face Respirators

The current revision of 10 CFR Part 20, which is to take effect January 1,
1994, states that half-face respirators are " not satisfactory for use where
it might be possible (e.g., if an accident or emergency were to occur) for the
ambient airborne concentrations to reach instantaneous values greater than 10
times the...{DAC values]." “This type of respirator is not suitable for
protection against plutonium or other high-toxicity materials."

1. Half-face respirators shall not be used on a routine basis as a
precautionary measure for protecting workers from potential airborne
radioactive materials. Half-face respirators are undesirable because
their seal with the face is more likely to fail than with full-face
respirators, particularly during heavy work. As a result, their
permitted protection factor is low.

2. The use of half-face respirators is not prohibited in situations where
intakes of radioactive material will be low, such as a few mrem, and
where industrial and safety considerations warrant, such as during the

operation of heavy equipment.

3. A few DOE facilities use half-face respirators for emergency evacuation
purposes. This practice is discouraged and shall not be implemented

where not in-place.



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USWA LU 8031 @oo4

PAGE 2

NIOSH SUMMARY OF FINDINGS. ROCKY FLATS

Glossary of Terms”

Report Findings

‘Cont. :
. 1. Some remediation workers who have worked at DOE sites cannot be

identified... .
Complete rosters of current and former remediation workers do not exist. Re-
construction of rosters from multiple data sources at the Sites is labor i intensive

Deactivation: ‘The pro-
‘| cess Ofiplacing a for-

merly active processing

facility in a safe and sta- and may exclude s some groups of workers.

ble condition until it can .

be decommissioned or 2. Accurate and complete exposure, work history, and medical records

dismantled. data are not available for this population.
Although radiation exposure records appear to be complete, decentralized re-
sponsibility for chemical exposure assessment and other records has led to gaps

Further NIOSH | in exposure, work history, and medical data.
Information:

3. Individual workers cannot consistently be linked to their exposure and
medical data.

The storage of data and records in hard copy format, on incompatible software
platforms, and on media produced by now obsolete hardware has diminished
the ability to identify workers and link them with their work history, exposure,
and medical data. The failure to standardize data collection and archiving both
within and among DOE sites will hinder linkage of individuals to their data.

e  Foracopy of the final
summary report, exec-
tive summary, or indi-
vidual site-specific
reports, call:

1-800-356-4674

¢ Forasummary of 4. At the present time the necessary information to conduct epidemiologic,

NIOSH research in- exposure assessment, or hazard surveillance studies of remediation work-
volving Department | ers is not available.
of Energy workers, The absence of worker rosters, the difficulty of creating such rosters with cur-
visit online at: rently available data, gaps in work history, exposure, and medical data, and data
www.cdc.gov/niosh/ linkage problems limit the ability to conduct accurate and comprehensive stud-
oeindex.htm! ies of remediation workers.

This report contains recommendations that address each of these findings.

Important Announcements

For more information, please contact DOE site representative, Karen Lutz at (303) 966-4546. Copies of the
complete report, Evaluation of Data for DOE Site Remediation Workers and individual site-specific re-
Ports can be found in the DOE Reading Room at Front Range Community College, 3705 112th Avenue,
Westminster, Colorado, 80030, (303) 469-4435. Questions concerning this study should be directed to the
investigators at (513) 841-4400.

NIOSH/HERB Contact Point for further information...

National Institute for Occupational Safety and Health (NIOSH)
Division of Surveillance, Hazard Evaluations and Field Studies (DSHEFS)
Health-Related Energy Research Branch (HERB)

Phone: (513) 841-4400
Fax: (513) 841-4470

NIOSH-HERB MS R-44
4676 Columbia Parkway ~
Cincinnati, OH 45226



~~ Local 8034
P.O, Box 745370 -

05/06/2003 15:08 FAX 303, 88 rie

Arvada, CO 80006-5370.

Bulking TOON”
Rocky Flats, CO
XB) 9052708 FAX Gxt 900-4317

Fax

Tor N rool Frome Te by Viewten
Fae 51 5-US4~ Ti 2nS pages:

Phone: Date:

Re: : cc:

¢ Urgent ¢ For Review ¢ Please Comment + Please Reply ¢ Please Recycle

4 Comments:



05/06/2003 15:08 FAX 303 966 4317 USWA LU 8031 @oo2

CLARENCE BUCHHOLZ BILL JACKSON ANTHONY DEMAIORI JOHN W. BARTON RAY MALITO
PRESIDENT

FINANCIAL SECRETARY RECORDING SECRETARY

GOLDEN, COLORADO 80403
303-278-4557 FAX 303-278-1320

VICE PRESIDENT ‘TREASURER

United Steelworkers of America

ea
AS.

