TRITIUM RELEASE 4/1989

[8 DEPARTMENT OF JUBTICK



DNFSB CONCERNS WITH ROCKY
FLATS -1990

“Examination of records of tests and
instruments monitoring Limiting Con
Operating Safety Requirements.”

, Federal Register Vol.55, No. 91 Thursday, May 10, 1990

calibration of safety systems and other
ditions of Operations or that satisfy

ites /default/ files /Board

ndf
cf

44.2 The condition and operability of vital safety systems, neludng safety
fety-related utility systems, are con irmed.

related process systems and sa

H.2.1 Instruments, indicators, and alarms that monitor limiting conditions
of operation or that satisfy operational Fi requirements have been
demonstrated to be capable of performing their intended functions in the

required manner.”
»OAct

85 pdf NFSB memo,

>

11/29/90, page 14


of records of tests and calibration of safety systems and other instruments manitoring Limiting
Conditions of Operations or that satisfy Operating Safety Requirements.”

Federal Register Vol.55, No. 91 Thursday, May 10, 1990

3/Recommendations/rec_1

990-4 _185.pdf

© “H.2 The condition and operability of vital safety systems, including safety related
process systems and safety-related utility systems, are confirmed.

H.2.1 instruments, indicators, and alarms that monitor limiting conditions of operation
or that satisfy operational safety requirements have been demonstrated to be capable of
performing their intended functions in the required manner.“

http://www.dnfsb.gov/sites/default/files/Board%20Activities/Recommendations/Imple
mentation%20Plans/ip_rec-id_185.pdf ONFSB memo, 11/29/90, page 14

The next two documents show that some of the same issues still existed 3 and 4 years later:

Defense Nuclear Facilities Safety Board (DNFSB) memo, dated 12/1/93
ht www.hss.doe.gov/deprep/1993-2/tr93d0ib.pdf

Page 1

b The staff noted that a potential existed for workers to be exposed to radiation without being
monitored in accordance with the Radiological Contre! Manual (RCM) and DOE Order

5480.11. tn discussions with Building 771 personnel, it was noted that the

Thermofuminescent Dosimeter (TLD) badge storage rack was being evaiuated ta determine

the amount of radiation the dosimeters were exposed to while hanging on the rack. This

evaluation was being accomplished os a result of RFP personnel noting that two TLDs thathung
on the rock for six manths had received approximately 300 mrem. The ONFSB staffquestioned
whether any unmonitored workers had spent a significant amount of the workday in the area.
RFP personne! nated that a guard station was adjacent to the area, and that the guards were
not required to wear dosimeters on a routine basis. The radiation level in the guard area was not
known at the time of the review, and was to be determined. If the radiation level in the guard’s
post is similar to that at the TLD storage board, exposure of guards to ionizing radiation may
exceed the 100 mrem per year limit for those who are not monitored.

And on page 8 of the same ONFSB memo:

Workplace Air Monitoring - RFP personnel described the Work Place Air Monitoring
Program at the RFP as an integrated pragram consisting of seven elements ranging from
Selected Alpha Air Monitors (SAAM) to bioassay. Air monitoring in the workplace at RFP
is not in compliance with the requirements of the RCM. Specifically, the RCM Article 555,


1996 - STOP RECORD
DESTRUCTION

April 25, 1996 Memo from Mark N. Silverman, Rocky Flats Field Office Manager
To All Rocky Flats Environmental Technology Site Employees
Subject: Moratorium on the Destruction of Records

“Effective Immediately, | am issuing a moratorium on the destruction of all
records at the Rocky Flats Environmental Technology Site, including the records
located at the Denver Federal Record Center. Until further notice, no
destruction will take place of any records unless approved by the RFFO Chief
Counsel...Virtually all recorded information in the custody of the Government
(including information held by contractors which is considered by contract to be
Government information) regardless of its media is considered “Government
records.”


