SERVICES
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CHAIRMAN:

Paul L. Ziemer, Ph.D.
Lafayette, Indiana

MEMBERS:

Josie Beach
Richland, Washington

Bradley P. Clawson
Rexburg, Idaho

Michael H. Gibson
Franklin, Ohio

Mark A. Griffon
Salem, New Hampshire

James E. Lockey, M.D.
Cincinnati, Ohio

James M. Melius, M.D., Ph.D.

Albany, New York

Wanda |. Munn
Richland, Washington

John W. Poston, Sr., Ph.D.
College Station, Texas

Robert W. Presley
Clinton, Tennessee

Genevieve S. Roessler, Ph.D.

Elysian, Minnesota

Phillip Schofield
Bosque Farm, New Mexico

STAFF:
EXECUTIVE SECRETARY:

Lewis V. Wade, Ph.D
Washington, DC

COMMITTEE MANAGEMENT :

LaShawn D. Shields
Atlanta, Georgia

ADVISORY BOARD ON RADIATION AND WORKER HEALTH
4676 Columbia Parkway, MS: C-46

Cincinnati, Ohio 45226
(513) 533-6825

July 2, 2007

The Honorable Michael O. Leavitt
Secretary of Health and Human Services
Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Dear Mr. Secretary:

The Advisory Board on Radiation and Worker Health (The Board) has
evaluated SEC Petition-0030 concerning workers at the Rocky Flats facility in
Denver, under the statutory requirements established by EEOICPA and
incorporated into 42 CFR Sec. 83.13 and 42 CFR Sec. 83.14. The Board
respectfully recommends Special Exposure Cohort (SEC) status be accorded
to all employees of the DOE, its predecessor agencies, or DOE contractors or
subcontractors who were monitored or should have been monitored for
neutron exposures while working at the Rocky Flats facility in Denver,
Colorado for a number of work days aggregating at least 250 work days
during the period from January 1, 1959 through December 31, 1966, or in
combination with work days within the parameters established for one or
more other classes of employees in the SEC. The Board finds that although
there are insufficient data available to reconstruct neutron dose with sufficient
accuracy for all members of the class during this time period, the Board
believes that NIOSH may be able to reconstruct other components of the
internal and external dose, and therefore individuals with non-presumptive
cancers may be considered for partial dose reconstructions.

This recommendation is based on the following factors:

e It is not clear, based on the review of the data, that the most exposed jobs
were monitored for all years. This is supported by statements made by
NIOSH’s primary site expert regarding the implementation of the NTA
film program. During this time period it is unclear whether the approach
proposed would be bounding for all workers within the class.


The Honorable Michael O. Leavitt July 2, 2007

e Reading the neutron badges in the pre-1963 period involved significant errors due to technical
limitation of the reading protocol (i.e., only a small area of the badge was read).

¢ No independent validation of the NDRP re-read badges was conducted during the project or
during NIOSH’s site profile development.

The Advisory Board is in agreement with NIOSH’s evaluation report with regard to the ability to
reconstruct radiation doses for the period from 1967 through 2005 and for all radiation doses other than
neutron doses from 1952 through 1966. Through the review process of the Rocky Flats petition (SEC-
0030) NIOSH has made several important modifications to the dose reconstruction approach, and the
Board notes that NIOSH has committed to re-evaluation of all affected cases in a timely manner. The
primary changes of concern include but are not limited to:

e NIOSH will use a modified approach for assessing internal doses due to “Super S” plutonium
for all affected cases

e¢ NIOSH will use a modified internal dose co-worker approach of using the 95" percentile
values of the electronic data in estimating worker dose via the co-worker internal dose model
for all affected cases.

e NIOSH will use a modified internal dose co-worker approach for D & D workers by using the
95" percentile values of the electronic data in estimating worker dose via the co-worker

internal dose model for all relevant radionuclides for all affected cases.

¢ NIOSH will use a modified approach for re-assessing neutron doses for the time period from
January 1, 1967 through December 1970 for all affected cases.

The Board strongly recommends that the re-evaluations described above be completed in a timely
manner.

Enclosed is supporting documentation from the Advisory Board Meeting held in Denver (Lakewood),
Colorado on June 11-12, 2007 and other meetings where this special exposure cohort class was

discussed. If any of these items are unavailable at this time, they will follow shortly.

Sincerely,

Paul L. Ziémer, Ph.D

Chairman

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