AFL-CIO-CLC ngeeeia OS
LOCAL UNION 8031 anos
4510 INDIANA STREET rc: MAILING ADDRESS:

May 6, 2003

NIOSH DOCKET OFFICE
Robert A. Taft Laboratories
M.S. C34

4676 Columbia Parkway
Cincinnati, OH 45226

To: Docket Officer vant . mM teas *

ae Gh i) WEL IP ge
These comments are subsite on'Behalf-of the’ tice deehlayers of America, Local 8031,
it's retirees, surviving spalisés.! vane the ove {000 erhployés, who have worked at the Rocky

Flats site since the plants; 'inbéptio’ as aifes )the’ gee Procedure for designating
classes of employees;.as? somone ii dé

ySpeui (> the Energy Employees
Occupational Iliness in| h, the Federal Register on

March 7, 2003.

disclosure of supplying

Both NIOSH in its Jarfat ry;00'
dmit they are unable to

inadequate Personal Brot ctive, E ‘
provide documentation'fgk 8 jose fecons

auhiis
Because of the daily h aida pcerous
substandard personal proteaive equement toultipie ‘squrces. . radiation, and NIOSH’s own
admission in the NIOSH Su Bg. othih ofhih

e Accurate and complete expat histaty.' cidents, releases, spills, and medical
records data are not available for "is euiation

Individual workers cannot consistently be linked to their exposure and medical data.

e At the present time the necessary information to conduct epidemiologic exposure
assessment or hazard surveillance studies of remediation workers is not available.

Respectfully submitted,

Judy Yeater, Co-Chair
Hazardous & Toxic Materials Committee

JY:lb:Enclosures
opeiu #5/afl-cio

P.O, BOX 745370, ARVADA, CO 80006-5370
ROCKY FLATS OFFICE 303-966-2798 — 966-7042
FAX 303-966-4317


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USWA LU 8031

Rocky Flats Edition .

NIOSH Summary of
‘ Findings vos

eka . thy : t

January 2001

Glossary of Terns’

Remediation Workers:
Workers who are involved
in any of the following ac-
tivities at DOE sites: de-
contamination, decommis-
sioning, dismantlement, de-
activation, waste manage-
ment, and environmental
restoration.

Decontamination: The
removal of hazardous ma-
terial (typically radioactive
or chemical material) from
facilities, soils, or equip-
ment by washing, chemical
action, mechanical clean-
ing, or other techniques.

Decommissioning: The

_ Process of removing a fa-
cility from operation, fol-
lowed by decontamination,
entombment, dismantle-
ment, or conversion to an-
other use.

Dismantlement: The dis-
assembly or demolition and
removal of any structure,
system, or component after
decommissioning and the
satisfactory interim or long-
term disposal of the residue
from all, or portions of, the
facility.

ca
(¥

‘for DOE Site Remediation Workers.

NIOSH Assessment of Information Needed for the Evalua-
tion of the Health Effects Due to Occupational Exposures

Investigators: Sharon R. Silver, M.A., Cynthia F. Robinson, Ph.D.,
Greg Kinnes, M.S., Tim Taulbee, M.S., Steve Ahrenholz, Ph.D.

Sites Included in the Assessment: Fernald, Mound, Rocky Flats, Savannah River
Site, Hanford, Oak Ridge, and Idaho National Engineering and Environmental
Laboratory.

Purpose: This report summarizes the findings of two NIOSH projects which as-
sessed whether records currently collected by DOE sites allow accurate identifica-
tion of remediation workers and their exposure, work history, and medical informa-
tion. This information is needed in order to evaluate any relationships between oc-
cupational exposures and health effects workers may experience.

Information Needed to Evaluate Health Effects: To conduct studies that can
adequately evaluate the health effects of occupational exposures of current and fu-
ture remediation workers, the following information is required:

1. Comprehensive worker rosters (lists) identifying all remediaton workers;

2. Adequate exposure, work history, and medical information for all remediation
workers; and

3. Links which match individual workers with their exposure, work history and
medical information.

How This NIOSH Assessment Was Done: The assessment included two recent
National Institute for Occupational Safety and Health (NIOSH) projects, the Expo-
sure Assessment Feasibility Study (EAFS) and the Integrated Health, Work History,
and Exposure Database for DOE Site Remediation Workers. These two projects
assessed the availability of information about remediation workers and their activi-
ties to address the following questions:

1. Can remediation workers be identified?
2. Are adequate exposure, work history, and medical data available for remediation
workers?

3. Can individual workers be linked to their exposure and medical data?

4. With current knowledge and understanding, as described in this report, can epi-
demiologic, exposure assessment, or hazard surveillance studies of remediation
workers and the technologies they employ be conducted now or in the
foreseeable future?