GAO 1989 REPORT ON ROCKY
FLATS

» In January 1989, DOE issued a comprehensive site-wide TSA
appraisal of Rocky Flats. Amon other things, the appraisal
evaluated the effectiveness an timeliness of actions taken in
response to previous TSAs. Overall, the appraisal found some
improvements in the safety progr: but indicated that more
still needs to be done. Of the 230 recommendations and/or
concerns in previous TSAs1, 39 were closed because corrective
action had been fully implemented. Further, the TSAs recognized
that increased emphasis on ES&H has been initiated by Rockwell.
However, the TSA also identified 32 new concerns including (1)
the lack of adequate training programs for fissile materials
handlers, (2) noncompliance with electrical safety standards
and/or codes, and (3) the lack of adequate measurements and
documentation on extremity doses for certain workers.

>.pal


l understand that three highly qualified professionals have, independent of each other, have raised
issues concerning IREP, You will hear from one tonight during the public comment period, | respectfully
request that the Board and OCAS address these concerns.

'd like to leave you with ane thought before | read the petitioner’s short comment. While this petition
is only 2 years old, these Rocky Flats issues have been around for 8 years. | have been involved in the
sick worker issues for 18 years. | want to “retire” in two years. i like to see this SEC petition decided in
favor of the Rocky Flats claimants before then.


different calibration techniques in different buildings and not testing the instruments with
appropriate radiation sources.”

On the next page,

“Air monitoring radiation at the plant needs to be upgraded. The TSAs identified a number of
problems with the plant’s air monitors, the need to study air flows, insufficient ventilation,

and improper use or placement of air monitors.” ;
|

http://www.gao.gov/assets/80/77207.pdF '
From the Government Accountability Office report a year later, page 15

htto://www.gao.gov/assets/220/211753. pdf 1

In January 1989, DOE issued a comprehensive site-wide TSA appraisal of Rocky Flats. Among
other things, the appraisal evaluated the effectiveness and timeliness of actions taken in
response to previous TSAS. Overall, the appraisal found some improvements in the safety
programs but indicated that more stil needs to be done. Of the 230 recommendations and/or
concerns in previous TSAS1, 39 were closed because corrective action had been fully
implemented. Further, the TSAs recognized that increased emphasis on ES&H has been initiated
by Rockwell, However, the TSA alse identified 32 new concerns including {1} the lack of
adequate training programs for fissile materials handters, {2} noncompliance with electrical
safety standards and/or codes, and (3) the lack of adequate measurements and
documentation on extremity doses for certain workers.

For over 8 years the Rocky Flats workers have attested to these practices. Is this enough to prove they
were telling the truth about the work place canditians? Is this enough ta convince the Board that the
records NIOSH is using to reconstruct dose are to be questioned? Yes, | understand that these
documents do not directly affirm that the personal bioassay testing was flawed. | haven't read each
DNFSB report nor have | read every GAO report, nor can | gain access to the three volumes of the Tiger
Team report not related to the environmental concerns, But let's be logical here. If the Tiger Team
presumably found fault with the radiological protection; if the ONFSB consistently called upon Rocky
Flats to improve the protection and monitoring; if GAO identified problems with protecting the workers
of the Rocky Flats plant wouldn’t it stand to reason that the lab in Building 123 was also deficient in their
processing of worker bioassay specimens, a5 asserted by the Interviewee?

Let’s move on to the tritium follow up white paper.

My understanding about tritium is like the element itself. Information seeps into my brain and just as
quickly it seeps out. Some knowledge remains though, so a good portion of this part of the presentation
will be observations and/or questions for the Board, NIOSH and SC&A to consider,

This is a stide from the petitioners’ presentation last September.

Notes to Jim:


Airborne Radioactivity Monitoring, paragraph 5 requires that Continuous Air Monitors should
be capable of measuring one {1) Derived Air Concentration {(DAC) when averaged aver eight
(8) hours (8 DAC-hours) under laboratory conditions. SAAMS used at the RFP were stated
by RFP personnel to have a sensitivity of approximately 42 DAC-hours. improvements are
planned and are expected to increase the SAAM sensitivity to approximately 8.5 DAC-hours.
In support of this improvement effort, @ pilot program has been completed in Building 707
Module J and Building 371. in addition to the sensitivity problem, SAAMS are no longer in
production and the RFP reties on cannibalizing or replacing units from approximately 150
spare units held at the Plant. A Capital Project Air Monitoring tmprovement Program is in
place to support the air monitoring requirements for the future Decontamination and
Decommissioning (D&D) work at the RFP. ONFSB staff review of the RFP RCM
implementation Ptan identified that EG&G has not included the upgrade to meet the
requirement in their implementation Plan, but has taken an exception to RCM Article 555.

And, again, in an August 24, 1994 DNFSB memo, captured by NIOSH on 11/18/12
http://eecap.org/PDF Files/Colorado/Rocky Flats/00192_petition-review pdf

“Equipment used for monitoring air for radioactivity does not meet the Manual’s sensitivity
requirements, but short and long term improvement efforts are in progress.”

So here we have four documents from the DNFSB which show there were problems with radiological
protection.

As noted in NIOSH’s white paper, DOE was so concerned they sent their own investigative teams to take
a look at the problems after the FBI/EPA raid. | would hazard @ guess that the concerns mentioned in
the DNFSB memos documents were the result of the DOE Tiger Team investigation and subsequent
reports.

Yes, the raid was initiated because of environmental crimes, but the Tiger Teams loak at the whale
plant. The white paper says the SRDB contains, “A report from a OOE Environmental Special Assessment
Team (one of four assessment teams that also included Management and Operations, Safety, and
Legal Matters) (SRDS 21359).” Does NIOSH have ail four assessment team reports or just the
environmental one? If they do have all four reports, did they review them to determine whether the
Tiger Teams found similar problems with the personal bioassay lab procedures? If all four reports are
not avaiable to DCAS, why not? They wauldn’t be part of the documents sealed by the court, because
those reports occurred after the raid. But if OCAS cannot obtain all three reports, how can they
emphatically assert that there were no problems with the worker bioassay laboratory?

It is interesting to note that even the GAO identified worker protection issues by reviewing DOE’s
Technical Safety Appraisals (TSA). And this was prior to the FBI raid, For example, the October 1988
report titled, “Summary of Major Problems at DOE's Rocky Flats Plant” states,

“The TSAs found that procedures for calibrating radiation monitoring instruments were weak
and poorly documented. The accuracy of such instruments in important to ensure that workers
and the public are not exposed to unnecessary levels of radiation. Problems included using


Tritium stripping Bldg. 444 in
1987

From: lopez, Theresa- - MFG [mailto:Theresa,Lopez@mfgenv,com]

Sent: Tuesday, March 21, 2006 2:26 PM

To: rmeyer Jim Langstedi Little, Craig -- MFG

Subject: New table 8-2

Importance: High

| have significantly revised table 8-2 in response to Jim's concerns and have found a new source of info on
the internet

that may be a better source for Karin to use if she would like to expand this table. From www.rfets.gov,
choose history

and go to the HAER site. They have pictures of the buidings and a good history (click on “building history”
under the

building number). At this point, | think everyone has sent in comments so here is the new table, until you
review it again!

Theresa «Table 8-2 2006Mar21 update TKL.doc»

Notes to Jim

They did not have any information of tritium stripping on building 444 except that it began in 1987, sol am
not sure where we can get more information; | have found no references to building 664 anywhere - any
ideas? | have nol added it to the table.

» — http://www.eecap.org/ PDF_Files/Colorado/Rocky_Flats/M iscellaneous/2006,_Oct._4_Rocky_Flats_ER_e
mail_between_Jessen,_Masterson. pdf


From Rocky Flats Field Office Manager

To All Rocky Flats Environmental Technology Site Employees
Subject: Moratorium on the Destruction of Records

“Effective immediately, {am issuing a moratorium on the destruction of aif records at the
Rocky Flats Environmental Technolagy Site, including the records located at the Denver
Federal Record Center. Until further notice, no destruction will take place of any records
unless approved by the RFFO Chief Counsel...Virtuaily all recorded information in the custody
of the Government {including information held by contractors which is considered by contract
to be Government information) regardless of its media is considered “Government records.”

BCAS still has three white papers ta produce, Thorium strikes, other thorium work and neptunium. I'd
like to offer a few observations on the thorium issue. Concerning the thorium strikes, after the thorium
was removed from the U-233 what happened to it? Was it processed and machined at Rocky? Was it
then shipped offsite? If so, to which facility? What was the process? Which building or buildings was
involved. Was it treated as waste and burned or buried. I'm hoping that the paper on “Other thorium
work” will explain that process.

| co-petitioner far the Dow Madison site, and | are grateful to the RF Chair for ensuring
that DCAS ‘will address the anonymous tip | received that the rnagnesium thorium alloy plates were used
to shield the semis. This process took place in Building 440, MOD Center. While there is a FOIA out for
this information, it might be quicker for DCAS and SC&A to obtain the information. 1 thank Mark Griffon,
Chair of the RF Work Group for insisting that this issue be addressed in the DCAS white paper on “Other
Thorium Work”.

hope | have enough time to mention a few last concerns brought to me by interested parties regarding
the dose reconstruction for Rocky Flats. I'm sure they would appreciate a written response to these
concerns.

IOCFR 20.1703 states that radiation exposure to ANY ORGAN except for the lens of the eye must
not exceed 50 rems (0.5 sv} per year. The very nature of the glove box work at RF insured that
the head of ony employee who worked in glove boxes would receive the highest dose of any part
of the body.

Until sometime in the 1990's radiation exposure to the head was never tracked at Racky Flats, so
they had no idea if they were in compliance for the brain {an organ of the body), or the lens of
the eye.


Diana, Sherri A. (CDC/NIOSH/EIO) (CTR)

From: Terrie Barrie <

Sent: Thursday, July 18, 2013 10:09PM

To: NIOSH Docket Office (CDC)

Subject: Submission to NIOSH docket

Attachments: Rocky Flats ID oral presenation.docx; Saunders ID presentation. deex; ROCKY FLATS SEC.

PETITIGN 00192 ID presentation. pptx

To Whom It May Concern:

Kindly post the attached three documents to the Rocky Flats page
+hitp:/www.cde.gov/niosh/ocas/rocky html#see

This information was provided during the Advisory Board on Radiation and Workers Health mecting on July
16, 2013.

If you have any question, please do not hesitate to contact me.

Sincerely,

Terrie Barrie

Rocky Flats SEC 00192 Co-petitioner

Founding Member of the Alliance of Nuclear Worker Advocacy Groups

-
=
Qe

ANWAG


Effect of delay on testing bioassay
samples

EPA Interviewee
“Nasal wipes, fecal, urine and tissue samples were frequently allowed to sit in
the lab for a week or two prior to analysis.”

NIOSH’s Response

“From a radiological perspective, there is no scientific basis for concluding that
sample counting performed weeks after collection would compromise the results
for the target radionuclides. The half- lives of these target radionuclides are too
long for the intervening time period to impact results.”

NCRP Report No. 87 page 31

“All biological samples are subject to deterioration by bacteriological action that
may interfere with subsequent analysis. Prompt analysis following collection is
the preferred method of avoiding these complications. When samples must be
kept longer than a day, they should be refrigerated, acidified to minimize
precipitation, or have a preservative added to prevent bacterial growth”


ROCKY FLATS SEC
PETITION 00192

Petitioners’ Response to DCAS White Papers
on Falsification and Tritium Follow Up



They did not have any information of tritium stripping on building 444 except that it began in
1987, sot am not sure where we can get more information; | have found no references ta
building 664 anywhere - any ideas? t Have not added it ta the table.

http://www.eecap.org/PDF_Files/Colarado/Rocky_Flats/Miscellaneaus/2006,_Oct._4_Rocky_
Flats_ER_email_between_Jessen,_Masterson.pdf

As far as | can ascertain, DCAS did not address this in their white paper. Apparently there is
documentation that tritium stripping was performed on Building 444 in 1987. Did DCAS research this
further? Did NIOSH choose the 1974 incident because they could not find any more information on the
tritium stripping on 444? Did they choose the 1974 incident because they reviewed the issue with
Building 444 and found that to be less exposure than the 1974 incident? Did this DCAS email mean
“tritium stripping in building 444 except that it began in 1987.”? More unanswered questions that will
affect the SEC petition and one that DCAS needs to respond to.

You should also note on this slide the document seized during the raid refers to a tritium release from
Building 776 in April of 1989. Was DCAS aware of this release? If so, did they determine the release was
less the 1974 or even the 1973 exposure.

During last week’s work group teleconference, Dr. Arjun Mahkijani of SC&A asked NIOSH if metal tritides
was present at Rocky Flats. NIOSH replied that they did not find any evidence of that. My understanding
is that a tritide, after reading the 2008 DOE Handbook “Tritium Handling and Safe Storage” is formed
when tritium gas or water forms a bond with a metal. (t is my understanding that, where there is
substantia! tritiated gas, it can form tritiated compounds with oils, solvents and even components of
hoods and gloveboxes. From the Work Group discussion, | gathered that at the very minimum the
bubblers or the hoods would become tritides. And what | gathered from talking with Rocky Flats
workers, those tritides would release contaminants on a continuous basis in the form of “out gassing”.
The petitioner and | would like a very simple tutorial from DCAS and SC&A on what a tritide is. This wilt
heip us with future discussions.

Many of the workers interviewed during the focus group and other interviews mentioned the fact that
tritium alarms went off frequently. | know that some of those accounts occurred after 1974, including
one from the petitioner, Did DCAS find any information on tritium alarm incidences and if so, did they
rule out that those alarms were caused by releases that were less than the 1974 exposure? And Special
Tritium Compounds — how does that weigh in when reconstructing tritium dose?

As | mentioned earlier, there are many Rocky Flats workers who work with the petition and | to educate
us in the areas we are not familiar with. One such worker informed me that tritides were indeed onsite.
£xperiments were done in Building 559, glovebox 4 by. _ ” using tritides.

And, of course, considering the documents | located regarding the monitoring insuffictencies at Rocky
Ftats, there are serious doubts in my mind that the records NIOSH is using to reconstruct dose are true
and accurate. In addition, | was provided with an Aptil 25, 1996 memo concerning the destruction of
records.


The former Mound worker interviewed by NIOSH offered his opinion that “it is a valid assumption that
Mound procedures woutd be representative of other DOE sites.” Did NIOSH investigate the validity of
this opinion, or just accept it because it fit nicely with their position?

I managed to easily find a 1985 document titled, “Current internal-Dosimetry Practices at U.S.
Department of Energy Facilities.” http://www.osti.gov/bridge/serviets/purl/5831506/5831506.pdf, The
suraimary states,

“The information gathered from the questionnaire responses ilfustrates the diversity of internal-
dosimetry practices ot DOE facilities...The differences include different frequencies in the use of
quality control samples, different minimum detection levels, different methods of recording
radionuclides, different amounts of data recorded in the permanent record, and apparent
differences in modeling the metabotism of radionuclides within the body.”

So, it cannot be assumed at all that Mound’s dosimetry procedures are representative of other DOE
sites.

Why would DCAS seek out a former Rocky Flats worker who started employment after the FBI raid for
his opinion of the bioassay program? What about the workers who made public comments and who
submitted sworn affidavits to the Board? What about the Focus Groups and classified interviewees?
Was there no one from these groups who could corroborate the problems with the lab identified in the
EPA interview?

Two documents were provided to NIOSH with the SEC petition 00192. Both show white out being
applied. Concrete proof, to me, that records were altered or falsified. Why will DCAS only believe the
workers or other experts that fit into their pre-determined position? We have tons of people telling
DCAS that records are missing, that they received a zero for a badge reading could the reason for all
these zero reading be that the lab was remiss in follawing scientific protocols? Yet these workers are not
believed. | supplied this EPA interview to bolster the workers’ testimony. It came from someone who
had direct knowledge of the lab’s practices and worked in the lab for an extended length of time. Itis
unbelievable that NIOSH would scoff at this information.

lam thankful that NIOSH will check with Legal on whether it will be possible to petition the court to
unseal the records seized during the FBI raid. | hope Legal agrees. ANWAG will be happy to submit a
brief supporting this proposed motion.

But | still don’t understand why DCAS is so insistent that there were no problems at Rocky Flats both
with regards to the bioassay program and with worker protection.

Besides the many workers who have come forward with their sworn testimony attesting to the issues, |
have discovered a few other documents which may confirm or at least support their statements that all
was not well at Rocky Flats.

The following documents identify some areas that were necessary for Rocky Flats management to
correct before the restart of the production facilities. Rocky Flats needed to ensure that: “Examination


DNFSB CONCERNS WITH ROCKY
FLATS - 1993

Defense Nuclear Facilities Safety Board (DNFSB) memo, dated 12/1 /93, Page 1

“The staff noted that a potential existed for workers to be exposed to radiation without being
monitored in accordance with the Radiological Control Manual (RCM) and DOE Order
Thermoluminescent Dosimeter (TLD) badge storage rack was being evaluated to determine

the amount of radiation the dosimeters were exposed to while hanging on the rack. This evaluation was
being accomplished as a result of RFP personnel noting that two TLDs that hung on the rack for six months
had received approximately 300 mrem. The DNFSB staff questioned whether any unmonitored workers had
spent a significant amount of the workday in the area. RFP personnel noted that a guard station was
adjacent to the area, and that the guards were not required to wear dosimeters on a routine basis. The
radiation level in the guard area was not known at the time of the review, and was to be determined. If the
radiation level in the guard’s post is similar to that at the TLD storage board, exposure of guards to ionizing
radiation may exceed the 100 mrem per year limit for those who are not monitored.”

And on page 8 of the same DNFSB memo:

“Workplace Air Monitoring - RFP personnel described the Work Place Air Monitoring
Program at the RFP as an integrated program consisting of seven elements ranging from
Selected Alpha Air Monitors (SAAM) to bioassay. Air monitoring in the workplace at RFP

is not in compliance with the requirements of the RCM.”


1988 GAO “SUMMARY OF MAJOR
PROBLEMS AT DOE’S ROCKY FLATS”

>

“The TSAs found that procedures for calibrating radiation
monitoring instruments were weak and poorly
documented. The accuracy of such instruments is
important to ensure that workers and the public are not
exposed to unnecessary levels of radiation. Problems
included using different calibration techniques in different
buildings and not testing the instruments with appropriate
radiation sources.”

“Air monitoring radiation at the plant needs to be
upgraded. The TSAs identified a number of problems with
the plant’s air monitors, the need to study air flows,
insufficient ventilation, and improper use or placement of
air monitors.”

http: //www.gao.gov/assets /80/77207.pdf


Good Afternoon,

Thank you for the opportunity to explain the petitioners’ opinion on DCAS’s white papers on data
falsification and/or data invalidation in Building 123 and the tritium follow-up. {also want to express my
heartfelt gratitude to the Rocky Flats workers and the advocates who have helped with this petition and
today’s presentation. | cannot express enough how much | appreciate your assistance.

| will first address the Falsification white paper.

Page 2, is an “allegation” that the fume hoods were inadequate. DCAS opines that there “could have .
been a chemical hazard issue.” | don’t know why DCAS bothered addressing this issue. The interviewee
affirmed that this was a chemical issue in his interview ~ “He and others reportedly complained to the
supervisor...about fumes from nitric acid, hydrochloric acid and ammonium hydroxide.” The
interviewee did not mention that radioactive materials were present. The interviewee’s concern was the
chemical exposure. In fact, the statement in the interview is, “[redacted] recalled taping a piece of pH
paper to the outside of the hoad and watching it turn bright red almost immediately, from the acid.”
Why did NiOSH bother? A fluff piece if | ever saw one.

The interviewee told the EPA and FBI that

“Nasal wipes, fecal, urine and tissue samples were frequently allowed to sit in the fab for a week
or two prior to analysis.“

NIOSH’s response to that assertion is

“From a radiological perspective, there is no scientific basis for concluding that sample counting
performed weeks after collection would compromise the results for the target radionuclides, The half-
lives of these target radionuclides are too long for the intervening time period to impact results.”

Really? Yes, NIOSH couldn't find bioassay procedures for Rocky Flats. ( find that very odd, especially
since their site expert and original author of the Rocky Flats Site Profile was the manager of the Health
Physics Lab. Couldn’t they have asked him for a copy? Fortunately, the LANL petitioner was generous
enough to share a section of his SEC petition with me, pages 56 and 57, which addresses this issue.

“The NCRP commented on collection of in vitro samples:

All biological samples are subject to deterioration by bacteriological action that
may interfere with subsequent analysis. Prompt analysis following collection is
the preferred method of avoiding these complications, When samples must be
kept longer than a day, they shoutd be refrigerated, acidified ta minimize
precipitation, or have a preservative added to prevent bacterial growth.

NCRP Report No, 87 page 31.”

Shouldn’‘t Health Physicists know that? And what about tritium bioassays? Tritium has a very short half-
life and depending on which paper you read, it is between 12 days and 12 years. If a sample that was
slated to check for tritium exposure sat on the shelf for a week or two, would the bioassay results be
accurate? Would there be any tritium left to test?


Why will DCAS only believe the workers or other experts that fit into their pre-determined position? We
have tons of peopte telling DCAS that records are missing, that they received a zero for a badge, that
instruments were recalibrated to show a background reading that was higher than what the worker's
badge read? Could the reason for all these zero readings be that the lab was remiss in following
scientific protocols? No one has believed these workers. We supplied this EPA interview to bolster the
workers’ testimony. It came fram someone who had direct knowledge of the lab’s practices and warked
in the lab for a number of years. It is unforgivable that NIOSH would dismiss this important information.

As noted in NIOSH’s white paper, DOE was so concerned about the raid that they sent their own
investigative teams to take a look at the problems at Rocky. | don’t think it would be a stretch of the

imagination that the issues mentioned in the DNFSB memos were the result of what the DOE Tiger Team
investigations found.

Yes, the raid happened because of environmental crimes, but the Tiger Teams look at the whole plant.
Does NIOSH have ali four assessment team reports or just the environmental one? If they do have all
four reports, did they review all of them to determine whether the Tiger Teams found similar problems
with the personal bioassay lab procedures? If so, what did they find? If they have the reports but didn’t
read them, why didn’t they? If all four reports are not available to DCAS, why aren’t they? Who has
them? If DCAS cannot abtain all four reports, how can they emphatically assert that there were no
problems with the worker bioassay program? Will we ever learn the whole truth?

While my petition is only a year old, these issues regarding the Rocky Flats site have been around for
more than 8 years, when the first petition was filed. When is the Board going to say “Enough is enough”
to DCAS? You know, when DCAS releases the other white papers that were due months ago, me, Terrie,
the Rocky Flats workers and other supporters will be crawling through every document we can tay our
hands on to show that NIOSH is wrong. They've been wrong for eight years how. And it’s because they
refuse to accept that the paperwork they are using is corrupted.

{, too, want to thank all the Rocky Flats workers and other advacates who have helped me with this
petition. There's a lot of information and explanations that Terrie and | couldn't relay ta you today
because of the ten minute time limit. | hope in October when the Board comes to Denver, we'll have as
much time as we need to explain our position.

We will ask that the full document we prepared and the power point be posted to the DCAS website.
Thank you for your time and we'll be happy to answer any questions.


DOE Sites had different bioassay
procedures

1985 document titled, “Current Internal-Dosimetry
Practices at U.S. Department of Energy Facilities.”

i.qov/bridge/serviets purl/583150¢

tty WV
>06.pdf
pat.

. “The information gathered from the questionnaire
responses illustrates the diversit of internal-dosimetry
practices at DOE facilities... The differences include
different i cen in the use of quality control
samples, different minimum detection levels, different
methods of recording radionuclides, different amounts
of data recorded in the permanent record, and apparent
differences in modeling the metabolism of
radionuclides within the body.”


DNFSB CONCERS WITH ROCKY
FLATS - 1994

“Equipment used for monitoring air for
radioactivity does not meet the Manual’s
sensitivity requirements, but short and long
term improvement efforts are in progress.”

http
00192_petition review.pdf

tS

a

eecap.org/PDF_Files Colorado/Rocky_Fla